The purpose of collecting your personal information is nothing more than for me to be able to do random audits. Obviouly there needs to be assurance that those taking the survey are indeed licensed appraisers. It is also to ensure that appraisers respond ony once.No personal info will be published in survey results.
I need a significant response to be meaningful. It is possible that implementation could get delayed if they don't have surveys to rely upon. So please pass the link on to every appraiser you know,
www.feesurvey.com.
I have engaged a university professor to compile the results and analyze them. I am seeking data from multiple lenders as well although this isn't as easy as it might seem. Some bundle the appraisal fee with credit and other fees into an application fee.
Joan,
The implementation has been delayed because it was effective at the signing of the bill by the president, that Appraisers were to be paid the C&R fees.
Now, you are all running to make up surveys of what fees Appraisers will
ACCEPT as customary and reasonable,
when in fact HUD policy since 1997 has been that the
combined fees of Appraisal and Appraisal Management have been
THE appraisal fee and could not be charged to the borrower any more than what is Customary and Reasonable.
The survey needs to be of the fees that where charged to borrowers over the past year. Those fees are recorded on the HUD 1 Statements. Which should be in the files of all the nifty title companies, which are also TAVMA members, so get them to start faxing over those HUD 1 statements because that is the real proof., not surveying appraisers that could not dictate their own fees for lending work over the past year and including additional time, expense and liability for the 1004-MC form, dealing with ever changing "new" client requirements and mandates, and all the call backs cause by thrid party providers that do not read the reports and ask for comment s that are in reports. Very few appraisers have been able to charge extra for these "problem" clients that hold paychecks, 30, 60, 90, 120+ days. Let's face it, if I'm paid at the door I would probably accept less than if I have to make 3 phone calls and wait 120 days to get paid. All of these considerations need to be included in fees.
Please reference Mortgage Letters 97-22, 97-46, 2008-43 and 2009-28 Here you will find the definitions that state that the combined appraisal and management fees can not be more than the C&R appraisal fee, and since AMCs took over the lending end of the appraisal business, your survey needs to be those fees that have been charged and paid by the borrowers.
I'm sure you knew this already because you are a smart women, so let us question why you feel the need to ensure that your survey takers are appraisers?
Is it perhaps because appraisers may not know that HUD mandated combined fees could not be more than customary and reasonable therefore you could get a bunch of appraisers to say they would accept less than what is already being paid, leaving money on the table for the industry leeches to grab?
Regardless to your survey results, either borrowers have been charged more than the customary and reasonable appraisal fees over the past year and might be able to file class action suites because of it, or, consumers have been charged the customary and reasonable appraisal fees and that now is the fee that must be paid to the appraisers, leaving the AMCs to collect their fee from their clients, the banks.
