Customary and reasonable fees - 90 days

[Frederick]

We should have some indication as to what will occur regarding C & R soon.

Like all mandates AMCs and lenders begin implementing them before they actually go into effect.

No.....I don't expect them to pay one dime more before they have to but I expect lenders to start getting notified by AMCs of what the new C & R appraisal fees will be and what their management fee will be so that all business in the pipeline prior to the drop dead date will have proper fees committed to them.

It will also be an opportunity for more efficient AMCs with more competitive management fees and more qualified appraisers on their panel to grab business from others.

I just answered a inquiry by an AMC asking me to expand on the profile of my experience in their system. I expect some AMCs to tout appraiser panels with high percentages of certified, experienced and possibly designated appraisers as a marketing tool.

Keep your ears open and post if any of your lender friends start getting any new fee schedules.

We are what? ...about 6 weeks out?

 

[Sulago]

Let's just wait till the effective date of 10-20 ...

when are Usual and Customary Fees applicable to our assignments? The actual answer is July 22, the day after the President signed the bill. That fee implementation language is contained in the bill and is separate from Appraisal Independence issues that regulators will define up to 90 days later.

The above taken from Dave Towne.

"Hey, just be glad you're getting customary and reasonable for the two assignments a month that the licensed AVMs aren't taking."

FEE APPRAISER DEFINITION- For purposes of this section, the term `fee appraiser' means a person who is not an employee of the mortgage loan originator or appraisal management company engaging the appraiser ...

From the Dodd‐Frank Wall Street Reform and Consumer Protection Act.

 

[KenAZ]

Like all mandates AMCs and lenders begin implementing them before they actually go into effect.

Haha, as long as it is not a burden on THEM

 

[saxon]

looks like most of the AMC's are weaseling out of the fees one way or another

 

[twells05]

looks like most of the AMC's are weaseling out of the fees one way or another

We as a group have already proven that we will not stand up to them so the question becomes, can they weasel out of the fines?

 

[WorkingTogether]

What fines? And how will a violation be proven? To whom or to what should allegations of violations be deleivered?

 

[saxon]

Can state boards put teeth in this new "law"?

 

[ezradams]

Seymon,

Each state will be required to produce AMC regulations as per this law. It is up to appraisers from within each state to push local legislation in that direction.

 

[WorkingTogether]

Aren't AMCs that are owned by banks exempt from state registration and regulation?

 

[hastalavista]

Aren't AMCs that are owned by banks exempt from state registration and regulation?

Exempt from state regulation but not federal regulation.
The regulatory agency that oversees the institution that owns the AMC will also oversee the AMC.

Based on everything I've ever heard from people I know in the regulated banking industry, they are a lot more fearful of their federal regulator than they are of the state regulator.