Customary and reasonable fees - 90 days

[Non Sequitur]

The law doesn't say that lenders and AMCs can't entertain bids that are less than the established R&C, but it doesn't say they can either. It's sort of a chicken/egg thing, and one for the lawyers to hash out. I've read enough legal rulings (and my mother's a contract attorney and agrees with me) to feel that if it isn't explicitly provided for, or even implicitly in this case, you can't do it. We shall certainly see, won't we?​

Good points. But I have two arguments. First I don't believe for one second that if appraisers consistently offer (for example) $200 per typical 1004 that anyone will hold the line and define C&R as $350. Second I agree that lawyers will hash this out and that is a big problem. Once again we find ourselves at the mercy of outsiders.

The way it is currently written, it does prevent the lender from paying below C&R. If they cannot pay below C&R, then how will the fees be driven down?

See above.

That is what is currently says. If it changes, then who knows.

What is written is one thing, what those who are really in charge say it means is what I'm afraid of.

IMO we'll regret the day someone defined what our "reasonable and customary" fee should be. If it's set in stone we'll have a war when it's time to raise it, if there's some flexibilty lenders will use it to drive fees down.

 

[kevco]

And the debate begins. Some are starting to see the downside of this new bill instead of thinking it's the holy grail. Again, for every action, there is an equal and opposite reaction by the ones it will effect. The banks will have their answer and it won't be the one we are looking for.

 

[Non Sequitur]

And the debate begins. Some are starting to see the downside of this new bill instead of thinking it's the holy grail. Again, for every action, there is an equal and opposite reaction by the ones it will effect. The banks will have their answer and it won't be the one we are looking for.

Little by little the rest of the massive 2,300 page law is coming into focus for some appraisers. While the vast majority of it isn't appraiser specific we will still have to deal with the politics of it all and how appraisal reform in general will fit into the overall scheme.

Just about everyone I talk to (bankers/lenders, staff appraisers) outside of the forum agree on one thing: This law will further consolidate the lending/banking industry. The language will debated for years but onerous regulations are on their way.

That isn't a good thing for appraisers.

 

[Meandering]

The direct contact person at the Federal Reserve Board where you can send a letter to discuss your personal AMC and Customary and Reasonable Fee situations, or anything else having to do with appraiser independence. (Can include Stips and mandatory comparable requirements and mandatory Cost Approach).


Please do so in the next few days, as new appraisal regulations are being drafted now, with implementation set for October, or perhaps sooner.

Here is the contact information for the person at the Fed that is handling the Interim rulemaking on appraiser independence (including customary & reasonable fees):
Pleasant

Ms. Sandra Braunstein
Director
Division of Consumer and Community Affairs
Federal Reserve Board
(email me for the mailing address)

NO EMAIL ADDRESS IS AVAILABLE YOU NEED TO use the US MAIL OR FED EX YOUR LETTER. FOR THE PRICE OF A STAMP YOU CAN BE HEARD.

I strongly suggest you provide your own letter in your own words, rather than rely on ‘template’ content from another source. Keep it short and to the point.

The FRB needs to hear from as many ‘boots on the ground’ appraisers as possible.

For the mailing address email me questions@poconorealestatenews.com

If you want to tell them all about AVMs, this is your opportunity to tell somebody in the government who can make a difference.

It's put up or shut up time.