Customary and reasonable fees - 90 days

[Meandering]

Denis,

We got that appointment, canceled one less important and have fit it into the schedule, so yes, we will be there looking for answers.

Please see my post in the General Appraiser discussion that we need everyone's help.


.

 

[hastalavista]

Denis,

We got that appointment, canceled one less important and have fit it into the schedule, so yes, we will be there looking for answers.

Please see my post in the General Appraiser discussion that we need everyone's help.


.

Outstanding; so then I will not pursue my own communicaton so as not to confuse anyone.

I did read the other thread; I am fortunate that I do not have any clients who make the kinds of demands you ask about. I have no doubt that you'll have a full file from those who do!

Thanks again!

 

[Meandering]

I can appreciate that you don't experience these things, but please do,

pass it on to every appraiser you know.

I have a full case of paper and want to print it all.

There is a ton of this information out there and we need to present it, or else, it is only us that know about it.

They cannot help us fix it if they do not grasp the depth and breath of the problems.


stay well.


Me

 

[Mike Kennedy]

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

From State Registration - Yes.

 

[Sulago]

The new Consumer Financial Protection Bureau or a state attorney general has explicit authority to enforce appraiser independence requirements. The CFPB is expected to be operational within 18 months.

 

[prasercat]

AI finally stepping up to the plate! I'm particularly interested in the words regarding appraiser independence enforcement and customary fees under "expedited rulemaking process..... commencing in October" They appear to be trying to get everyone on the same page, from fee survey to lender, etc.

... pasted below from AI newsletter:


Appraisal Institute Releases FAQ on Dodd-Frank Financial Reform Law

[FONT=Arial, Helvetica, sans-serif]The Appraisal Institute has issued clarifying information regarding appraisal provisions found in the newly enacted Dodd-Frank Wall Street Reform and Consumer Protection Act. The Aug. 31 list of frequently asked questions addresses issues relating to enforcement of customary and reasonable fee provisions and upcoming rulemaking procedures.

Of note, the FAQs clarify that the new appraiser independence requirements, including the provisions relating to customary and reasonable fees, can be enforced by state attorneys general under the Act. This enhances the authority of the new Consumer Financial Protection Bureau, the lead enforcement agency of the Truth in Lending Act and other consumer protection laws.

In follow-up to the law, the Appraisal Institute announced it will be soliciting bids for a fee survey that would meet the criteria for customary and reasonable fees found in Dodd-Frank, receive broad industry support, and adhere to generally accepted research standards. The RFP will be disseminated to interested parties and the academic community.

“These FAQs are intended to clarify several misconceptions that we have seen within the lending and appraisal communities regarding the appraisal provisions found in Dodd-Frank,” said Richard Maloy, SRA, chair of the Appraisal Institute’s Government Relations Committee. “Most pressing are those provisions dealing with appraiser independence and payment of customary and reasonable fees, both of which are under an expedited rulemaking process. Lenders, their agents, and appraisers should have no doubt that these requirements will commence in October of this year.”
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[Meandering]

The Appraisal Institute has issued clarifying information regarding

That's interesting since the law says only the CFPB can interpret the laws. AI has lawyers interpreting the law?

 

[jnordquist]

AI finally stepping up to the plate! I'm particularly interested in the words regarding appraiser independence enforcement and customary fees under "expedited rulemaking process..... commencing in October" They appear to be trying to get everyone on the same page, from fee survey to lender, etc.

... pasted below from AI newsletter:


Appraisal Institute Releases FAQ on Dodd-Frank Financial Reform Law

[FONT=Arial, Helvetica, sans-serif]The Appraisal Institute has issued clarifying information regarding appraisal provisions found in the newly enacted Dodd-Frank Wall Street Reform and Consumer Protection Act. The Aug. 31 list of frequently asked questions addresses issues relating to enforcement of customary and reasonable fee provisions and upcoming rulemaking procedures.

Of note, the FAQs clarify that the new appraiser independence requirements, including the provisions relating to customary and reasonable fees, can be enforced by state attorneys general under the Act. This enhances the authority of the new Consumer Financial Protection Bureau, the lead enforcement agency of the Truth in Lending Act and other consumer protection laws.

In follow-up to the law, the Appraisal Institute announced it will be soliciting bids for a fee survey that would meet the criteria for customary and reasonable fees found in Dodd-Frank, receive broad industry support, and adhere to generally accepted research standards. The RFP will be disseminated to interested parties and the academic community.

“These FAQs are intended to clarify several misconceptions that we have seen within the lending and appraisal communities regarding the appraisal provisions found in Dodd-Frank,” said Richard Maloy, SRA, chair of the Appraisal Institute’s Government Relations Committee. “Most pressing are those provisions dealing with appraiser independence and payment of customary and reasonable fees, both of which are under an expedited rulemaking process. Lenders, their agents, and appraisers should have no doubt that these requirements will commence in October of this year.”
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Anyone have a copy of the pdf download for this article? The link will not open on my end

 

[prasercat]

Anyone have a copy of the pdf download for this article? The link will not open on my end

They have a problem with this link from the AI Appraiser News Release. Go to the AI website, choose the "News and Advocacy" tab, on the left side choose "Key Documents" and then click on the top listing "....FAQ on Dodd Frank Financial Reform Law" . It will then download - about 1.6 Megabites.

 

[Elliott]

And this is the way Stars see's it:

Important message from STARS:

STARS has been receiving inquiries in reference to the impact of the Dodd-Frank Financial Reform Bill (HR 4173), specifically around what STARS will be doing to ensure that “reasonable and customary” fees are to be paid to appraisers.

As more defined guidelines are promulgated by the Federal Reserve Board regarding Customary and Reasonable Fees, STARS will pro-actively evaluate the requirements, address any necessary changes and communicate results to our appraiser network.

At this time our current fee schedules are still in effect and fee changes will approved per our current policy based on complexity of the assignment.