Wes Costello
Freshman Member
- Joined
- Jul 6, 2006
- Professional Status
- Appraiser Trainee
- State
- Pennsylvania
The NJ State Department of Banking and Insurance has ended the practice of setting appraisal fee maximums for particular owner occupied properties. The purpose of their usual, customary, and reasonable was not to set a minimum that AMC's and lenders must pay be a maximum that could be charged to borrowers for conforming, single family primary residences
The Public Notice from December 2012 was still in effect. It set the maximum fee that could be charged to the borrower as $400 if the lender was going direct to the appraiser. $450 if an AMC was used.
As a lender, there were certain instances where the fee was too restrictive. Especially for complex properties.
Many AMC's and some lenders who operating in NJ were not even aware of the restrictions, at least until they received a state audit. No AMC that our lender ever interviewed was aware of them. As a lender, we were and do not use AMC's.
I see the retirement of this as a positive. I have not found the actual statue or Public Notice yet, but was I have seen reported is interesting, "The Department has adopted a simple requirement that an appraisal fee charged to a consumer must total no more than the amount charged by a third-party appraiser." I assume they must have an exception in the case of the AMC.http://blogs.claconnect.com/residen...y-adopts-provisions-regarding-appraisal-fees/
The Public Notice from December 2012 was still in effect. It set the maximum fee that could be charged to the borrower as $400 if the lender was going direct to the appraiser. $450 if an AMC was used.
As a lender, there were certain instances where the fee was too restrictive. Especially for complex properties.
Many AMC's and some lenders who operating in NJ were not even aware of the restrictions, at least until they received a state audit. No AMC that our lender ever interviewed was aware of them. As a lender, we were and do not use AMC's.
I see the retirement of this as a positive. I have not found the actual statue or Public Notice yet, but was I have seen reported is interesting, "The Department has adopted a simple requirement that an appraisal fee charged to a consumer must total no more than the amount charged by a third-party appraiser." I assume they must have an exception in the case of the AMC.http://blogs.claconnect.com/residen...y-adopts-provisions-regarding-appraisal-fees/
