FFIEC Requested Action on TRID
The American Guild of Appraisers, Chapter 44, of the Office and Professional Employees International Union of the AFL-CIO (AGA, OPEIU/AFL-CIO) wishes to add its name to the attached letter on behalf of our professional appraiser members, and our thirteen million consumer members and their families, with the additional concerns:
As written, TRID necessarily embeds an appraisal fee cap determined by third party service providers other than appraisers, within the initial consumer disclosure provided to prospective borrowers.
The perception of these providers as to what constitutes “customary and reasonable fees” as required under Dodd-Frank is at odds with what appraisers consider to be customary and reasonable. Current procedures for determing C&R fees are also ambiguous and subject to gross abuse.
TRID also incorporates non-appraiser third fees under the term “Appraiser Fees.” These are more properly described as lender and or third party appraisal management related administrative fees. Incorporating them as a single line disclosure item misleads consumers as to the true cost of real estate appraisals, and subjects them to added risk of inadequate service.
We urge that CFPB be directed to work with all national appraiser guilds, peer organizations and state coalitions in order to resolve these issues at the same time they are dealing with the other concerns cited in the original letter.
Peter Vidi, President
ABOUT THE AMERICAN GUILD OF APPRAISERS/OPEIU GUILD 44 – The American Guild of Appraisers/OPEIU Guild 44 seeks to represent the interests of appraisers, developing a strong presence before the U.S. Congress and each of the state legislatures. By working closely and exchanging dialog with other like-minded organizations, the AGA works to educate consumers about the appraisers’ non bias, independent role in the value process, while ensuring the accountability of both the appraisal profession and the financial institutions with which the appraiser provides services.
ABOUT OPEIU – The Office and Professional Employees International Union (OPEIU), AFL-CIO represents more than 104,000 members in the United States, Puerto Rico and Canada. OPEIU represents employees and independent contractors in banking and credit unions, insurance, higher education, shipping, hospitals, medical clinics, utilities, transportation, hotels, administrative offices and more.
Professional organizations and Guilds affiliated with OPEIU are a diverse group that includes nurses, pharmacists, chiropractors, appraisers, podiatrists, clinical social workers, minor league baseball umpires, teachers and helicopter pilots.