MBREA Meeting with Congressman Frank RE C&R Fees
Update on MBREA Meeting with Congressman Frank Regarding Customary & Reasonable Fees
One of our readers forwarded MBREA’s email following up on the meeting with Congressman Barney Frank about Customary & Reasonable Fees.
“We recently reported about a meeting MBREA had with Congressman Barney Frank. Congressman Frank is aware of the appraisal professions concerns about customary and reasonable fees and has been working with the Federal Reserve on its interpretation of the statute.
Congressman Frank wrote in a followup letter to MBREA Government Affairs Committee Chair, Allan Cohen, “…I am especially sensitive to any misinterpretation of legislation we enacted because I do not want in any way to be responsible for any harm coming to an important economic activity [appraising] such as yours.” He went on to say, “…I am already one hundred percent convinced of the accuracy of the complaints and have already been working on them.”
Today, we enjoyed a lengthy conversation with one of Congressman Frank’s staff. We discussed the need to establish a complaint hotline for use by appraisers as well as a need for the Federal Reserve to instruct banks about the requirement that fees be both customary and reasonable.
We would like to present Congressman Frank with concrete examples that show lenders and AMCs are unwilling to agree to your request for a fee increase due to the complexity of the assignment or expanded scope of work.
We do not need examples of assignment orders you receive offering fees you consider too low to begin with.
While we would like to receive written documentation between you and the AMC. We will also pass along a well documented history of such an exchange. These examples should show you are requesting a higher fee due to complexity of scope of work, and the rejection of your request by the AMC.
Please send these to firstname.lastname@example.org.”