Questions & Comments RE Customary and Reasonable Fees
Where To Direct Questions and Comments Regarding Customary and Reasonable Fees
The appropriate agency to receive your concern about a creditor’s compliance with the Truth in Lending Act (TILA), including the requirement for the creditor or the creditor’s agent (including an AMC) to pay an appraiser a customary and reasonable fee, is the agency that enforces TILA with respect to the creditor. With respect to insured depository institutions of more than $10 billion and their affiliates, the Consumer Financial Protection Bureau (CFPB) is the appropriate agency. For other non-depository institutions, the appropriate agency to receive the complaint is the CFPB or the Federal Trade Commission. There are two websites that you can use to find the federal regulator for a creditor that is an insured depository institution of $10 billion or less:
- Federal Reserve System – National Information Center website; and
- FDIC website at the “Bank Find” webpage
Questions regarding the appropriate interpretation of the Truth in Lending Act, including those on customary and reasonable fees, should be directed to the Consumer Financial Protection Bureau, Office of Research, Markets and Regulation.
If the concern regards payment of customary and reasonable appraisal fees is related to a specific appraisal assignment or assignments, you can also contact the State appraisal board or agency in which the property or properties are located to find out if they have enacted appraisal laws and/or regulations that address your concern.