AGA to Discuss Appraiser Independence & C&R Fees
…excluded from Reasonable and Customary fee surveys…
The American Guild of Appraisers (AGA) / Guild 44 of the Office and Professional Employees International Union, AFL-CIO met with Representative Barney Frank (D-MA) on April 14 to discuss the Guild’s concerns with the Federal Reserve Board’s Interim Final Rule (Rule) regarding Appraiser Independence.
With the implementation of the Rule issued April 1, 2011, the Federal Reserve has introduced faulty regulation that implicitly fails to capture Congressional intent to reform the appraisal process and Appraiser Independence and the necessity to promote the use of market driven, Reasonable & Customary (R&C) fees for various valuation assignments. By injecting a skewed “safe harbor” under Presumption One in section 42(f), the Rule has unwittingly given license to appraisal management companies (AMCs) to use their own internal, non-market, fee schedules to disproportionately justify Reasonable and Customary fees directly in opposition to the Congressional mandate throughout the Mortgage Reform and Anti-Predatory Lending Act (MRAPLA) to have such fees excluded from Reasonable and Customary fee surveys.
Guild National President Peter Vidi requested that Rep. Frank write a letter to the Federal Reserve regarding the Rule, pointing out its significant deviation from the intent of MRAPLA.
“Congressional intent to restate the market survey for Customary and Reasonable Fees was not to include fees paid by appraisal management companies,”
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