Reasonable and Customary Fees – Who to Call?
Who to Call?
Fellow appraisers, peers, coalition members and all who work as professional real estate appraisers, we ask for your help.
Federal Law known as the Dodd-Frank Act went into effect on April 1, 2011. It clearly states and intends that real estate appraisers be paid “Reasonable and Customary” fees for appraisals performed by state licensed and certified real estate appraisers.
Reasonable and customary, generally means what appraisers in a geographic area are generally paid based on a survey of such fees. The survey is supposed to be of fees paid by such entities as the Department of Veterans Affairs (VA) or by surveys completed by a variety of others, not including Appraisal Management Companies (AMC’s). Many surveys have been done by Alamode, The Buzz Forum, and others.
As soon as the federal law went into effect on April 1, 2011, major Appraisal Management Companies (AMCs) immediately came out with new fee schedules that LOWERED fees offered appraisers who do work for those AMCs and anyone else who wishes to do work for them.
Whether or not this is a violation of Federal Law is and will be decided by others, likely in court.
However, it at least appears to be a violation of the spirit of the law, and a slap in the face of appraisers, the Congress of The United States that passed the law, and The President of the United States that signed the law.
We call on you to make your concerns known to federal regulators by immediately contacting those regulators at:
Call or email the Appraisal Subcommittee, http://www.asc.gov/, and it’s Executive Director, Jim Park at firstname.lastname@example.org and perhaps your state board as well.
If you have a copy of any AMC’s fee schedule sent to you on or after April 1, 2011, as well as what others such as the VA consider to be reasonable and customary, please attach that as well when contacting such regulators.
We can do this.