Questions Regarding Customary and Reasonable Fees?
Where To Direct Questions and Comments Regarding Customary and Reasonable Fees
There has been a lot of confusions about where appraisers can direct questions and comments regarding customary and reasonable fees. The Appraisal Subcommittee has recently posted the following information:
The appropriate agency to receive your concern about a creditor’s compliance with the Truth in Lending Act (TILA), including the creditor or the creditor’s agent paying an appraiser a customary and responsible fee, is the agency that enforces TILA for the creditor. If the agent or appraisal management company (AMC) is affiliated with a federally-regulated creditor, the appropriate agency to receive complaints against the AMC is the affiliated creditor’s federal regulator. If the agent (or AMC) is not affiliated with a federally-regulated creditor, the appropriate agency to receive the complaint is the Federal Trade Commission.
There are two websites that you can use to find the federal regulator for a creditor:
- 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 Federal Reserve Board.