Low AMC Appraisal Fees? FDIC Wants to Hear from Appraisers
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AMCs paying low fees, Appraisers and Regulation Z of TILA
VaCAP recently learned of some encouraging news. The FDIC wants Regulation Z to be followed and will enforce it for appraisers. Here is what VaCAP received from an appraiser who reached out to the FDIC:
I just had a call from an extremely pleasant lady named Susan Welch from the FDIC Consumer Response Center (1-800-378-9581). I had sent a note over regarding an AMC attempting to get me to sign a “Base Fee Letter” agreeing to a drop of my base fee for full appraisals to $325 from $400-500. She said the FDIC is VERY interested in hearing from appraisers regarding AMCs paying low fees. As you know FDIC regulates the banks, who are responsible for third party oversight with AMCs they engage. FDIC wants Regulation Z to be followed and will enforce it for appraisers.
Incidentally I opted to have them proceed while keeping me anonymous, a la whistle blower status. Susan said she would be surprised if they had not investigated this within 90 days.
FDIC bank examiners will contact the bank involved and look at their procedures for engaging appraisers, look at fees appraisers are actually paid versus what is considered C&R based on things like the VA sheet and go from there.
Instead of appraisers complaining about AMCs paying low fees, it’s best for us all to take a little time and file an appropriate complaint.
The FDIC VERY much wants to hear from appraisers and is VERY INTERESTED in appraisers not being paid C&R. They cannot do anything about AMCs directly, but the banks sure can.
Federal Deposit Insurance Corporation
Consumer Response Center
1100 Walnut St, Box #11
Kansas City, MO 64106
Complaints against AMCs go to:
Regulatory Programs and Compliance Section
Department of Professional and Occupational Regulation
9960 Maryland Drive, Suite 400
Richmond, Virginia 23233-1463
Phone: (804) 367-8504
FAX: (866) 282-3932
Make sure to follow the proper procedures to file your complaint. There is nothing worse than having the complaint dismissed due to a technicality!