Exactly Mike!!

Generally yes.

Why would you NOT be able to do so? Federal law protects our right to disclose the fee IN our appraisal report.

Federal law also prohibits lenders from telling us HOW or what to write in our reports.

Put a separate text page after TOC or in your transmittal if you want.

I second this proposal

If you’re told to take a formal page out of the report then that’s appraisal direction or violation of appraisal independence??

What I am proposing is: Can we make a separate page as part of the report called

“Disclosure of Appraisal Fee””?

I don’t see how Pat.

An invoice is a bill. Its not normally a part of an appraisal.

NO AMC can prevent us from disclosing what we were paid, in the body of the report (text addendum) or transmittal letter.

Just youtube John Belushi as Bluto

IF we had any funds to hire an attorney to fight the case…. I along with a state coalition specifically asked our State Board for this 5-6 years ago. They punted of course and tabled the decisions which disappeared.

MY last remark was threatening???

Are you smoking crack?

YES WE DO
We are doing great!!
Need all the help we can still collect
The more the better
Thanks!!

But you are using common sense- none of these agencies have that ability!!

No. Any necessary info is redacted prior to submitting it to the appropriate agencies and it is going to a governmntal agency-so that gives you an out as well. Nothing to be concerned about.

Pat, do you still collect data? I mean I can send mine to you.

Just wait till this breaks!!!!

Louisiana lost that case because they didn’t follow APA which a majority of appraisal boards today fail to follow and make rules without proper procedures. At that time you also had a different FTC and having spoken with Director Chopra last month this is a major issue in their radar.

I am way too deep in this with information most don’t have. Including evidence collected from appraisers nationally. What Louisiana had is nothing compared to today’s transgressions and how it’s being approached.

ASA, AI, MBA, NAR, everyone except REVAA has come out for the fee split disclosure. That has taken some monumental effort by a group that is almost ready to go public. They have been behind most of these stance changes and with zero funding.

This is a waste of time and anger. It has been going on for years. The C&R movement died when the State of Louisiana went after AMCs with well documented cases of below C&R fees. And instead of going after the culprit, the DOJ/FTC filed suit against the State of Louisiana. They said the state was attempting “price fixing”. This is a dead issue. We are just howling at the moon.

https://www.valuationlegal.com/2020/10/valuation-legal-brief-louisiana-real-estate-appraisers-board-v-ftc/