Appraisal and AMC Fees Separated on Revised Settlement Forms
The Consumer Financial Protection Bureau released the second proposed version of a new Consumer Disclosure Form Feb. 1 that includes clear disclosure of any fee paid to a “Local Appraisal Company” and to an “Appraisal Management Company.”
The Appraisal Institute reported last month that the CFPB is in the midst of developing a new form that would replace the existing HUD-1 settlement statement. In December 2011, Appraisal Institute representatives met with CFPB officials about the new form.
The CFPB has indicated that several versions of the proposed form will be developed and tested with consumers by focus groups, with a proposed rule to be released this summer.
No final decision has been made as to whether to require separation of fees, to allow for them, or to continue bundling the fees. The most recent draft gives an indication of what full disclosure would look like. The Appraisal Institute intends to offer suggestions to the CFPB.
Click here to view the two versions that have been tested in the Philadelphia market during the past month. The CFPB is not taking public comment at this time, but it is expected to issue a Notice of Proposed Rulemaking this summer and will seek input at that juncture.
Additionally, the CFPB is concurrently developing a new Good Faith Estimate (Loan Estimate) form. The Appraisal Institute released Feb. 2 also includes separate lines for Appraisal and Appraisal Management Company fees.
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WORD OF CAUTION: Don’t count your chickens before they’ve been bribed appraisers.
The U.S. government lives for playing cruel pranks on appraisers on April Fool’s Day.
April 1, 2009: 1004MC
May 1, 2009: HVCC (I know…they couln’t wait)
April 1, 2011: C & R Fees Manditory (yeah right)
April 1, 2012: ????
I agree with a lot of other appraisers. Make the AMC’s file an IRS Form SS-8 – Request for Determination -status and watch them drop like flies…
Many states are already demanding total itemized appraisal fee breakdowns in their own emerging legislation.
If a fee is not legit, and is kept in secret, it’s potentially a garbage or junk fee.
Junk fees – no go – abort! Consumers never know though. That’s why total appraisal fee distribution disclosure is highly necessary.