VaCap Speaking out Regarding C&R Fees
- Federal Valuation Agency Impact on Appraisers & the Public - July 22, 2022
- Is Georgia Going Rogue? - June 13, 2022
- Bias in Automated Valuation Models - February 28, 2022
CUSTOMARY AND REASONABLE FEES
When Dodd Frank was passed a few years ago there was much discussion as to what it actually meant to lenders, appraisers, and AMCs.
AMCs were quick and forceful in their definition. It was the fee they could coerce an appraiser into accepting. That was their definition. This has been a big impact on the well-being of an honorable profession.
In June the Federal Final Rules were released, and they took effect in September of this year. These Final Rules clarified many questions regarding lending, appraising, and AMC involvement. First, the Feds have made it very clear that lenders ARE NOT required to utilize the services of any AMC. Indeed, if they do opt to do so the lender is responsible for the accuracy and reliability of ALL appraisals done by their AMCs. It is clear that lenders have liability for good, honest, and competent appraisals regardless of any involvement of an AMC. AMCs do NOT protect lenders or borrowers.
Second, the Final Rule clearly mandates that customary and reasonable fee definition is left to each state to determine.
On November 17 at DPOR Headquarters on Mayland Road in Richmond is the quarterly Real Estate Appraiser Board meeting. It begins at 10 am.
It is expected that at this meeting the Board will consider customary and reasonable fees. This is important to us all. It appears that DPOR has come to the realization that C & R fees are an important issue that must be settled.
VaCap has been at the center of this issue, not only in Virginia, but also on a national basis through the Network of state appraiser coalitions that represent about 25 states now.
VaCap will speak out regarding C & R. The premise is that the current VA fee in Virginia is fair as the minimum C & R fee to be paid to an appraiser. The utilization and adoption of the VA fee meets all Dodd Frank requirements and definitions, much better that the self-serving, selfish fee maintained and promoted by AMCs.
WHAT CAN YOU DO?
You can and should attend this most important meeting on November 17 to speak or support.
You can and should join VaCap NOW especially if you believe VaCap represents your interests.
Join us on November 17 in Richmond.
Join VaCap TODAY!!!!!