Twisted AMC & C&R Fees Gone Wrong!
This AMC is Just Wrong & Confused!
An AMC sent an appraiser the following email this morning:
“…..customary and reasonable fees are compliant under Virginia presumption that rates are based on recent rates paid to a representative sample of providers of appraisal services in the geographic market based on the fee schedules of these providers. Please complete the attached form and submit to:“
Wow are they confused about customary and reasonable fees! This is a severe twist on Virginia Regulations for customary and reasonable fee compensation to appraisers. Virginia Law mirrors the language in the TILA. They are essentially the same. The verbiage in the email sent to appraisers by this AMC is just WRONG!
The Virginia Real Estate Appraiser board attempted to make things easy for AMCs. On February 23, 2016 the Virginia Real Estate Appraiser Board adopted the United States Department of Veterans Affairs’ Roanoke Regional Loan Center Appraisal and Inspection Fees Schedule as a presumption of compliance. This was a gift to the AMC’s, but I guess some just don’t want to accept it.
The Virginia Real Estate Appraiser Board created a Guidance Document for AMCs and appraisers to help understand the law. VaCAP sent a copy of the Guidance Document via email and US Mail to the address of record for each AMC licensed to operate in Virginia. As AMCs did not like this clear guidance, they began to twist things around, or just ignore the parts of the legislation they did not like.
As many were still confused, or trying to avoid paying appraisers a customary and reasonable fee, the Virginia Real Estate Appraiser Board published additional guidance on DPOR’s website. They in turn sent this additional clarification along with a copy of the original Guidance Document to each AMC and appraiser licensed to operate in Virginia.
The Virginia Real Estate Appraiser Board has gone out of its way to help the AMCs. It boggles the mind why some refuse to accept it!
And here we are today… The final rules have commentary associated with them explaining each and every provision of the Dodd-Frank Act including customary and reasonable compensation to fee appraisers. Even if you don’t like the rules, we all must follow them.
- AMC Engagement Letter: Appraisers Do Not Include Your Invoice - July 28, 2023
- We the People… - April 9, 2023
- Federal Valuation Agency Impact on Appraisers & the Public - July 22, 2022