TAVMA strongly disputes the substance of the on-line petition Jennifer J. Johnson, Secretary Board of Governors of the Federal Reserve System Re: Interim Final Rule – Customary and Reasonable Fee Stipulation Dear Ms. Johnson: The Title Appraisal Vendor Management Association (“TAVMA”) wishes to express its views about the misinformation being disseminated by appraisal organizations and publications about the Federal Reserve’s Interim Final Rule and Appraisal Management Companies (“AMC’s”). TAVMA is a national trade association of real estate settlement services providers including many leading appraisal management companies. Some appraisers continue to attack AMC’s by asserting that the DOD Frank Act, TILA...
LandSafe Appraisal Services, a wholly owned subsidiary of Bank of America, recently released its latest “Appraisal Services Agreement” to its panel appraisers. The agreement includes, among others, indemnifications of LandSafe against any liability, and loss of intellectual rights. If this goes through and appraisers agree to sign this new agreement, other AMCs will follow LandSafe’s lead and produce their own version of Appraisal Services Agreements. LIA Insurance has reviewed the new LandSafe Appraisal Services Agreement. The review is available to LIA’s insured appraisers and READI members but others can also view it by registering with code 201700. The whole idea of appraisers as...
…excluded from Reasonable and Customary fee surveys… The American Guild of Appraisers (AGA) / Guild 44 of the Office and Professional Employees International Union, AFL-CIO met with Representative Barney Frank (D-MA) on April 14 to discuss the Guild’s concerns with the Federal Reserve Board’s Interim Final Rule (Rule) regarding Appraiser Independence. With the implementation of the Rule issued April 1, 2011, the Federal Reserve has introduced faulty regulation that implicitly fails to capture Congressional intent to reform the appraisal process and Appraiser Independence and the necessity to promote the use of market driven, Reasonable & Customary (R&C) fees for various...
Lenders May Still Profit Most from Appraisal Fees, writes Kenneth Harney WASHINGTON — When you pay $450 to $550 at settlement for an appraisal on a home purchase or refinancing, do you assume that all or most of the money is going to the appraiser who comes to the house and performs the valuation? That’s logical, but probably not correct. Despite new Federal Reserve regulations that took effect April 1 requiring lenders to pay appraisers fair fees, growing numbers of them say they are still being offered $200 to $250 — even as low as $134 — for work that...
Where To Direct Questions and Comments Regarding Customary and Reasonable Fees There has been a lot of confusions about where appraisers can direct questions and comments regarding customary and reasonable fees. The Appraisal Subcommittee has recently posted the following information: The appropriate agency to receive your concern about a creditor’s compliance with the Truth in Lending Act (TILA), including the creditor or the creditor’s agent paying an appraiser a customary and responsible fee, is the agency that enforces TILA for the creditor. If the agent or appraisal management company (AMC) is affiliated with a federally-regulated creditor, the appropriate agency to receive...
Appraisers online petition opposing use of AMC fees as Customary & Reasonable Please consider signing the online petition launched by appraisers and written by George Hatch, opposing the use of AMC fees as Customary & Reasonable: Federal Reserve Board to Clarify Customary and Reasonable Appraisal Fees On October 18, 2010, the Federal Reserve Board announced an interim final rule to Regulation Z of Title 12, also known as the Truth in Lending Act (TILA). One of the elements to Regulation Z is a binding requirement upon creditors and appraisal management companies to ensure that appraisers who are not employees of...
Who to Call? Fellow appraisers, peers, coalition members and all who work as professional real estate appraisers, we ask for your help. Federal Law known as the Dodd-Frank Act went into effect on April 1, 2011. It clearly states and intends that real estate appraisers be paid “Reasonable and Customary” fees for appraisals performed by state licensed and certified real estate appraisers. Reasonable and customary, generally means what appraisers in a geographic area are generally paid based on a survey of such fees. The survey is supposed to be of fees paid by such entities as the Department of Veterans...
A new frontier in appraising is upon us… Approximately 30 years ago the automobile industry began to introduce computers into cars and since that time they have never been the same. What was once considered a rather simple procedure – tuning up your engine or even changing the spark plugs – has become an almost impossible project for anyone, except the highly trained automobile technician. Today nearly every aspect of your car is aided or controlled in some manner by a computer. Digital radios with CD players, climate control systems, cruise control and pollution control devices are just a few...
