Where To Direct Questions and Comments Regarding Customary and Reasonable Fees The appropriate agency to receive your concern about a creditor’s compliance with the Truth in Lending Act (TILA), including the requirement for the creditor or the creditor’s agent (including an AMC) to pay an appraiser a customary and reasonable fee, is the agency that enforces TILA with respect to the creditor. With respect to insured depository institutions of more than $10 billion and their affiliates, the Consumer Financial Protection Bureau (CFPB) is the appropriate agency. For other non-depository institutions, the appropriate agency to receive the complaint is the CFPB...
FOR IMMEDIATE RELEASE – February 2, 2012 Contact: Paula Douglas Seidel, Executive Administrator, The Appraisal Foundation Washington, DC — A recent survey conducted by the Government Accountability Office (GAO) of state appraiser regulatory programs has produced high marks for The Appraisal Foundation regarding its effectiveness in issuing appraisal standards and appraiser qualifications. The survey, which was performed in conjunction with the GAO study issued last month entitled “Real Estate Appraisals: Appraisal Subcommittee Needs to Improve Monitoring Procedures,” contained 65 questions relating to the effectiveness of the current real property appraiser regulatory system. In addition to the effectiveness of the Foundation,...
On January 18, 2012, the US Government Accountability Office (GAO) released their report on real estate appraisals “Appraisal Subcommittee Needs to Improve Monitoring Procedures” as required per Dodd-Frank. GAO was tasked with 1) determining how the Appraisal Subcommittee (ASC) is carrying out its Title XI responsibilities, 2) ASC’s plans to implement Dodd-Frank provisions, and 3) regulatory dollar thresholds for determining when an appraisal is required. GAO reports that one of the challenges faced by ASC is in the area of resources and planning. GAO cites the creation of a national hotline as one example of a Dodd-Frank requirement that could...
