Tagged: Customary & Reasonable Fees

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Questions & Comments RE Customary and Reasonable Fees

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...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations / Appraisal Subcommittee

American Guild of Appraisers Petitions Fed 0

Fed Petitioned by American Guild of Appraisers

American Guild of Appraisers Petitions Fed and Consumer Financial Protection Bureau to Overturn Regulation that Threatens Viability of Professional Appraisal Practice WASHINGTON, Feb. 23, 2012 /PRNewswire-USNewswire/ — The American Guild of Appraisers (AGA), a national organization of real estate appraisers that is an affiliate of the AFL-CIO’s Office and Professional Employees International Union (OPEIU), has petitioned the Federal Reserve Board (“Fed”) and the Consumer Financial Protection Bureau to overturn a regulation adopted by the Fed that is contrary to the Dodd Frank Financial Reform law, threatens the viability of professional appraisal practice and undermines the legitimacy of real estate appraisals...

AGA / AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations

Appraisal and AMC Fees Separated on Revised Settlement Forms 4

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...

AI / AMC / Appraisal / Appraisal Institute / Appraisal Management Companies / Appraisal News

On Appraisals, Should You Follow the Money? 6

On Appraisals, Should You Follow The Money? Asks Kenneth Harney

Follow the Money Some appraisers are being paid less than half the fee, while the balance flows to an appraisal management company. Washington – The new Consumer Financial Protection Bureau is working on a real estate issue that gets to the core of the agency’s purpose: Bringing clarity and better disclosures about the often opaque and costly fees that homebuyers, sellers and refinancers are hit with at closings. One of the disclosures now under review might surprise you: appraisal charges. Why do they need clarifying? Doesn’t just about everybody who applies for a mortgage, whether it’s to buy a house...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / Dodd-Frank Act / C&R Fees

American Guild of Appraisers Files Request with Federal Reserve Board Seeking Documents Related to Regulations on Customary and Reasonable Compensation of Fee Appraisers 1

American Guild of Appraisers Files Request RE C&R Fees

American Guild of Appraisers Files Request with Federal Reserve Board Seeking Documents Related to Regulations on Customary and Reasonable Compensation of Fee Appraisers WASHINGTON, Jan. 23, 2012 /PRNewswire-USNewswire/ On behalf of the American Guild of Appraisers, today the law firm Garvey Schubert Barer filed a request with the Federal Reserve Board under the Freedom of Information Act seeking a wide variety of documents related to the regulations on customary and reasonable compensation of fee appraisers that were issued by the Board in October 2011. In announcing this action, Guild President Peter Vidi said, “It is clear that appraisal management companies...

AGA / AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations

Appraisal Institute Seeks Separation of Appraisal and AMC Fees 2

Appraisal Institute Seeks Separation of Appraisal and AMC Fees

The Appraisal Institute continues to represent the interests of its members in ongoing rulemakings resulting from the Dodd-Frank Act, including the separation of appraisal and appraisal management fees in order to provide transparency to consumers. Last November, AI and the American Society of Farm Managers and Rural Appraisers urged the Consumer Financial Protection Bureau to separate appraisal fees and appraisal management fees. Last month, Appraisal Institute representatives met with CFPB officials about a new Consumer Disclosure Form slated to replace the current HUD-1. The Dodd-Frank Act authorizes, but does not require, separation of appraisal and appraisal management fees on these...

AI / AMC / American Society of Farm Managers and Rural Appraisers / Appraisal / Appraisal Institute / Appraisal Management Companies

The Louisiana Real Estate Appraisers Board Holds the First Hearing for AMC’s Not Following the Laws and Rules for Determining Minimum Reasonable and Customary Fees - Imagecredit Flickr - GotCredit 0

CFPB Appraisal Fees

ASA has repeatedly stated its belief that the Fed’s interpretation and the massive loophole it created ran contrary to the plain language and clear intent of Dodd-Frank. CFPB Reissues Interim Final Rule On Valuation Independence, Eliminates Federal Reserve Commentary Permitting AMCs To Include Their Own Payments To Appraisers To Comply With Dodd-Frank’s Customary and Reasonable Fee Requirement. On December 22, the Consumer Financial Protection Bureau (CFPB) released an Interim Final Rule dealing with the valuation independence requirements imposed by the Dodd-Frank Act, including the law’s “customary and reasonable” fee mandate. The CFPB’s rule was republished to reflect the transfer of...

AMC / American Society of Appraisers / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News

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FDIC Publication Focuses on Real Estate Valuation Programs

Issues related to real estate appraisal and valuation programs are of critical interest to bankers and regulators. “Navigating the Real Estate Valuation Process,” which appears in the Winter 2011 issue of Supervisory Insights released on December 14, 2011, highlights certain aspects of the 2010 Interagency Appraisal and Evaluation Guidelines (Guidelines). This article also provides information for bankers regarding sound practices for banks’ real estate valuation processes in the areas of valuation review, independence, content standards, preparer selection, and monitoring. “Banks have implemented provisions of the Guidelines, but continue to seek feedback from their regulators on appraisal-related concerns,” said Sandra L. Thompson, Director, Division of...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / Customary & Reasonable Fees

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‘Middleman’ Appraisers Spur Concerns

If you’ve paid for a home appraisal within the last five years, a chunk of that charge likely went to a middleman you never knew existed. And because a third party was used, it might have driven up your closing costs and affected the quality of the valuation. Lenders often use appraisal management companies to block collusion between mortgage brokers and appraisers — and to comply with anti-fraud rules the industry adopted in May 2009. The hotly debated reforms have boded well for the appraisal managers, whose presence in the U.S. has jumped from a handful in the 1990s to...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations / Appraisers News

Wanted: Angry Appraisers 12

Wanted: Angry Appraisers – BankRape

Wanted: Angry Appraisers Experienced residential appraisers have spent the past 30 months wishing for change and wondering if it would ever come.  Most were fooled into believing that justice could be found by writing to politicians, signing petitions, and waiting for their state agencies and appraisal organizations to fix the problem. Nearly two years passed and the remaining appraisers continue to tread water while scanning the horizon for signs of a rescue. Appraisers awakened on April 1, 2011 (Appraiser Fool’s Day) with renewed hope, only to find that the tiny clause within Dodd Frank, “customary AND reasonable fees” had been altered at...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / Customary & Reasonable Fees

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