customary and reasonable fees

Customary and Reasonable Fees: Making Your Case

The good news for appraisers is that the Financial Reform legislation recently signed into law puts teeth into its mandate that appraisers be paid fees that are “customary and reasonable.” Now what? The “bite” that Congress provided is wording which states that “such fees may be established by objective third-party information, such as government agency fee… Read More

Appraisers Talk, FHA Listens

Appraisers are finally being heard. As a result of grass roots complaints by appraisers about diminishing appraisal quality in industry blogs, publications, the general media, and in a formal appeal by a coalition of appraisal organizations, the Federal Housing Administration (FHA) announced several important policy changes intended to increase accountability and due diligence in the appraisal… Read More

Appraiser Game Changer: Financial Reform Bill Passes (Bye-Bye HVCC)

The Dodd-Frank Wall Street Reform and Consumer Protection Act includes a section referred to as the Mortgage Reform and Anti-Predatory Lending Act in Title XIV. The appraisal activities provisions are located within Subtitle F, which includes the following highlights: Sub prime mortgages will require written appraisal reports by state-licensed appraisers, including an… Read More

Decoding Customary and Reasonable Fees

Congress, recognizing that quality reports are dependent on paying appraisers “fairly,” wrote a customary and reasonable fee provision into Dodd-Frank, and going further, stipulated that any independent studies to determine such fees should specifically not take into consideration fees paid by appraisal management companies (AMCs), suggesting their acknowledgment that AMC fees are artificially low. The Interim… Read More

Fed Board Update: Customary and Reasonable Fees

As implementation of Dodd-Frank takes effect, the Federal Reserve Board shed light regarding the implementation of the customary and reasonable fee provision of the legislation. The Federal Reserve Board, tasked with implementing the landmark Dodd-Frank Financial Reform legislation passed last year, laid out its guidance in the “Interim Final Rule” (IFR) published in October 2010 (find… Read More

Customary and Reasonable Assignments

Editor’s Note: Andy Anderson looks around and ahead toward fixing a now broken appraisal profession. Customary and Reasonable Assignments By Andy Anderson The appraisal profession was not broken. Just like other professions, there were (and are) some bad actors, but appraising was not broken and should have been allowed to do its job correctly. That is not… Read More