Interim Final Rule

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