Sunday, December 12, 2010

Help Shape Future of "Customary and Reasonable Fees"

On October 28th, the Board of Governors of the Federal Reserve System published an “Interim Final Rule” amending Regulation Z, Truth in Lending Act, or TILA. This interim rule implements Section 129E of the TILA which was enacted in July as Section 1472 of the Dodd-Frank Wall Street Reform and Consumer Protection Act.

As has reported, the “Customary and Reasonable Fees” provision bodes well for appraisers, with this part of the act scheduled to be implemented on April 1, 2011. This “Interim Final Rule” has language that concerns appraisers in regard to whether the provisions related to appraisal fees will be truly enacted and not be a bad April Fool’s joke.

A link to the Fed’s “Interim Final Rule” is found here: Part 226 Truth in Lending: Interim Final Rule

More importantly, a link where you can register your comments with the Fed is found below. The deadline for comments is December 27th so please take a few minutes to make your voice heard.

Federal Reserve Board: Electronic Comment Form

(Thank you, Michael Imes)

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