Monday, April 11, 2011

"Customary and Reasonable" fees

There are a number of emails circulating regarding the issue of "Customary and Reasonable" fees, and the topic is becoming more indistinct with the aggregation of opinions.

1. The "Part 1 Provision" that AMCs and CoreLogic are talking about is a misrepresentation. AMCs must be in compliance with all 6 parts of the presumption, or they are not in compliance at all. They cannot break out one or two sections and claim exemption while disregarding the rest of the law.

2. Your appraisal fee is reported on line 804 of the HUD-1. Or, it is the fee you charged before AMCs began skimming your fees. It's really that simple.

3. If you are still being pressured by an AMC, report them to the Fed here, and the FTC here.

4. In the meantime, stop agreeing to work for less than your normal fee!

5. Richard Hagar has an online class about this, "Appraiser Independence and Mandatory Reporting of USPAP Violations." Part 2, "Appraiser Independence," includes a discussion about the "Customary and Reasonable" provisions.

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