A "Customary and Reasonable" appraisal fee is the fee the borrower paid for the appraisal service.
Not the fee from the appraiser's fee schedule, but the "appraisal fee" the borrower/buyer paid.
This fee is always specifically identified on the HUD-1, a Federally required form, as "the appraisal fee." [Ed. - Line 804]
So the fees are already known and the market has been paying them, and the market (and appraisers) have third-party proof.
Now do the AMCs understand what kind of hole they are in?
Richard Hagar SRA