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Customary and Reasonable Fees
December 1st, 2015 4:39 PM
When Dodd Frank was passed a few years ago there was much discussion as to what it actually meant to
lenders¸ appraisers, and AMCs.
AMCs were quick and forceful in their definition. It was the fee they could coerce an appraiser into
accepting. That was their definition. This has been a big impact on the well-being of an honorable
In June the Federal Final Rules were released, and they took effect in September of this year. These Final
Rules clarified many questions regarding lending, appraising, and AMC involvement. First, the Feds
have made it very clear that lenders ARE NOT required to utilize the services of any AMC. Indeed, if they
do opt to do so the lender is responsible for the accuracy and reliability of ALL appraisals done by their
AMCs. It is clear that lenders have liability for good, honest, and competent appraisals regardless of any
involvement of an AMC. AMCs do NOT protect lenders or borrowers.
Second, the Final Rule clearly mandates that customary and reasonable fee definition is left to each
state to determine.
On November 17th at DPOR Headquarters on Mayland Road in Richmond is the quarterly Real Estate
Appraiser Board meeting. It begins at 10 am.
It is expected that at this meeting the Board will consider customary and reasonable fees. This is
important to us all. It appears that DPOR has come to the realization that C & R fees is an important
issue that must be settled.
VaCAP has been at the center of this issue, not only in Virginia, but also on a national basis through the
Network of state appraiser coalitions that represent about 25 states now.
VaCAP will speak out regarding C & R. The premise is that the current VA fee in Virginia is fair as
the minimum C & R fee to be paid to an appraiser. The utilization and adoption of the VA fee
meets all Dodd Frank requirements and definitions, much better that the self-serving, selfish fee
maintained and promoted by AMCs.
You can and should attend this most important meeting on November 17 to speak or support.
You can and should join VaCAP NOW especially if you believe VaCAP represents your interests.
Join us on November 17th in Richmond.
Join VaCap TODAY!!!!!
OR you can donate $$$ TODAY!!!!! OR you can volunteer your time. Both are essential to the success of
the appraisal profession.

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Posted by Virginia Coalition of Appraiser Professionals on December 1st, 2015 4:39 PMPost a Comment

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Great information - keep it coming ...

Posted by Beverly T Davis on January 3rd, 2016 8:47 AM