When it comes to fair fees, if you’re waiting for government help, you may be waiting a long time. The issue over customary and reasonable fees (CRF) for appraisers under Dodd-Frank is far from settled. For now, when it comes to earning fair fees, you may be your own best friend.

As most know by now, Dodd-Frank calls for appraisers to be paid customary and reasonable fees and allows for independent studies as evidence. The studies are to exclude AMC-ordered appraisals. The legislation also calls for stiff fines for lenders and their agents (AMCs) who refuse to comply. However, the Interim Final Rule, designed to provide guidance for implementation of Dodd-Frank, seems to have backed away from the intent of the legislation, when it comes to appraiser fees, leaving more questions than answers (see Decoding Customary and Reasonable Fees).