AMCs

Decoding Customary and Reasonable Fees

Congress, recognizing that quality reports are dependent on paying appraisers “fairly,” wrote a customary and reasonable fee provision into Dodd-Frank, and going further, stipulated that any independent studies to determine such fees should specifically not take into consideration fees paid by appraisal management companies (AMCs), suggesting their acknowledgment that AMC fees are artificially low. The Interim… Read More

State Watch: Regulating AMCs

State Watch: Regulating AMCs By Mike Antoniak When the Home Valuation Code of Conduct (HVCC) became law May 1, 2009 it had unintended but far-reaching consequences for professional appraisers. “The HVCC, and its perceived need for financial institutions to separate the origination and the appraisal ordering function to preserve appraiser independence, resulted in an explosion...… Read More

Fed Board Update: Customary and Reasonable Fees

As implementation of Dodd-Frank takes effect, the Federal Reserve Board shed light regarding the implementation of the customary and reasonable fee provision of the legislation. The Federal Reserve Board, tasked with implementing the landmark Dodd-Frank Financial Reform legislation passed last year, laid out its guidance in the “Interim Final Rule” (IFR) published in October 2010 (find… Read More