Comment from Anonymous
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Summary: The commenter argues that the combined fee disclosure and the 0% tolerance for appraisal fees should be repealed. They claim these measures allow lenders and AMCs to suppress appraiser compensation and ignore property complexity, which hinders the training of new appraisers.
The combined fee disclosure has been abused to deceive consumers, violate the first presumption of compliance in TILA 129E, and actively suppress appraiser compensation for the profession. This has led to many appraisers refusing to work for many AMCs and lenders as they aren’t looking at property complexity, designations, or expertise.
Both the 0% tolerance fee for appraisal fees being reported in loan disclosures and the combining of the AMC and Appraisal fee as a single line item need to be repealed. Those two measures have allowed AMCs and Lenders to control appraisal fees and created fee suppressions to a point that severely limits being able to train new appraisers.