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Citing the lack of time available to sort out and clarify various parts of the Dodd-Frank appraisal related regulations, the Title Appraisal Vendor Management Association (TAVMA) has sent a letter to Federal Reserve Chairman Ben Bernanke recommending a delay of the Oct. 20, 2010 effective date of Subtitle F, Appraisal Activities, Section 1471—Property Appraisal Requirements, of the bill.
TAVMA, along with several other mortgage trade associations, urges the Federal Reserve Board to clarify what constitutes "customary and reasonable" appraisal fees. FHA says it is a market driven negotiation between client and appraiser. Some appraisers have said it is a single-point value; others believe it is a range. Our letter (and others) point out the need for a clear definition.
Click here to view a copy of the letter.
For more information, visit www.tavma.org.