25th January 2012

AGA uses law firm to request documents related to Customary and Reasonable Fees

posted in Dodd-Frank C&R Topics |

WASHINGTON, Jan. 23, 2012 – [List of AMCs] On behalf of the American Guild of Appraisers, today the law firm Garvey Schubert Barer filed a request with the Federal Reserve Board under the Freedom of Information Act seeking a wide variety of documents related to the regulations on customary and reasonable compensation of fee appraisers that were issued by the Board in October 2011.

In announcing this action, Guild President Peter Vidi said, “It is clear that appraisal management companies have interpreted rules issued by the Fed as permitting practices that result in real estate appraisers being compensated at levels that are far below ‘reasonable and customary fees’ as required in the Dodd Frank Law. We want to learn whether the Fed intended this result and if so why.”


Vidi continued, “we hope that these documents will shed light on why the Board chose to create two conflicting ‘safe harbors’ for compliance with these regulations, one of which permits Appraisal Management Companies to rely upon the considerably lower rates that they themselves pay appraisers in determining what compensation is considered ‘customary and reasonable’ in direct violation of the Dodd Frank law. To this end, we have asked for all internal and external correspondence related to their development of these regulations, as well as documents such as meeting records, studies, reports and other information considered by the Board in the development of the regulations.”

The formal request under the Freedom of Information Act seeks all documents that chronicle any consideration given by the Board, after having issued the regulations, to the public comments submitted to them, many of which pointed out the problems created by the safe harbor provisions, as well as to any follow-up actions that might be taken to correct these problems. “We are hopeful that these documents will allow us to better understand the seriousness with which these issues have been considered and the potential for future corrective action,” Vidi noted.

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2012 Appraisal Management Company Directory

2012 Appraisal Management Company Directory

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