12th April 2011

Customary & Reasonable : enforcement 3 to 4 years away?

It sounds like we are in another waiting game regarding customary & reasonable fees as noted in Dodd-Frank.

Key Notes:
* The minimal timeline set forth in the Dodd-Frank Act indicates that those rules may be promulgated within 18 months of July 21, 2011.

* After the rules are in final form, States have 36 months to implement the minimum requirements established by the rules for registration and supervision of AMCs. (The ASC may grant States up to a 12-month extension, subject to specific limited conditions set forth in the Dodd-Frank Act.)

Please read the entire article below:

…continue reading the rest of this post: Customary & Reasonable : enforcement 3 to 4 years away?

posted in Appraiser News | 0 Comments

31st January 2011

Entire Letter from ASA, AI, Etc. Interim Final Rule December 27, 2010

December 27, 2010

Jennifer J. Johnson
Secretary

Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, NW
Washington, DC 20551

Re: Docket No. R-1394 and RIN No. AD-7100-56

Thank you for the opportunity to comment on the Interim Final Rule (IFR) amending Regulation Z (Truth in Lending) and the matters of appraiser independence and customary and reasonable fees to appraisers. In reviewing the rule it is clear that the Federal Reserve spent considerable time in preparation of the IFR. The agency is to be commended for its hard work, especially for meeting a very strict and difficult deadline and given other agency resource constraints.

…continue reading the rest of this post: Entire Letter from ASA, AI, Etc. Interim Final Rule December 27, 2010

posted in Dodd-Frank C&R Topics | 2 Comments









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