Sound Off!

Customary and Reasonable Fees? I Think NOT!

Dear H2 and REV:

Why are we not hearing about any law suits over the Customary and Reasonable Fee fiasco? It would seem that the very low fees that are currently being paid are both forcing appraisers out of the profession and helping to create a barrier for new trainees/apprentices from entering the profession. Combined with appraisers either retiring or dying off, the current available appraiser pool is dwindling and will continue to do so in the foreseeable future.

If there are going to be less and less residential appraisers in the coming years, why are those with a stake in having more appraisers being silent?

Won’t E & O Insurance companies feel the pain with fewer and fewer insureds?

Won’t software companies lose huge amounts of new sales and maintenance contracts with less and less appraisers buying their products?

Aren’t the continuing education and new licensee schools going to have to go out of business with no new pupils?

Wouldn’t the large appraisal organizations feel the pinch with not having robust membership?

The lack of anyone with deep pockets and a large stake in the game — maybe even a very large appraisal firm? — challenging the Customary and Reasonable Fees that did not change as they were supposed to on April 1st is mind-boggling. Those entities that depend on sheer numbers of working appraisers to stay in business should at least test the waters with a class action lawsuit. The specter of a $10,000 fine per occurrence and the potential liability for a fine
per appraisal should sharpen the mind and cause some lenders or AMC execs to rethink the flawed fee model.

Just a thought!

Fred Hankins