" . . .the current interpretations found in the “New RESPA Rule FAQs” contributes to a significant problem facing real estate appraisal companies and independent real estate appraisers today – forced fee reductions and widespread “cramdowns” in fees to appraisers, by as much as 50 percent, according to our members in a recent survey."

That's part of what the most recent letter from the Appraisal Institute, American Society of Appraisers, the ASFMRA, and NAIFA had to say! . . .

"Oh behalf of the more than 35,000 members of our professional appraisal organizations, we urge HUD to clarify how fees charged for mortgage-related appraisals and for appraisal processing services are to be reported under the Real Estate Settlement Procedures Act (RESPA). Based on our review of the “New RESPA Rule FAQs” and other relevant documents, we seek confirmation of our conclusion that fees charged by Appraisal Management Companies (AMCs) for ordering and processing mortgage-related appraisals are correctly reported as “Origination” or “Other Settlement Services” fees in Blocks 1 or 3 of the Good Faith estimate (GFE); and on the “origination charge” line 801 of the HUD-1"

"We believe a clarification by HUD is necessary to avoid consumers paying unnecessarily for services reported on the Appraisal line of the HUD-1 that are actually part of a lender’s cost of doing business. Many consumers today are under a false impression that appraisal costs have increased in recent months, when in fact, many thousands of appraisers are being denied customary and reasonable fees in their local market.1 The reason for the reported increase is simple – many lenders have added AMC processing charges – traditionally regarded as a cost of originating a loan – to the Appraisal line of the HUD-1. We do not believe this practice is fair to consumers, as “lumping” these fees together may result in misleading information to the consumer"

"Further, we are concerned the current interpretations found in the “New RESPA Rule FAQs” contributes to a significant problem facing real estate appraisal companies and independent real estate appraisers today – "forced fee reductions and widespread “cramdowns” in fees to appraisers, by as much as 50 percent, according to our members in a recent survey."

For the complete document click here