The Appraisal Sub-Committee (ASC) has updated their website with the following information:

Where To Direct Questions and Comments Regarding Customary and Reasonable Fees

Friday April 15, 2011

The appropriate agency to receive your concern about a creditor’s compliance with the Truth in Lending Act (TILA), including the creditor or the creditor’s agent paying an appraiser a customary and responsible fee, is the agency that enforces TILA for the creditor.

If the agent or appraisal management company (AMC) is affiliated with a federally-regulated creditor, the appropriate agency to receive complaints against the AMC is the affiliated creditor’s federal regulator.

If the agent (or AMC) is not affiliated with a federally-regulated creditor, the appropriate agency to receive the complaint is the Federal Trade Commission.

There are two websites that you can use to find the federal regulator for a creditor:

• Federal Reserve System – National Information Center website: http://www.ffiec.gov/nicpubweb/nicweb/nichome.aspx  ; and
• FDIC website at the “Bank Find” webpage: http://www2.fdic.gov/idasp/main_bankfind.asp  .

Questions regarding the appropriate interpretation of the Truth in Lending Act, including those on customary and reasonable fees, should be directed to the Federal Reserve Board at http://www.federalreserve.gov/feedback.cfm .

Source: ASC