FHA has released their latest FAQ page on AMCs/Reasonalble and Customary Fees and Turnaround Times.
In part here are some of their answers:
- FHA does not set fees or determine whether a fee is reasonable and customary.
- Even if the lender employs an AMC to manage the appraisal process, FHA holds the lender responsible, equally with the appraiser, for the quality and accuracy of the appraisal.
- Consistent with RESPA guidelines, lenders are not required to break out or itemize appraisal related fees on the HUD-1.
An appraiser who feels that the fee offered or paid for the appraisal is not reasonable and customary should file notice with the lender. Appraisers should not accept an assignment if they believe that the terms of the appraisal service being requested, including fees, are not reasonable.
- FHA has no authority to regulate AMC’s. If an AMC requests an appraiser to violate USPAP or act in an unethical manner, the appraiser should refuse the assignment and notify the lender.
- FHA does not set acceptable turnaround times for completion of appraisal assignments. Appraisers should always be familiar with the terms of an assignment and not accept assignments which have unrealistic terms.
THANKS HUD!? No guidance on fees, put the blame on the lender or appraiser, and don't require that fees be disclosed on the HUD-1!!
Basically saying . . . Take it or leave it! It's up to you.
What do you think appraisers?
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