Appraisers – Your Comments are Important

Comment ICON


FROM:   ICAP – Illinois Coalition of Appraisal Professionals

This must be done by Tuesday July 7th.  

The Consumer Financial Protection Bureau (CFPB) is requesting comments on the proposed amendment to the “Know Before You Owe” mortgage disclosure rule, which proposes to move the rule’s effective date to October 3, 2015.


As noted in our last ICAP Blog, your ICAP Board of Directors feel it is very important that the appraisal fee be disclosed separately from any add on fees such as an AMC fee.  


Recently 23 state appraiser coalitions, including ICAP, worked together and submitted a letter to the CFPB about making it a requirement to separate the fees of the AMC and the appraiser at the closing table on the disclosures.

Letter That Was Submitted To CFPB By State Coalitions   

Now it is our turn to do our part and I am asking that you take a minute to make a personal comment to the CFPB. This is a part of appraisers having a seat at the table in our industry. 


Right now there are 79 comments and almost every one of them are from Banks and AMC’s. 


Appraisers also need to express our opinion on this issue. 


Keep it simple it’s about transparency for the consumer, but there is a sample comment below feel free to use it or create your own. It’s just important that you make a comment. 


  • Click on the comment icon above or below to submit your comments.
  • Read the Proposed Rule by CFPB
  • To comment click on “Comment Now!” at the upper right corner of the webpage
  • Add your comment.  See Sample Comment Below.

Comment ICON

Let’s flood them with comments from appraisers. 


Once you have done this please forward this to another appraiser.

This is a sample comment……Feel free to copy and paste, edit or submit something totally different but please make a comment. 

 Sample Comment:

 “Appraisal” fees to consumers continue to rise while the actual payments to appraisers have fallen. As with any business, a focus of third party appraisal management companies is to increase their profits. Under the current disclosures, there is no benefit or accountability to the consumer since the AMC fees are not listed independently.

The result of this lumping together of the fee often misleads the consumer to think that the appraiser fee is high. Currently, (with no separation requirement), a consumer might see an “appraisal” fee for $600 or more, with no awareness that the appraiser they met at their home and has completed their report is only being paid as little as $300 or less.

We ask that the Bureau recognize this major concern and take this proposed delay, in an attempt to “get it right”, as an opportunity to address this issue. I implore that you implement this simple solution of requiring the actual appraisal fee to be disclosed on its own, not an inflated fee that includes other administrative bank or AMC “add-ons”.

About ICAP

ICAP works to promote the appraisal profession and its image to the general public and to users of appraisal services. ICAP initiates discussion and analysis of issues affecting professional appraisers and monitors political action with the intent to influence legislation, regulation and public opinion toward the appraisal profession.

About icapweb

ICAP was established in 1994 to be a unified voice for Real Estate Appraisers in the State of Illinois

Posted on July 3, 2015, in The Good Stuff. Bookmark the permalink. Leave a comment.

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