- The CFPB has proposed two versions of the new SDF, both of which continue to bundle appraisal fees with fees paid to appraisal management companies.
- The Dodd-Frank Act authorized separation of appraisal and appraisal management fees, and doing so would fully inform borrowers of actual costs paid.
- There is no consumer benefit with continuing to bundle two separate services and not fully disclosing such information to borrowers.
- Thus: the CFPB should revise these forms with a separate line for Appraisal Management (or management fees in total) as required by Dodd-Frank Act.
- Consumers deserve to know who is providing services relative to their loan and how much was paid.
- Itemization is needed, among other things: so that the consumer knows the level of service provided by the appraiser; to assure that the consumer is not misled to believe that a more thorough appraisal analysis was performed.
- Itemization is warranted because: consumers deserve to know who is providing services relative to their loan and how much was paid.
- Itemized prevents, among other things: manipulation of price versus service, which is consistent with the goal of disclosure and is clearly a consumer service.
American Society of Farm Managers and Rural Appraisers
Letter to Consumer Financial Protection Bureau
Opposing the bundling of appraisal fees
with appraisal management company fees:
CFPB’s proposed Settlement Disclosure Form
November 16, 2011