What Does More State Involvement Mean For Customary & Reasonable Fees?
Dodd-Frank requires lenders to pay appraisers a Customary & Reasonable (C&R) Fee. The most common thread in appraiser comments on C&R is that it doesn't matter because there is no enforcement. So the natural progression is that one must first determine C&R before one can enforce it. For most states, determining C&R has been a challenge, but we have identified some states that have completed C&R surveys and published their results. Naturally, appraisal fees vary greatly depending on the market and type of appraisal product.