News & EventsThe Dodd-Frank Act
On July 21, 2010, the Dodd-Frank Wall Street Reform and Consumer Protection Act was signed into law. Section 1472 of the Dodd-Frank Act ["Truth in Lending Act" aka "TILA" Section 129E] establishes new requirements for appraiser independence and Appraisal Management Company ["AMC"] mandates. The amendments made to TILA can be found at: Dodd Frank Act
The release of the Federal Reserve Board’s interim final rule on October 28, 2010 (currently in public comment status), provides both clarification around appraisers and their ability to work free of influence or pressure from interested parties on transactions and the need for appraiser compensation to be ‘customary and reasonable’ in their market.
Specifically, the interim final rule contains new language in the areas of coercion, extensions of credit, conflicts of interest, mandatory reporting of appraiser misconduct, and customary and reasonable rate of compensation for fee appraisers.
While this interim final rule is currently in the public commentary stage and is subject to possible modification, the Risk Management staff and FAS is monitoring the activity around this and other relevant legislation, acts and ordinances to ensure that we are at the forefront of compliance requirements.
