On March 30 the American Society of Appraisers (ASA), together with the National Association of Independent Fee Appraisers (NAIFA), sent a letter to the Consumer Financial Protection Bureau (CFPB) regarding CFPB’s ongoing “Know Before You Owe” mortgage disclosure form revision initiative. In the letter ASA and NAIFA reemphasized their views, expressed in a letter sent last December 7, that any proposed revision to the Good Faith Estimate (GFE) and settlement statement forms should require separate disclosure of the fee paid to the appraiser from the appraisal management company (AMC) fee when the appraisal is ordered through an AMC, as most are. The letter praised three prototype forms (the “Honeylocust”, “Butternut”, and “Hemlock” forms) that were field tested in Philadelphia and which separately disclosed the two fees. Forms tested in other parts of the country failed to do so. The ASA and NAIFA letter stated that failure to separate the fees in the final CFPB-recommended forms would deny consumers information essential to fully understanding the costs of a mortgage application. The CFPB is expected to release proposed final rules regarding these revisions sometime this summer.
Read the full letter here. ASA NAIFA_Follow_Up_Letter_to_CFPB_Re_Forms