Customary and Reasonable?

They’ve done it again!  The Illinois Real Estate Appraisal Board has published another gem of an article in their August 2010 newsletter.  So good is the article, in fact, that we felt compelled to reprint it here so that appraisers nationwide can enjoy it.

With the passage of H.R. 4173, lawmakers slipped in a statement referring to appraisers being paid a customary and reasonable fee for assignments in a given market area.

Well…that’s just dandy. What does that mean?

Don’t look to Congress to define it.  They’ve already clapped their hands together like blackjack dealers at the end of a shift and moved on to something else.

Is it what an appraiser is paid by an AMC?   Is it what a bank pays?

In February of this year, a la mode released the Appraisal Fee Reference - Median Observed Appraisal Fees by County, State, & Region.

While comprehensive in scope and quick to push aside AMC fees, it is not the official document by which “customary and reasonable” are to be measured.

After all, fees are subject to change, right?

I certainly didn’t charge the same for a RUSH on Christmas Eve.

Appraisers typically charge different fees to different clients.  I did.

There was also the myriad report formats and valuation products that range from the sublime to the ridiculous.

Should URARs all be paid at the same rate in Cook as they might be in Boone or Sangamon counties?

What about Brown County?  There aren’t any appraisers in Brown County at all.  Would a Brown County fee just roll from the next most populous area?

The bill states the following about establishing customary & reasonable:

“Evidence for such fees may be established by objective third-party information, such as government agency fee schedules, academic studies, and independent private sector surveys.  Fee studies shall exclude assignments ordered by known appraisal management companies.”

So, before you leap for joy over a return to normal fees…everyone needs to take a step back and figure out…how to figure that out.