• Real Estate Appraiser Board

    About the Customary & Reasonable Fee Guidance Document

    The Real Estate Appraiser Board adopted a Guidance Document on February 23, 2016, about customary and reasonable compensation for fee appraisers. The Board’s law and regulation require Appraisal Management Companies (AMCs) to pay customary and reasonable compensation in compliance with the Truth in Lending Act (TILA) and its regulations. 

    The Guidance Document outlines the two presumptions of compliance with customary and reasonable compensation as found in TILA and its regulation. An AMC is presumed to pay a fee appraiser customary and reasonable compensation if the AMC meets either of the two presumptions. 

    The second presumption says, in part, if an AMC relies on rates based on fee schedules—prepared by independent, third parties such as government agencies—it is presumed to comply with customary and reasonable compensation. 

    The Board, through this Guidance Document, adopts the U.S. Department of Veterans Affairs’ Roanoke Regional Loan Center Appraisal and Inspection Fee Schedule (VA fee schedule) as a government agency fee schedule which AMCs may use as a presumption of compliance to provide customary and reasonable compensation to fee appraisers. If an AMC uses the VA fee schedule as the basis for paying fee appraisers, the Board considers the AMC as meeting the presumption of compliance for customary and reasonable compensation. However, an AMC may also meet the presumption of compliance if it uses another presumption set out in TILA and its regulation.