The Dodd–Frank Wall Street Reform and Consumer Protection Act was signed into federal law on July 21, 2010. A response to the Great Recession, it made changes in the American financial regulatory environment that affect all federal financial regulatory agencies and almost every part of the nation’s financial services industry.
SettlementOne, its products and services are fully compliant with all aspects of Dodd-Frank, including guidelines designed to protect consumers and appraisers.
Rule 1 states that a creditor and its agent is presumed to have paid a customary and reasonable fee if the fee is reasonably related to recent rates paid for appraisal services in the relevant geographic market and, in setting the fee, the creditor or its agent has:
- Taken into account specific factors, which include, for example, the type of property and the scope of work; and
- Not engaged in any anticompetitive actions, in violation of state of federal law, that affect the appraisal fee, such as price-fixing or restricting others from entering the market
SettlementOne Compliance to Presumptions of Compliance 1:
- SettlementOne pays fees based off of recent rates in geographic markets as well as complexity of the actual assignment.
- Appraisers have the ability to ask for a price increase on any order that warrants such based off the relevant details of the assignment.
- In addition SettlementOne does not engage in any price fixing or anticompetitive actions.
Data Sources considered for Analysis
- OREP/Working RE Customary and Reasonable Fee Survey
- Alamode Fee Survey
- Historical Data from SettlementOne fee panels
- Competitive AMC fees