http://financialservices.house.gov/Key_Issues/Financial_Regulatory_Reform/Final_ conference_titles/T14_FINAL.pdf ??...(3) EXCEPTION FOR COMPLEX ASSIGNMENTS.?In the case of an appraisal involving a complex assignment, the customary and reasonable fee may reflect the increased time, difficulty, and scope of the work required for such an appraisal and include an amount over and above the customary and reasonable fee for non-complex assignments. RE: The above link is where the latest reform may be read in PDF. I inserted an excerpt as a paragraph above. It talks about "complex assignments" and related fees. A portion of the reform has interim clauses, as well. Every assignment in America involving every 'inch of land' may be complex in this new complexity economy. The "exception" can be for every inch of real estate located within the U.S. Boundary. The very asset and/or incentive, real estate, ultimately exploited, is observed to have evolved into a complexity economy. The cause or effect is a negative external looking to be a probability on a scale of 5.0 (an assumption of certainty), adversely affecting America's "Whole Property." Complexity is abstract due to the principle of change and, of course a host of additional characterizations and/or causes. I do not like the word "customary" in a changing economy like this one. The context in which it is used, tells me there is a central idea to control a fee that truly desires to stand alone with each case and or assignment in a complexity economy. Customary should be withdrawn -- replaced with Independent -- 'an Independent, competent, ethical and economically (reasonable) fee -- shall reflect time, difficulty, the scope of work for efficient interpretation, and quality.' I think Independent Real Estate Appraisers should look for every loop hole to close the De Minimis; so long as the HVCC is 'theoretically' being extended and while Appraiser Independence is on the table. The elimination of the De Minimis economically, ridding ownership of (so-called) third Parties - needing a defined firewall, and sincerely implementing a true IVPI or 'the similar' ALL should be targeted! While being smart about negotiating fees during the research and study period and fighting for those three loop holes -- Being smart about fees; it is a good strategy for (following up and/or) advancing Appraiser Independence. I agree with studying the appraisal process in depth and its complements per extension of the HVCC in the proposed legislation. Additional: more consumer language is important for an Independent Appraisal process to progress - for the Independent Appraiser to evolve. Disclosure: as of the effective date of this post, the amendments and/or legislation linked to the PDF has yet to come to a full vote; as issues are being discussed (as the link is only a portion of financial reform) Changes may be in lieu, before a full vote. However, the interim legislation related to the Appraisal subject is 'subjected' to changes of certain "things" that does not benefit Appraiser Independence in lieu of an attempt at economic efficiency.
