An AMC acting for a creditor offers $200 for a covered residential appraisal when comparable work locally often pays $400–$450. Under Regulation Z’s customary-and-reasonable fee rule, which party bears the compensation obligation?
Correct Answer
A) The creditor and its AMC agent must satisfy the fee rule
Regulation Z §1026.42(f) requires the creditor and its agents to compensate a fee appraiser at a customary and reasonable rate for comparable work in the property’s geographic market. The appraiser may negotiate or decline, but the rule does not itself command every appraiser to reject a lower offer.
Why This Is the Correct Answer
The federal customary-and-reasonable compensation rule places the payment duty on the creditor and its agent. A fee appraiser may discuss terms or decline, but the $200 offer alone does not create a USPAP duty for that appraiser to refuse.
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