The National Community Reinvestment Coalition announced Nov. 6 that it has joined the Appraisal Institute and the American Society of Farm Managers and Rural Appraisers in an effort to get the Consumer Financial Protection Bureau to separate the appraisal fee from the appraisal management company fee on mortgage disclosure forms.

The joint comment letter urged the CFPB to require “disclosure of AMC fees separate and apart from the fees paid to a professional appraiser for appraisal services when AMCs are used by banks and financial institutions.”

Under the proposed rule, the disclosure of AMC fees is only optional — despite clear authorization under the Dodd-Frank Act to require such disclosure. This situation can be perceived as a conflict of interest since lenders provide instructions to settlement agents relating to the fees to disclose. The groups note that “this is likely to result in inconsistency in disclosure of AMC fees, with some lenders listing only an appraisal fee and others listing both an appraisal and an AMC fee without any explanation. We believe this will confuse consumers, rather than empower them to make rational and responsible decisions.”

Read the comment letter.