I received this email from fellow appraiser peer, Dave Towne in WA and have his permission to pass it along:
Appraisers…………
For those of you who have concerns about the upcoming implementation of the revised HVCC because it enforces appraiser independence rather than allowing Mortgage Brokers to influence your work (i.e., direct placement of orders from MB’s), you may want to read this info from the National Association of Mortgage Brokers (NAMB) which appeared in their January magazine:
“Controversial Appraisal Agreement
In March, New York Attorney General Andrew Cuomo, the GSEs, and the Office of Federal Housing Enterprise Oversight (OFHEO)—now the Federal Housing Finance Agency (FHFA)—reached an agreement modifying appraisal standards in an attempt to address appraiser fraud. The agreement would adopt a Home Valuation Protection Code (HVCC), which would create requirements governing appraisal selection, solicitation, compensation, conflicts of interest and corporate independence.
It would also prohibit brokers from selecting appraisers
[DT Note: only for loans placed with Fannie/Freddie], and prohibit lenders from using “in-house” staff appraisers or appraisal companies they know or own. [DT Note: This part of the sentence is FALSE] The agreement has been met with significant opposition from NAMB, as well as much of the mortgage industry since its release.
However, on December 24, Cuomo, the GSEs, and the FHFA released a revised HVCC, which still falls short of what is necessary for addressing appraiser fraud. NAMB has opposed the agreement and HVCC because it will hurt small businesses, thereby increasing costs to consumers.
Furthermore, the agreement fails to recognize the Board’s final HOEPA rule, which already prohibits creditors or mortgage brokers from coercing, influencing, or otherwise encouraging an appraiser to provide a misstated appraisal. NAMB believes that the solution to the appraiser fraud problem is to hold responsible those committing fraudulent acts: appraisers.
NAMB is currently reviewing all available options to oppose the agreement and protect members’ interests.”
Folks……this is a huge bucket of BULL…… – what I call ‘bovine essence’. Of course they don’t like the Agreement. And of course, they want to make it appear that ‘you’ are the real problem. Nothing like a ‘friend’ stabbing you in the back.
It may affect their bottom line, and changes their status quo. Nothing in their ‘final HOEPA rule’ will prevent ‘them’ from insisting a certain appraised value be met in order to ‘do’ the loan. These people are salespeople. They want to make the sale first and foremost, so that they can earn a big commission.
This self-serving statement of theirs fails to mention that there are already bushels of laws and regulations affecting our work and performance……but virtually none that ‘regulate’ the mortgage sales industry. The revised HVCC is one step in leveling the playing field.
Again, the HVCC only applies to loans sold to Fannie/Freddie. So the MB’s will still be interacting with you for other loans they will place elsewhere. Which means………their present ‘sales tactics’ may continue.
Dave Towne”
http://realestateappraisertips.info/ is simply publishing the opinion of Dave Towne.
Statement From National Association Of Mortgage Brokers Shoots Appraisers
by http://realestateappraisertips.info/ on February 2, 2009
http://realestateappraisertips.info/category/hvcc-issues-&-comments/ - Statement From National Association Of Mortgage Brokers Shoots Appraisers
I received this email from fellow appraiser peer, Dave Towne in WA and have his permission to pass it along:
“Subject: Statement from NAMB shoots appraisers
Appraisers…………
For those of you who have concerns about the upcoming implementation of the revised HVCC because it enforces appraiser independence rather than allowing Mortgage Brokers to influence your work (i.e., direct placement of orders from MB’s), you may want to read this info from the National Association of Mortgage Brokers (NAMB) which appeared in their January magazine:
“Controversial Appraisal Agreement
In March, New York Attorney General Andrew Cuomo, the GSEs, and the Office of Federal Housing Enterprise Oversight (OFHEO)—now the Federal Housing Finance Agency (FHFA)—reached an agreement modifying appraisal standards in an attempt to address appraiser fraud. The agreement would adopt a Home Valuation Protection Code (HVCC), which would create requirements governing appraisal selection, solicitation, compensation, conflicts of interest and corporate independence.
It would also prohibit brokers from selecting appraisers
Furthermore, the agreement fails to recognize the Board’s final HOEPA rule, which already prohibits creditors or mortgage brokers from coercing, influencing, or otherwise encouraging an appraiser to provide a misstated appraisal. NAMB believes that the solution to the appraiser fraud problem is to hold responsible those committing fraudulent acts: appraisers.
NAMB is currently reviewing all available options to oppose the agreement and protect members’ interests.”
Folks……this is a huge bucket of BULL…… – what I call ‘bovine essence’. Of course they don’t like the Agreement. And of course, they want to make it appear that ‘you’ are the real problem. Nothing like a ‘friend’ stabbing you in the back.
It may affect their bottom line, and changes their status quo. Nothing in their ‘final HOEPA rule’ will prevent ‘them’ from insisting a certain appraised value be met in order to ‘do’ the loan. These people are salespeople. They want to make the sale first and foremost, so that they can earn a big commission.
This self-serving statement of theirs fails to mention that there are already bushels of laws and regulations affecting our work and performance……but virtually none that ‘regulate’ the mortgage sales industry. The revised HVCC is one step in leveling the playing field.
Again, the HVCC only applies to loans sold to Fannie/Freddie. So the MB’s will still be interacting with you for other loans they will place elsewhere. Which means………their present ‘sales tactics’ may continue.
Dave Towne”
http://realestateappraisertips.info/ is simply publishing the opinion of Dave Towne.
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Tagged as: HVCC Appraisal Code