http://www.realestateappraisertips.info/ - Real Estate Appraiser Tips: Appraisers: Help Stop Bad Policy and Support Appraisal Industry
Appraisers……….
In case you have not heard, the US Dept. of the Treasury is about to implement a new policy which will not allow you to participate in the valuation of ‘short sale’ properties.
You can help stop this absurd policy by sending a letter to Timothy Geithner – see below. Four appraisal organizations have already sent their response. But you need to participate in this also, and stop the madness.
If you won’t or don’t help, you cannot justify complaining about this if it is implemented.
I’m not a big fan of pre-written ‘form letter responses.’ But for context and to start your juices flowing, my letter is below. Please slice and dice it, add your own personal comments to your own letter, and then mail yours by this weekend.
Final point: send an ‘advisory’ e-mail to your US Congressional representatives about this bad policy and ask that they contact the Secretary of the Treasury to ask that the pending policy be abandoned, and to allow licensed appraisers to help value ‘short sale’ properties.
My letter:
The Honorable Timothy Geithner
Secretary of the Treasury
1500 Pennsylvania Avenue, NW, Room 3330
Washington, DC 20220
Re: Proposed ‘short sale’ policy in the HAFA
Mr. Geithner:
I am a self-employed, independent Certified Residential real estate appraiser with close to a decade of appraisal experience.
The proposed ‘new’ procedure within the Home Affordable Foreclosure Alternatives program to mandate real estate salespeople as the only people allowed to establish the sales price on a short sale property is dangerous for this country and consumers as a whole. I ask that you delay implementation of this provision until independent appraisers are added, or to abandon it all together.
This proposed procedure is contrary to the HVCC and regulatory agencies policies that demand valuation procedure independence for mortgaged properties. In a majority of cases, short sales will become mortgaged properties. To have any party with a financial interest in the property be the ‘only’ one allowed to set the price is absurd. A real estate sales person has a financial interest if they are involved with the pricing of the property, and ultimately participate in the sale of that property.
Per USPAP, independent licensed appraisers sign certifications that they have no financial or personal interest in appraised properties. These are the people who should determine Market Value of a property via a completed appraisal report. Once that is done, the lender can determine an appropriate ‘price’ for the property, perhaps by also consulting a knowledgeable real estate agent familiar with the property location.
Please carefully consider these suggestions. The proposed HAFA procedure is bad policy.
Name
License Title
Address, City, State, ZIP
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Do you have Geithner’s e-mail address ?
I’m stunned that so much of this nonsense is slipped into laws without proper exposure for commentary.
Hi Mike, I’m sorry, I don’t have his email address! Thank you for taking the time to read and respond! Bill