HVCC - Countdown

Today is April 29, 2009 and we're just two days away from the effective date of the Home Valuation Code of Conduct (HVCC). There are quite few different points of view being expressed by folks about to be affected by the agreement between the Attorney General of New York and the Federal Housing Finance Agency (FHFA), Fannie Mae and Freddie Mac.

The National Association of Mortgage Brokers (NAMB) is not taking the assault lightly and has ramped up their efforts. THIS ACTION ALERT went out to their members recently

Stop the HVCC! We Still Need Your Help! CRITICAL - Take Action Now!
April 24, 2009

Dear NAMB Member:

In addition to what NAMB is doing to save your business, ask yourself, "What can I do to help save it?"

You can pick up the phone and act! It is undeniable that the implementation of the Home Valuation Code of Conduct ("HVCC") will have severe consequences. The deadline is just days away. Regrettably, many of you have not yet contacted your legislators, and time is running out!

THANK YOU to everyone who has contacted their Senator and/or Representatives. You are being heard! NAMB has spoken with several legislators as a result of your calls regarding the HVCC, but we still need your help! Key Republican and Democrat Congressmen have shown their support for NAMB's cause, but we need to keep the momentum going. We can not stop now!

Please contact your Senators and Representatives TODAY, and urge them to stop or delay the implementation of the final rule promulgated by the FHFA, which implements the controversial HVCC. Congressmen Gary Miller (R-CA-42) and Travis Childers (D-MS-1) are taking the lead in this fight. Please ask your legislator to contact their offices today. Every call counts! We are asking you to keep calling until notified otherwise.

FULL TEXT

The National Association of Realtors (NAR) is also seeking a one year delay in the implementation of the agreement. This was sent to their Board of Directors this week, in advance of the May meeting of the Board.

NAR: Delay Cuomo-GSE Appraisal Agreement

The Home Valuation Code of Conduct that Fannie Mae and Freddie Mac agreed to with New York Attorney General Andrew Cuomo should be delayed until May 1, 2010, NAR President Charles McMillan says in letters to the heads of the two secondary mortgage market companies. More guidance is needed, including on enforcement responsibility, and appraisers and others impacted by the changes need time to prepare.

The agreement, approved in December 2008 to reduce the potential for inaccurate appraisals, is expected to have an impact beyond New York state because of the nationwide influence of Fannie and Freddie. For more info contact Jerome Nagy, 202/383-1233.

The Appraisal Institute (AI) does not appear to be fighting the implementation. Instead, their efforts are directed towards preparing their members to compete within the new paradigm, dispelling the myths swirling around the agreement, and educating their membership. Today's Appraisal News Online says:

HVCC Effective Friday; FAQs, Telebriefing, Myths Document among Resources Available

Despite legal maneuvers and rumors of intervention and delay, the Home Valuation Code of Conduct is scheduled for implementation this Friday, May 1, 2009. According to the Code and Fannie Mae and Freddie Mac, mortgage loans originated by lenders from there on out and after must comply with the Code in order to be eligible for sale to the GSEs. Leading up to the implementation date, the Appraisal Institute has drawn appraisers' attention to a variety of resources, including recent FAQs from Fannie and Freddie; a "Myths and Realities" document the organization drafted; and promotion of its May 6 telebriefing on the HVCC with the American Bankers Association.

FULL TEXT

The AI also provides a link to their Home Valuation Code of Conduct - Myths and Realities document HERE.

Appraiser Active has a favorite:

Myth: Use of third party vendors ensures the use of competent appraisers.

Reality: Lenders traditionally have been responsible for ensuring the competency of the appraisers and reliability of the appraisals they use for credit decisions. However, the competency of an appraiser is not measured by scoring compliance with seller servicer guidelines. Processing appraisal orders is a separate function that does not specifically include a review of competency. The function of competency review is best performed by individuals with significant education in appraisal standards and theory.

Further, institutions should consider any potential reductions in quality that might result from outsourcing the appraisal function. To this point, federal bank regulatory agencies recently reminded institutions to consider an appraiser’s competency for any given appraisal assignment.

There's three options for you. Please take one, or ALL, and do something!

They meant for the acronym HVCC to be pronounced "havoc" right?

About Gregoire & Gregoire Inc.

Gregoire & Gregoire, Inc. was incorporated in 1986 by Donald K. Gregoire, IFA and Francois K. Gregoire IFA RAA. The Company provides valuation, expert witness, tax appeal and consulting services for a wide variety of local and national clients. Clients include Banks, Mortgage Companies, Mortgage Insurers, Property Insurers, Realtors, Attorneys, Private Individuals and Government Agencies.

Francois K. Gregoire, IFA, RAA is a second generation Realtor and Appraiser. He has been involved in Real Estate Appraisal since 1977, is a member of the National Association of REALTORS Appraisal Section and a Designated (IFA) Member of the National Association of Independent Fee Appraisers. In addition to providing Expert Witness services for private and government clients, Frank is often quoted as a source for nationally syndicated real estate columnists and appears as a speaker on appraisal and mortgage related topics. Articles by Francois Gregoire have been published in the REALTOR® Magazine and the Journal of Property Economics. Francois K. Gregoire is a FHA Roster Appraiser and has over twenty years of experience in the development of appraisals for FHA Mortgage Insurance. He completed the first Master Appraisal for a proposed multi-story HUD Approved Condominium in Florida in 1990

In February, 2000 Governor Jeb Bush appointed Francois K. Gregoire to the Florida Real Estate Appraisal Board, the regulatory agency for Florida Real Estate Appraisers. The Governor appointed him to a second term in March, 2004. Gregoire served as Chairman of the Florida Real Estate Appraisal Board in 2002, 2004, 2006 and 2007 and Vice Chairman in 2001, 2003 and 2005.

Gregoire & Gregoire, Inc. is ready and able to help you with your appraisal and valuation needs for Pinellas County, Florida residential properties.

Gregoire & Gregoire, Inc.

Realtor - Appraiser

Office 727-344-3393

Fax 727-344-3395

EMAIL

HVCC Update

Appraiser Active has provided quite a bit of information about the impending May 1, 2009 implementation of the Home Valuation Code of Conduct (HVCC). Most recent was the post describing the NAR effort to urge a one year delay of its effective date.

As of today, there has been no word from Fannie, Freddie or Attorney General Cuomo in response to the NAR letters.

However, we hear there are at least at TWO members of Congress are passing around a letter on the Hill that will also ask for a delay. It sound like NOW would be a good time to contact YOUR member of Congress to ask them to support the delay.

Use this LINK to locate your US Representative and Senators. Use your Zip+4. The contact information for each is provided along with a link to their webpage. At this stage of the game, it's best to a telephone call, fax or email to make your points.

Use whatever you like, the points made the NAR Letters or these suggestions:

• One of the pillars necessary for implementation of the HVCC is the Independent Valuation Protection Institute. Without the IVPI there is no enforcement mechanism, hotline, or means of verifying compliance. Delaying implementation would allow creation of the IVPI or establishing an alternative framework


• Many state legislatures are in the process of enacting laws to regulate Appraisal Management Companies. In other states, the regulatory agencies are in the process of promulgating rules and procedures to deal with Appraisal Management Companies. Delaying implementation would allow these states to finalize their actions


• To this day, the fact that the HVCC resulted from improper influence on appraiser independence by a Federally regulated lender and a rogue Appraisal Management Company cannot be reconciled with the apparent endorsement of unregulated Appraisal Management Companies as the “protector” of appraiser independence by the HVCC. Delay would allow a reconciliation of this glaring conflict. (See Story on New York AG Complaint and link to suit HERE)


• Fannie Mae has adopted policies that protect the brokerage fees from downward negotiation in certain transactions (short sales). Delay of implementation would permit efforts to protect appraiser’s fees from downward negotiation by Appraisal Management Companies. At the very least, it would allow time to arrange for full and transparent disclosure of valuation related fees in closing documents (AMC fee, Appraisal Fee, etc)

They meant for the acronym HVCC to be pronounced "havoc" right?

New Appraisal Rules Lack Enforcement

The Center for Public Integrity Reports:

Nine days before new rules radically changing the appraisal industry are set to take effect, appraisers, lenders and real estate agents are asking the same question — who will enforce them?

The rules, intended to prevent lenders from pressuring appraisers to falsely inflate housing values to justify higher mortgages, would ban loan originators from communicating directly with appraisers. The new rules would thus carve out a bigger role for appraisal management firms, which serve as middlemen between lenders and appraisers.

The post mentions the letters sent by NAR President Charles McMillan to the heads of Fannie and Freddie (posted previously), and goes on to say:

Perhaps most significant, the letter notes the lack of a clear enforcement policy. “The HVCC does not clearly delineate which agency or organization will be responsible for enforcement of all or part of the agreement,” wrote Charles McMillan, president of the National Association of Realtors. “There are multiple stakeholders affected by the agreement and none have clear responsibility to see that it is enforced. There is no accountability if there is no organization for enforcement.”

As part of the original agreement, Fannie Mae and Freddie Mac agreed to pay $24 million to set up an “Independent Valuation Protection Institute” to field appraiser complaints about pressure to inflate values and police the rules. But the institute is not yet functioning, and its fate is unclear.

.......and then, the clincher

A Freddie Mac spokesman declined to comment on how his organization would enforce the rules. A Fannie Mae representative did not immediately return calls for comment. Andrew Cuomo’s office has failed to respond to repeated requests by the Center for comment on the HVCC.

Read the Article

They meant for the acronym HVCC to be pronounced "havoc" right?

NAR Seeks One Year Delay in HVCC

In letters to Michael J. Williams, President and Chief Executive Officer of Fannie Mae, and John A. Koskinen, Interim Chief Executive Officer of Freddie Mac, National Association of Realtors President, Charles McMillan urges a one year delay in the implementation of the Home Valuation Code of Conduct (HVCC).

Freddie Letter

Fannie Letter

McMillan notes that "There are many benefits for consumers and real estate practitioners to delaying the effective date of the HVCC until May 1, 2010. Stakeholders across the country will be granted sufficient time to prepare for changes to the appraisal process brought forth by the HVCC. He asks that the implementation be delayed to allow for several outstanding issues to be addressed.

These include:

• Lack of Guidance
• State Regulating AMCs
• HVCC does not Apply to FHA
• HVCC May Increase the Cost of Real Estate Transaction
• Lenders are not Prepared for HVCC
• No Clear Enforcement Agency
• IVPI is not Yet Functioning

With respect to the Independent Value Protection Institute, President McMillan states: "The Independent Valuation Protection Institute (IVPI) was announced as part of the HVCC to receive complaints from appraisers and users of appraisal services on the improper influence or attempted improper influence of appraisers. In the original agreement between the GSEs and the New York State Attorney General, Andrew Cuomo, $5 million was to be paid by Fannie Mae and Freddie Mac to fund the first 5 years of the Institute’s existence. The final agreement includes the IVPI but makes no mention of funding. It’s not clear whether the GSEs will provide the upfront funding and long-term funding was never addressed in the HVCC.

In our comments provided on April 30, 2008, we recommended the Independent Valuation Protection Institute be affiliated with an already existing appraisal organization. This will help to ensure that the code is implemented to add value to the appraisal process rather than becoming a duplicative layer of bureaucracy. Under the final agreement of the HVCC, the lender, rather than the IVPI, is responsible for establishing a telephone hotline to receive complaints from appraisers, individuals, or any entity concerned with the improper influencing of appraisers or the appraisal process. Lenders report any improper activity to the IVPI and the state regulating agency. If properly implemented, the code will complement, rather than duplicate or contradict, already existing appraisal codes such as the Uniform Standards of Professional Appraisal Practice (USPAP). Further, the IVPI will be better positioned to work with appraisal organizations and state regulatory agencies to ensure the independence of appraisers and the integrity of the appraisal process.

Readers of Appraiser Active have heard all the reasons cited in the NAR letter. Kudos to the National Association of Realtors and President Charles McMillan for stepping into the fray.

Your letters to Congress, the FHFA and the decision makers and Fannie and Freddie may help the cause.

They meant for the acronym HVCC to be pronounced "havoc" right?

Freddie Mac Exec Found Dead At Home

(WUSA) A top executive at Freddie Mac was found dead Wednesday morning from an apparent suicide, according to CBS affiliate WUSA-TV in Washington, D.C.

David Kellermann, the acting chief financial officer and senior vice president of the government-sponsored mortgage lender, was found dead in his home after his wife alerted Fairfax County Police to his suicide, authorities told WUSA.

STORY

LATEST UPDATES

CALCULATED RISK - On the HVCC

Calculated Risk, an informative blog about Finance and Economics, posted yesterday about the Home Valuation Code of Conduct. There are excerpts from Ken Harney's "The Nation's Housing" column from this weekend, along with links to a couple of other articles.

Read it HERE

For regular readers of Appraiser Active, there's not much new. However, there are nearly 100 comments expressing a wide variety of views.

One of my favorite comments: They meant for the acronym HVCC to be pronounced "havoc" right?

SHOCKING!!: AMC - Appraiser Agreements and Indemnity

Please take a look at the Appraiser Legal Defense and Insurance Blog. They have posted an informative piece about AMC/Appraiser Agreements and the ever-more popular Indemnity Provisions. Their post spotlights an agreement used by TSI Appraisal Services.

They say:

We are receiving many calls from our insured appraisers about AMC agreements. Many of our calls in the last fews days have concerned the TSI Appraisal Services Appraiser Agreement. This agreement is worth looking at because, though more extreme than others in its one-sided wording, it illustrates the typical legal problems for appraisers found in AMC agreements.With regard to the TSI agreement, appraisers are particularly concerned about the indemnity section. Indemnity provisions are a recurring issue with AMC agreements. The bottom line is they are usually an AMC's attempt to shift potential liability by contract from the AMC to the appraiser. Because of the current mortgage crisis, this attempted shifting of liability is occurring more than ever.

...and go on

The first paragraph of section 7 requires, in part, that the appraiser "indemnify, defend, save and hold harmless [TSI] from and against any and all liability, claims, damages, penalties, losses, fines, judgments . . . [and] any other costs, fees and expenses . . . in any way related to . . . [among other things] any appraisal report submitted to [TSI] by Appraiser pursuant to this Agreement." Simply construed, this means the appraiser is promising to pay TSI for any cost or loss of any kind (including criminal or civil fines ordered against TSI) for anything related to an appraisal submitted by that appraiser. This is an unusually broad indemnity provision because TSI could conceivably take the position that the appraiser is required to indemnify TSI for losses caused by TSI itself in handling an appraisal or resulting from TSI's own negligence. For example, if TSI conveyed erroneous instructions to the appraiser which resulted in a problem with the appraisal and the lender client demanded that TSI make up a resulting loss, TSI could conceivably demand that the appraiser pay TSI for TSI's own mistake.

...and how about this gem related to Mortgage Repurchases?

Another significant issue is raised in the second paragraph of section 7. In this part, the appraiser "agrees that if a mortgage lender is required to repurchase a mortgage loan for any reason in any way related to [among other things] . . . any appraisal report submitted by Appraiser pursuant to this Agreement, Appraiser shall pay [TSI] an amount equal to the repurchase price paid by such mortgage lender to repurchase such mortgage loan." The appraiser is further required to "pay the reasonable attorney’s fees of [TSI] incurred in enforcing Appraiser’s obligations hereunder, including, with [sic] limitation, the obligation of Appraiser to pay [TSI] an amount equal to the repurchase price of a mortgage loan as set forth above."

Read the whole thing, PLEASE.

Florida's Effort to Regulate Appraisal Managment Companies

UPDATE 4-16-2009: It's not looking too good for the effort to regulate Appraisal Management Companies in Florida this year. Neither bill identified as a candidate to attach the AMC Regulation language as an amendment has been heard in committee. At this stage of the session, if a bill has not advanced, it ain't gonna.

Over the next two days several hundred Florida Realtors will visit Tallahassee, the state capital, to meet with our elected representatives. Florida Realtors have a number of legislative priorities, among them, the regulation of Appraisal Management Companies (AMCs).

Although we were able to get quite a bit of support lined up, the drafting of the appropriate bill took a little longer than we expected. Nevertheless, we have the bill ready, an amendment prepared, and bills in the Florida House and Senate identified as ready for amendment. We're not fooling ourselves, however. It will take some incredibly hard work and amazing luck to get this important task completed.

Watch HB 653 and SB 2524 and keep your fingers crossed that the AMC Regulation Amendment is attached and the bills are heard.

Updates will be made to this post as events warrant and time permits.

Free Fannie Mae 1004MC Tools

Many appraisers are wringing their hands, stressed about the April 1, 2009 requirement to include the Fannie Mae 1004MC form with appraisal reports. Over the past month or so there have been a number of free tools and resources posted online.

Here is a sample of what is available:

• First, Fannie Mae has a 1004MC Page. There is a link to download a pdf copy of the 1004MC Form and link to Recorded Training Presentation. According to Fannie, the presentation will allow you to "gain an understanding of and recognize the sources of market information necessary to analyze market conditions. Our new recorded training is organized to address the Market Conditions Addendum (Form 1004MC), effective April 1, 2009, section by section."

On the same page is a pdf of 1004MC FAQs for additional information about the form and other appraisal topics.

When it comes to gathering the necessary data and making the computations to complete the form, there are a few alternatives:

• If you area subscriber to a Multiple Listing Service that uses the Tempo 5 System, MarketLinx has developed an Excel Spreadsheet to automatically make the calculations. Instructions that detail how to structure your MLS search, download the data and insert it into the spreadsheet are at the bottom of THIS PAGE under "Appraiser Resources".

• George Hatch, a California State-Certified General Appraiser, has developed suite of Excel spreadsheets and instructions that detail how to structure your MLS search, format the results, download the data and insert into one of his spreadsheets. All of George's files are available on Box.net. Download the pdf file of his CATALOG and use that to locate the instructions and spreadsheet for your MLS vendor.

• Don Machholz, another California State-Certified Appraiser has a nifty suite of Excel Spreadsheets as well. His versions run on Excel and Open Office. You can find the latest versions of his work on his 1004 MC Spreadsheet page. In addition, Don has some other goodies, available by links at the bottom of the 1004 MC Spreadsheet page:

1. Market Trend Analysis Program: A multiple regression program for determining subject value over time, adjusted for SF, lot size and age of property.


2. DOM vs Selling Price: A program to determine quick sale prices.


3. Weighted Comps: Determines final value from comparable data from your grids


4. Snapshot of the Past Three Months: Similar to the 1004MC 10 column, but covers only the last 3 months.

There are some other resources to provide some answers to questions you may have about the form:

• October Research/Valuation Review provides some answers from Tracy Martin, a veteran appraiser and USPAP Instructor. Download the pdf HERE


• Liability Insurance Administrators has a short post about Minimizing Risk on the Fannie Mae Form 1004MC on their Appraiser Legal Defense and Insurance Blog

For the time being, this is what I've found available at NO COST to you. You've probably been inundated with emails and solicitations promoting solutions and tools at costs well above FREE. For a review of one of the programs, surf on over to Appraisal Scoop and read the REVIEW of David Braun's Total Solution by my friend, Doug Smith.

Give them a try. If you find other free alternatives, please send me an email or leave the information in the comments.

Lenders Not Yet Ready for HVCC

UPDATE#1 - Fannie HVCC FAQs Below

UPDATE #2 - Freddie HVCC FAQs Added Below

........no kidding, and few if any are ready for the May 1, 2009 deadline.

From HousingWire.com:

Survey: Lenders Not Yet Ready for HVCC

It’s not garnering as much press as it perhaps should, but new appraisal guidelines set forth in the Home Valuation Code of Conduct are set to go into effect on May 1 — and a recent study suggests that while U.S. mortgage lenders are confident their systems will be ready, few say they have actually completed system upgrades designed to ensure compliance.

That’s the finding from a recent survey distributed to more than 1,000 key industry personnel by mortgage technology company FNC, Inc. — the company’s client base includes major mortgage banks as well as regional and community banking outfits.

As the result of legal action almost a year ago, New York Attorney General Andrew Cuomo announced an agreement with Fannie Mae, Freddie Mac, and the Federal Housing Finance Agency (formerly OFHEO) to establish a Home Valuation Protection Program. The program demands significant changes to the real estate appraisal process for residential mortgage transactions and includes the Code of Conduct.

FULL STORY



Since the National Association of Mortgage Brokers (NAMB) has withdrawn their lawsuit against against Federal Housing Finance Agency (FHFA) Director James B. Lockhart over the Home Valuation Code of Conduct (HVCC), there are rumors of some groups seeking a delay in the implementation scheduled for May 1, 2009.



For a number of reasons, I agree with a delay in the implementation of the Home Valuation Code of Conduct. There are just too many unsettled procedural matters with the HVCC

• One of the pillars necessary for implementation of the HVCC is the Independent Valuation Protection Institute. Without the IVPI there is no enforcement mechanism, hotline, or means of verifying compliance. Delaying implementation would allow creation of the IVPI or establishing an alternative framework
• Many state legislatures are in the process of enacting laws to regulate Appraisal Management Companies. In other states, the regulatory agencies are in the process of promulgating rules and procedures to deal with Appraisal Management Companies. Delaying implementation would allow these states to finalize their actions
• To this day, the fact that the HVCC resulted from improper influence on appraiser independence by a Federally regulated lender and a rogue Appraisal Management Company cannot be reconciled with the apparent endorsement of unregulated Appraisal Management Companies as the “protector” of appraiser independence by the HVCC. Delay would allow a reconciliation of this glaring conflict. (See Story on New York AG Complaint and link to suit HERE)
• Fannie Mae has adopted policies that protect the brokerage fees from downward negotiation in certain transactions (short sales). Delay of implementation would permit efforts to protect appraiser’s fees from downward negotiation by Appraisal Management Companies. At the very least, it would allow time to arrange for full and transparent disclosure of valuation related fees in closing documents (AMC fee, Appraisal Fee, etc)

There’s more, but it should be clear that a delay would benefit real estate brokers, appraisers, mortgage brokers and consumers.

UPDATE #1 - Fannie believes they're ready. Fannie HVCC FAQs

My favorite:

Independent Valuation Protection Institute (IVPI)

Q55. What is the status of the IVPI?

The structure of the IVPI has not yet been determined and the IVPI has not yet been established. Therefore, the provisions in the Code regarding the IVPI are not yet effective.

Appraiser Active Question #1

Given the financial condition of Fannie Mae and Freddie Mac, when is the IVPI expected to be funded?

Appraiser Active Question #2

When is the IVPI expected to be created?

Update #2 - Freddie believes they're ready. Freddie HVCC FAQs

Taking a Break - Just for the Weekend

Every now and then we have to take a break from real estate appraisals, the Home Valuation Code of Conduct, Appraisal Management Companies, the Uniform Standards of Professional Appraisal Conduct and the Florida Real Estate Appraisal Board.

That's what I'm doing this weekend; taking a break. You will find me on the waterfront in downtown St. Petersburg, Florida, with thousands of other fans, walking the track and enjoying the Grand Prix of St. Petersburg.

Over the next week, I plan to make some comments about the Fannie Mae 1004-MC, the HVCC and the ongoing effort to regulate Appraisal Mangement Companies in Florida.

In the meantime, I'll see you at the races!

UPDATE!!

Race Results

NAMB Withdraws from Suit Against FHFA

NAMB's Strategic Withdrawal of Legal Action Against FHFA

McLean, Virginia, April 2, 2009 – In February 2009, the National Association of Mortgage Brokers (NAMB) filed suit against the Federal Housing Finance Administration (FHFA) to block implementation of the Home Valuation Code of Conduct (HVCC), which will inhibit competition among mortgage originators and increase the cost of mortgages to consumers. NAMB’s suit asserted that the HVCC constituted a "de facto" rulemaking that did not comply with the requirements of the Administrative Procedures Act (APA), which sets out the procedures a federal agency must follow when issuing a regulation.

Today, NAMB has withdrawn its lawsuit against the FHFA. NAMB invoked this strategic maneuver to assess means by which we can refute the FHFA’s claim that no court may review their decisions while the GSE's are in conservatorship. NAMB believes the FHFA's claim that there are no legal limits on the arbitrary and unilateral use of their conservatorship power is unprecedented and will prove detrimental to consumers.

"This issue goes beyond the bounds of this particular case," said NAMB President, Marc Savitt, CRMS, "All companies, investors, and trade groups should understand there may not be a court, any court, able to hear their case while FHFA is utilizing their conservatorship powers."

NAMB strongly opposes FHFA’s position that it does not need to comply with the APA and other laws. NAMB has withdrawn its lawsuit against FHFA, without prejudice, as it assesses various means to challenge FHFA’s extraordinary claim. Those options include filing suit again with revised and expanded arguments directed at FHFA’s new claim.

Press Release HERE

In other communication with NAMB members, the applicable Federal Legislation was described as HR 3221

Click the link, read it and weep.

Another View of AMC Regulation

UPDATE!! April 3, 2009

Scroll to the end of message

It looks like I spend WAAAAY too much time scouring the web and sources for information about the HVCC, Appraiser Regulation, Appraisal Standards, Mortgage Fraud and Appraisal Management Companies. There's quite a bit of information available, and I happened to run across a post on the TAVMA Blog.



TAVMA calls itself the voice of the settlement services industry. TAVMA is a 501(c)(6) non-profit trade association headquartered in Pittsburgh, PA that represents nearly 100 companies engaged in the real estate settlement services industry.

At any rate, TAVMA is concerned about the efforts to regulate Appraisal Management Companies. Here is the post from the blog:

Why State Regulation of AMCs Will Put Small AMCs Out of Business

Finally, someone in media has reported what I've been trying to get across for the past month: That state registration and regulation of appraisal management companies (AMCs) will assure the survival of only the largest of the large AMCs.

Unintended Consequences

In a story, about a proposed AMC bill in Missouri in today's Valuation Review, I am quoted (correctly) as saying that, “'… (T)his new legislation will have unintended consequences. Small or in-state AMCs won’t be able to afford the initiation fee. The state is essentially forcing small or local AMCs out of business. They’re taking jobs out of the state and putting them in other states with the large, national management companies.'”

FULL POST


My response is posted in the comments. Feel free to provide your point of view here.

UPDATE - April 3, 2009

It looks like several folks have surfed over to the TAVMA Blog to add their comments. Blog owner, Jeff Shurman has responded to my comments and several others. He has also promised to post a new entry in response to some of the issues raised. Use this LINK to access those comments when posted.

New Fannie Mae Selling Guide Released

Fannie Mae has released their 2009 Selling Guide. Unlike previous editions, this one is in PDF format.

Here's the LINK to download your copy!

Plenty of other information available at eFannieMae.com, single family.