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HVCC went into effect today. It is the new appraisal requirements negotiated by FNMA and FreddieMac with the New York Attorney General in settlement over a pending lawsuit. This pending law suit was being brought against a lender and an appraisal management group for alleged appraisal abuses.

So, to solve perceived problems with the appraisal process, it has been mandated for conventional loans that lenders and appraisal management companies control the appraisal process, separate from loan origination centers.

Several customers have already expressed concerns about the new appraisal process. I was writting a post describing how to communicate with the HVCC complaint department when I received an email from NAMB seeking information about HVCC problems.

It is expected by many industry professionals that this new process will cause loan approval and closing delays, increase closing costs, force consumers to pay unnecessarily for appraisals that will not support their loan, restrict appraisal transferability between lenders, and in general reduce home values in the market.

Additionally it will harm the consumer as well as the local appraiser who is running a small business by increasing the per appraisal cost, yet reducing the appraisal fee actually paid to the local appraiser. The reduced fee paid to the appraiser has been reported to me by some appraisers to be shocking low.

This by the way has been put on the local appraisers on top of a recent tightening of valuation documentation and standards that have increased the work load for each appraisal.

NAMB has provided an email to communicate problems with HVCC. It is encouraging somewhat that Federal Housing Finance Agency (FHFA) has requested such feedback. FHFA is the agency established this past summer to oversee FNMA and FreddieMac.

NAMB has asked for problems such as "increased costs, appraisal quality, portability issues, regulatory issues, etc." Problems must "include specific, tangible evidence of how the HVCC has prevented you from conducting business. 

Send an email, including your contact information, to hvcc@namb.org explaining the problem and it will be included in NAMB's report to the FHFA."

Other emails can also be sent to Rep Barney Frank , Sen Christopher Dodd, and your own Congressional represenatives who can be located via this map locator provided by NAMB.

Rep Barney Frank's home page indicates that he only accepts emails from his constituents. That is a little bothersome in my mind given that his focus and influence extend beyond the 4th District in Massachussetts. I would think that should extend his constituency. If you send an email to him supposedly it will be forwarded to the appropriate legislator.

This reminds me of the early predatory lending laws passed in Georgia which essentially stopped all mortgage lending in that state until corrective legislation was quickly passed.

If there are real problems please take time to communicate the facts and details.

These new guidelines do not impact FHA, VA, or Rural Housing loans.


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Richard Smith
NMLS# 184479 TN# 40161 GA# 28928 

Conventional, FHA, FHA 203k, HUD $100 down purchases, VA, Jumbo VA, Rural Development, Jumbo, FannieMae Homepath, Home Equity Line of Credit (HELOC).
Lending in Chattanooga, Tennessee and Georgia for over 20 years.

Stearns Lending, Inc

Cell phone: 423-280-0345 Email: Richard@HomeLoansChattanooga.com

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This blog represents the opinions of Richard Smith. The posts and comments written on the blog do not represent the opinions or positions of Stearns Lending, Inc. 

 
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13 Comments on HVCC complaints

MAY
01
2009
1,545,500 Points 416 Featured Posts Localism Sponsor Attended Rain Camp Called Shot Master

It is clear that the Congress, the White House have decided that they must first totally destroy the housing industry so that they can then rebuild it.

We, the housing industry, suvived 9/11 but we'll never survive the fixes by our own government.

 

3:29pm • #1
199,697 Points 13 Featured Posts Outside Blog

Lenn,

I appreciate your support on all these issues. There is still one that has not received much attention - credit risk retention.

As far as the destroy to rebuild thinking, it may not be a conscious and intentional strategy, but I think the underlying assumption is that everything is broke and any change is better than where we are.

Apparently, that includes all involved, including home owners. It just does not seem to include big banks who are too big to fail.

Richard

4:21pm • #2
829,433 Points 156 Featured Posts Outside Blog Hit Router Attended Rain Camp Called Shot Master

Hi Richard, I am inclined to see the strong merit in Lenn's comments.  I also liked this post and appreciate the links you provided. I think we come to see the real mess in this.

11:56pm • #4
MAY
02
2009
115,040 Points

Richard, the regulatory pendulum is swinging hard and fast in the other direction. NAMB is doing the right thing to bring swift opposition to the rules to keep the pendulum from going too far the other direction, but that is how it goes in the world of politics and business...soetimes the mix is a little dicey.

Good post

Bo

10:25am • #5
MAY
08
2009

It's been a week since the HVCC went into effect.

I have had absolutely no orders from the 40+ appraisal management companies I have signed up with. I am not even sure how they pick an appraiser for an assignment. For all I know, they use the same 3 appraisers and never go all the way down the list.

The only thing I have going for me is that I am an FHA appraiser.

I foresee small appraisal and mortgage companies going out of business within the next few months.

I can't imagine the impact this will have on the economy.

Brenna
9:54am • #6
199,697 Points 13 Featured Posts Outside Blog

Brenna,

I hope you will come back to this post and update how things go. You are very correct about the imact on the economy and especially on appraisers.

BTW, after signing with 40+ companies and no orders, how much were you going to be paid on average for an appraisal. That is if you don't mind publishing that info. I have some idea.

Richard

10:59am • #7
JUL
02
2009

All well and good that we are in this for a few months now. However, where is the HVCC Complaint Board? There are Appraisal Management Companies collecting fees for Conforming and FHA Appraisals, delivering the product to the Broker/Lender and NOT paying the Appraiser. This practice needs to be addressed imediately.

Francis McGuigan
10:52am • #8
JUL
23
2009

Just talked with a former client and he said his borrower paid $435 for an appraisal after all the fees were added in.   Boy are the borrowers getting screwed by HVCC.   After over 20 years in the business I am now OUT of business.  If Obama gets his way we will all be out of business.

Appraiser from California

 

Mike J.
1:11am • #9
AUG
17
2009

I would like to know where or who an appraiser turns to when he or she doesn't get paid by the appraisal management company. It seems like they just want to stretch us out as long as possible even though they are getting paid up front with credit card transactions from the borrower. I have 2 appraisals that are over 70 days now and I can't talk to anybody but the receptionist. I left numerous emails and messages and still no response. Did any of the bureaucratic morons think of this ???? Who is watching the AMC's ???? What a freakin mess, 25 years down the drain. Definitely looking for a new career.

 

Tony Pello
12:23pm • #10
AUG
18
2009

I laugh when I read the appraisers response to getting paid. How about we get some real appraisers who know what their doing. It's been total chaos, doom & gloom seems to be the under the breathe feeling when an appraisal is ordered. I have seen 19 ordered and 19 come back so lean it makes you wonder if the properties where ever worth anything from the start. Today, I ask all Realtors to have an independent appraisal completed by the owner, prior to the listing, once sold, the Realtor can let the appraiser know that they have an appraisal already completed. If the AMC appraiser comes in to short, the Realtors are suing the AMC company and appraiser. Good Stuff! Let's keep them honest.

Darren
4:43pm • #11
OCT
22
2009

    This whole HVCC process is a big joke. If you look at the broader picture at whats going on, is that the appraisers that are signed on with these management companies they are not giving true values to homes. They included shorts sales and foreclosures and dont even mention it in the appraisal once it is completed. Consumers that rely on fair and close to accurate values of their home across this country dont even come close. I've been i the mortgage industry for almost a decade now, and I have to say this from the bottom of my heart, this country is headed for destruction. Fannie, freddie open up new programs to help the public with values being over what their current mortgage balances, the appraisal process sets them back even further.

    I have to say that if 50% of homeowners let their homes go into foreclosure cause of being upside down, maybe then this new administration of the US will look at whats wrong with the picture in this country and change a few thing around. People that are self employed and dont claim every dollar on their returns are suffering at all the new guidelines. The crooks who put this country at where we are today should kill themselves to make things easier on the taxpayers.  To the Attorney General Andrew Cuomo, who proposed this process and put honest appraisers out of business, I can only hope that you end up just like Spitzer, both of you should only have the same carma that you put people through who try to make an honest living in this BS political country. 

  The problem is that people are scared in this country to voice their opinions because someone who has more $$$$$$$ then them will pay off some politician and they will fight to impose some dumb ass law that only helps a select few people who stand to profit from it, (oil, Wall st, HVCC, law enforcement, the list is too big to go on). There is no fairness in this country........I dont care what anyones elses opinion maybe, this is how I feel and think, and im sure that someone will rebut this post. You too can sign up to the military and maybe you can get blown up in one of these 3rd world BS wars that cost everyone money. WAKE UP PEOPLE.......SMELL WHATS ROTTEN HERE

Mike
3:22pm • #13
MAY
13
2010

For the record you can count two more experienced appraisers out of business.  I had 18 years experience and my partner had 8 years training under me.  Why on earth would any experienced appraiser continue in this business when they are forced to surrender every client and work for 30 to 50% of their typical fees?  Beats me.  Had I continued to accept orders I would be making less than I make as a trainee 18 years ago.  At that time I had no expenses.  Under the new HVCC extortion business model the fees that AMCs are paying would fall short of paying for overhead minus the appraisers salary.

Believe it or not greenhorn appraisers are still eating it up!!!  They are so inexperienced that they confuse staying business with making a living.  Eventually they'll be forced to recognize the difference either through bankruptcy court or through a divorce (and the loss of the partner that supports their bad habit of appraising for free).  A full two thirds of the appraisers in our state have left the business and we were hardly affected by the housing bubble.  License renewal has yet to hit us.  My guess is that we will eventually lose 85% of our licensees.

Retired Appraiser
7:45pm • #14

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Richard Smith FHA VA Rural Development in TN GA

Chattanooga, TN

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