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Call to Action - HVCC

By
Mortgage and Lending with Lakewood Lending Group, LLC (NMLS#132141)

 

The National Association of Mortgage Brokers recently sent out a call to action in attempt to get the industries voice heard.    I want to make the mortgage brokers that are not in the association know, as well as appraisers, Real Estate Brokers, Consumers, and Title Agents know what they can do to have help the situation.               

 

NAMB has set up a HVCC Resource Center, which can be found at: NAMB HVCC Resource Center

 

NAMB also wants to receive emails detailing specific issues that have been created by HVCC (delays in closings, cost to consumer, lost rate lock, etc.).  This information can be sent to NAMB at the specific email address:  hvcc@namb.org

If you believe HVCC has caused issues in your business then please let let your voice be heard.  Whom to contact from NAMB release:

" Who will you be contacting?

NY Attorney General Andrew Cuomo's Office: (212) 416-8000, Internet Complaint
Federal Housing Finance Agency (FHFA): (866) 796-5595, director@fhfa.gov
Fannie Mae: (202) 752-7000, headquarters@fanniemae.com
Freddie Mac: (703) 903-2000, Internet Complaint
Senators, Representatives and Governors: Click here for contact information. "

 

The problems I've seen so far:

  • Each lender is requiring their own Vendor Management company
  • It is taking 2 - 3 times longer to get an appraisal
  • After the appraisal is ordered through one lenders "preferred" Appraisal Management Company, you cannot take the appraisal to another lender.
  • Quality appraisers with years of experience and industry knowledge are leaving, because these unregulated Appraisal Management Companies are taking 20 - 30% of the appraisal fee.

 

Articles Illustrating the Effects of the HVCC from NAMB email


    A.  The Appraisal Bubble - The Center for Public Integrity
    B.   The Cure is Worse than the Disease - Appraisal Press
    C.   Appraisals Roil Real Estate Deals - The Wall Street Journal

 

Don't forget to sign the petition for a Reconsideration of HVCC

 

Rhonda Porter at "The Mortgage Porter" wrote an excellent post on "HVCC:  Why Should YOU Care?"  Go check it out.

Jesse Skolkin
Independent New York State Certified Real Estate Appraiser - Fresh Meadows, NY

Regarding the point you made:

"After the appraisal is ordered through one lenders "preferred" Appraisal Management Company, you cannot take the appraisal to another lender."

Under USPAP (prior to HVCC), Appraisals could not be taken to another lender or "reassigned"  as illustrated in Advisory Opinion 26 below:

 SUBJECT: Readdressing (Transferring) a Report to Another Party

 APPLICATION: Real Property, Personal Property, and Intangible Property

 THE ISSUE:

 After an assignment has been completed and the report has been delivered, an appraiser may be asked to “readdress” (transfer) the report to another party.  Does USPAP allow an appraiser to “readdress” (transfer) a report by altering it to indicate a new recipient as the client or additional intended user when the original report was completed for another party?

No. Once a report has been prepared for a named client(s) and any other identified intended users and for an identified intended use, the appraiser cannot “readdress” (transfer) the report to another party.

I believe that the HVCC is the unfortunate result of lenders AND appraisers neglecting to follow USPAP (Uniform Standards of Professional Appraisal Practice).

 

Jun 09, 2009 01:33 PM
Laura Higginbotham
Arizona Real Estate Options - Mesa, AZ
Broker/Real Estate Consultant, Mesa, Arizona Home

Thanks for the post. I am so frustrated with these new rules. The result on my business are HUGE delays in closings, 3 out of 9 pending sales falling through completely -all due to VERY low appraisals.-that's a thirdof my business!  (ex: had 4 offers on a home for over $265,000 and appraisal came in at $238,000).

I work with investors who flip homes and now they are reluctant to even take an offer with financing becasue they have no idea if the deal will fall through....and because now these appraisals take as much as 3 weeks we are near Close of Escrow when it happens. EVERYONE suffers.

Result: further depressing property values in an already struggling market.....was that the intended outcome?

I can only hope enough of us in the field let our voices be heard and these rules are ammended.

AZ Broker for 8 years.

 

Jun 09, 2009 01:57 PM
Anonymous
Appraisal Influence Must Be Stopped

Laura, "low" relative to what?  To what you say it should be?  The days of realtors and loan originators faxing the sales contract to the appraiser and expecting him to "hit the number" are O-V-E-R.

I suggest the broad application of the Veterans Administration appraisal process to all appraisals.  It's been working for VA, with no degradation of value, for decades.  Whatever the VA fee appraiser--not two over-enthusiastic realtors and their hapless customers--says the value is, is what the value is.

Appraiser Pressure at Pandemic Proportions

http://tinyurl.com/qk9786

 

 

 

Jun 09, 2009 02:55 PM
#11
Russ Ravary ~ Metro Detroit Realtor call (248) 310-6239
Real Estate One - Commerce, MI
Michigan homes for sale ~ yesmyrealtor@gmail.com

There is always government interference so one person they know will make a lot of money and cost consumers more.

Jun 09, 2009 03:21 PM
Roland Woodworth
Blue Cord Realty - Clarksville, TN
Blue Cord Realty

Jeremiah: What a interesting post.. Great information. I will re-blog this as well.

Jun 09, 2009 03:46 PM
Marian Gregor-Ann
Keller Williams - Ann Arbor, MI
Arbor area Real Estate

Hi Jeremiah, I just had an appraisal situation yesterday, so this is a very timely post. I'll send it to my entire office.

Jun 09, 2009 04:00 PM
Christianne O'Malley
Dickson Realty - Reno, NV
Exceptional Service - Delivering Results in Reno!

This is a great post and I really appreciate the links to sign the petition and to send our feedback. I had a deal die because the appraiser was not qualified and the appraiser pool just sent some 20 year old kid that had done maybe 6 months of REOs...I will definitely be sending them the long drawn out explanation of how the HVCC really hurt my clients...

Jun 09, 2009 04:02 PM
Chris Olsen
Olsen Ziegler Realty - Cleveland, OH
Broker Owner Cleveland Ohio Real Estate

Hi Jeremiah -- One step forward...two steps backward.

Jun 09, 2009 04:38 PM
Hans Bruhner
First Priority Financial - Sebastopol, CA
Sonoma County Home Loans

I agree whole heartedly. There is one bright spot here. FHA is not participating. We lenders still have full control over who we place our FHA appraisals with.

As an honest mortgage banker/broker, I see what happened and what led up to this but this is not a viable solution.

Jun 09, 2009 05:37 PM
Chip Jefferson
Gibbs Realty and Auction Company - Columbia, SC

Its became an absolute mess. The days where a appraiser had to search county records to make sure the value was accurate are gone. Now they only rely on MLS data.

Jun 10, 2009 12:18 AM
Bill Gassett
RE/MAX Executive Realty - Hopkinton, MA
Metrowest Massachusetts Real Estate

Excellent information. I have already seen much longer appraisal times on a few occasions.

Jun 10, 2009 12:22 AM
Mark Watterson
Salt Lake City, UT
Utah Real Estate

Appraiser are like any other industry.  There is always bad apples.  This however is not the way to deal with them.  Let the state agencies handle the bad apples.

This also is not the cause of the mortgage crisis.  The mortgage crisis is much deeper and roots are in Washington.  This is just a distraction for the root cause of the problems.

Jun 10, 2009 12:26 AM
Ed Vogt
Midwest Properties of Michigan - Grandville, MI
Grandville, MI Midwest Properties

I was forwarded this e-mail by a local lender this morning.  Very timely post - I'm in the middle of dealing with an appraisal that came in way low by a not so reputable company even though the non-profit sellers had an appraisal done prior to listing. 

Jun 10, 2009 12:35 AM
Home Loan Search.Online
Home Loan Search Online - Newnan, GA

The cost for appraisals is an issue that I'm facing. Working with the same professional appraiser for years the price was $300, now my clients are paying $400+!

Jun 10, 2009 12:39 AM
Joe Pryor
The Virtual Real Estate Team - Oklahoma City, OK
REALTOR® - Oklahoma Investment Properties

Thanks for the links. I have had two lenders say that this has added an average of two weeks to get something closed. That kind of bureaucracy we don't need.

Jun 10, 2009 01:09 AM
Jeremiah Wean
Lakewood Lending Group, LLC (NMLS#132141) - Indianapolis, IN
NMLS#132221

Thank everyone for the comments.

@Brad Emler - I have seen the amount the AMC's take vary greatly from one to another, but in all cases I feel the amount is unreasonable given the minimal amount of work they do.  And it is an unfortunate fact that it is pushing qualified appraisers out of the business when we need them most.  Dealing with a declining market and the amount of foreclosures is not an easy task.

@Jesse Skolkin - I agree that USPAP banned appraisals from being reassigned.  However, prior to HVCC I was the client the Mortgage Broker.  So, I could take the appraisal from Lender A to Lender B.  USPAP's intention was to prevent the appraisal from going from Client A to Client B.  Now the client is the Lender, but even if it were me, each Lenders guidelines clearly state that they will not accept an appraisal from another Lender, it must be ordered using their platform.

@Laura Higginbotham - Please have your investor make calls and send emails to HVCC@namb.org.  The time has been all over the place, and the worst part is the lack of communication of when you will get the appraisal, or the status

@Ed Vogt - That would be great information to forward.  I think a lot of it is caused by the rush of the appraisal to get the report done, since they are making so much less per appraisal they have to do more appraisals.  Thus lack of quality.

@Darrell Walters - The prices have definitely gone up.  But the extra isn't getting passed to the appraiser doing the work.  I saw one AMC that charged $75 for the required market conditions report, but none of that went to the appraiser.  This came from an appraiser I spoke to that had been contacted about joining the AMC network.

 

Jun 10, 2009 03:32 AM
Stephen Kappre
KW Hometown - Mantua, NJ
Helping You Home

Went over and signed the other day. Something really does ahve to be done. This has caused such expense, stress, and chaos, and customer service is so much harder to keep within high standards.

Jun 11, 2009 05:37 AM
Jesse Skolkin
Independent New York State Certified Real Estate Appraiser - Fresh Meadows, NY

Jeremiah:

Sorry, I didn't consider the implications of the Mortgage Broker being the client vs. the Lender being the client.  I was under the impression that a Mortgage Broker could utilize an appraisal from one lender to another lender based upon Question #46 in "Home Valuation Code of Conduct Frequently Asked Questions".  Please copy the link below into your browser to get a copy of this document.

https://www.efanniemae.com/sf/guides/ssg/relatedsellinginfo/appcode/pdf/hvccfaqs.pdf

Jun 11, 2009 09:56 AM
Margaret Woda
Long & Foster Real Estate, Inc. - Crofton, MD
Maryland Real Estate & Military Relocation

Thank you for the contact info.  I contacted several appraisal organizations and they ignored me, so now I can start over AND provide this contact info to my buyers who were totally screwed (am I allowed to say that?) by their appraiser.  You may remember my post about an out-of-area appraiser demanding a quid pro quo for the right value rather than just correcting his numerous errrors.

Jun 21, 2009 02:41 AM
Anonymous
Darrell Palmer

Great Post!

It is good to see I am not alone in my frustration. Thanks for getting the word out.

Finally - Laura Higgenbotham...... your comment was not on-topic. Blaming appraisers for low valuations to serve your own financial need is not the point here. And your final "8 years" as an agent does not mean anything if you only sold 8 homes over that period. 

Darrell 

 

 

Jul 03, 2009 04:22 PM
#28