It seem like every where we turn mortgage brokers are being attacked. Many of the new laws and rules that on the table only change the way a mortgage broker conducts their business. Here is another one.
Here is a notice and call for help from the NAMB (if your not a member of your local chapter - you should be)
Included is a sample letter to send.
If your not a member take that part out (or you could join)
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Take Action Now!New GSE Policy Prohibits Mortgage Brokers from Ordering Appraisals
Dear NAMB Member:
Fannie Mae & Freddie Mac recently entered into agreements with the New York Attorney General that will prohibit mortgage brokers from ordering appraisals. The GSEs are accepting comments on these agreements until April 30th.
Please respond to this critical call-to-action and tell the GSEs that there are better ways to address concerns over appraiser pressure and coercion, and that mortgage brokers help keep consumer costs down and promote comparison shopping when they order appraisals for their customers.
Below you will find a sample letter, which you are free to use in its entirety or modify, but please take a moment and submit your comments to the GSEs.
Comments may be sent to Fannie Mae by clicking here, and Freddie Mac by clicking here.
The agreements between the GSEs and New York Attorney General Andrew Cuomo were entered into on March 3, 2008 and are scheduled to take effect January 1, 2009. A copy is available by clicking here.
This may be the most important issue facing our industry today.
It is vital that you share your comments with the GSEs by April 30th.
Thank you for all of your continued support.
George Hanzimanolis, CRMS
NAMB President
******************************SAMPLE LETTER***************************
Dear Sir / Madam:
I am a mortgage broker and a member of the National Association of Mortgage Brokers ("NAMB"). I am writing to express my grave concern over the appraisal agreements entered into by the GSEs and New York Attorney General Andrew Cuomo.
Although I support the concept of a Home Valuation Code of Conduct, I strongly oppose the prohibition against mortgage brokers ordering appraisals for their customers. Under this Code, consumers will be financially tied to whichever lender they submit an application to first. If the consumer needs to submit an application to another lender, for any reason, a new appraisal must be ordered, the consumer's costs will rise significantly, and unnecessary delays are likely to follow.
All of this creates a disincentive for consumers to shop around for a mortgage loan that is right for them, and penalizes consumers if they ever need to change lenders in order to secure approval, a better rate, lower fees, or a more attractive loan product or program. Additionally, appraisal quality will suffer if local, independent appraisers, who have longstanding professional relationships with mortgage brokers and real estate agents, are cut out of the process.
Moreover, there are a number of possible alternatives to this Code that would actually address the problem of appraiser independence, while promoting consumer protection and comparison shopping, without disadvantaging an entire segment of the industry. Some better alternatives include:
1. Establishing a Peer Review System for Appraisals.
2. Requiring Lenders to Conduct Independent Appraisal Reviews.
3. Providing Regulators with the Resources Necessary to Conduct Comprehensive Audits and Review.
Mandating accountability for appraisers will benefit consumers and the industry far more than targeting long-standing business relationships that present no inherent problem.
If the Home Valuation Code of Conduct takes effect as it is written today, it will harm consumers and put me out of business, along with thousands of other mortgage brokers and the small, independent appraisers who rely on us for their business.
Please reconsider the prohibition against mortgage brokers ordering appraisals for their customers.
Sincerely,
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