NAMB Lesiglative Update

Mortgage and Lending with Citizens Bank & Trust NMLS #192086

TO: All NAMB Members
FROM: NAMB Government Affairs

Dear NAMB Members:

On September 18, 2009 the Department of Housing and Urban Development (HUD) released Mortgagee Letters 09-28, 09-29, 09-30. These mortgagee letters contain provisions similar to those seen in the Home Valuation Code of Conduct (HVCC). Mortgagee Letter 09-28 prohibits "FHA-approved lenders... from accepting appraisals prepared by FHA Roster appraisers who are selected, retained or compensated in any manner by a mortgage broker or any member of a lender's staff who is compensated on a commission basis tied to the successful completion of a loan." Mortgagee Letter 09-29 states, "In cases where a borrower has switched lenders, the first lender must, at the borrower's request, transfer the case to a second lender." Mortgagee Letter 09-30 changes the appraisal validation periods from 6 months for existing properties and 12 months for proposed or under-construction properties, to 120 days for both.  All three of these Mortgagee Letters go into effect for case numbers on or after January 1, 2010.

These letters are of great concern to NAMB, as we believe mortgage brokers should be able to order their own appraisals. NAMB officials will be in Washington, DC next week and will be meeting with members of Capitol Hill as well as attending various other meetings.

Click here for a copy of the Mortgagee Letters issued by HUD on September 18, 2009.
Click here for a press release on these mortgagee letters and upcoming rule making.

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