The recent passage of the financial reform bill includes provisions to impliment changes in the appraisal regulations which have hampered the process greatly since the start of HVCC. This has made the appraisal industry the punching bag of this forum for the past year. Now is your opportunity to change that instead of merely complaining.
I recently received the following e-mail directing where the industry can have input on the regulations being crafted to impliment the Bill. Please be aware that if those negatively affected by HVCC do not provide substantial input, the AMC lobby will do their best to form it to closely resemble HVCC.
Appraisers…….
Click the link: http://www.fdic.gov/news/news/press/2010/pr10187.html
You can participate with the new appraiser independence regulations that are being crafted as a result of the Dodd-Frank financial reform bill.
If lots of independent appraisers provide comments, the more likely it will be that your (and our) concerns will be addressed.
If you think direct client ordering of appraisals can be implemented, provide specific methods to do that which will preserve your independence but still allow business relationships.
If you don’t like that idea, then aspects of the current HVCC may be mandated – which will not help your business environment. Remember, the ‘commerce’ section of the HVCC actually had its beginning with FIRREA in 1989. Times change.
This has direct impact on appraisers and their businesses but also impacts Realtors and Mortgage Brokers. I would recommend that the latter two groups place it on the agenda of the next company meeting and designate someone to provide well-thought input on the part of your firm. This will keep the input directed and should eliminate extensive reactive comments specific to individual experiences.
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