Appraisal Scope

Well, at least the wondering is over...

FHFA has announced the final version of HVCC will be implemented by Fannie and Freddie as of May 1, 2009.  For those of you who have read our blog, you know that we have serious concerns about this agreement and on first read, the revised version does not address those concerns. 

If you are an independent mortgage broker, please take the time to read this final version NOW.  DO NOT WAIT UNTIL MAY TO DETERMINE HOW YOU WILL DEAL WITH THESE MAJOR CHANGES.  At Miller and Perotti, we have been providing one hour workshops, free-of-charge, to local mortgage brokers to assist them in understanding the agreement and it implications as well as how to implement the requirements.  If your offices would like to schedule a presentation, please call us.

Between the holidays, staff vacations, and an increase in appraisal requests, I don't have the minutes to develop a full rant on this news, so I am stealing from the National Association of Mortgage Brokers' press release.  Although I don't agree that "the problem" with the housing crisis is attributable to appraiser fraud as much as it is to loose underwriting and no-appraisal loans, I do agree that HVCC does nothing to deal with any of the underlying issues at the heart of our current housing crisis.  And I do agree with their other comments:

This agreement amounts to a de facto regulatory action which avoids the appropriate process. The law provides for a process to implement regulatory and policy changes such as those contemplated and specified in this agreement.

This agreement will increase costs to consumers and remove thousands of small business competitors from the marketplace. This will create a severe disadvantage to small business mortgage brokers, and prevent them from engaging competitively in the mortgage marketplace.

The Attorney General and GSEs disregarded many letters submitted by industry associations citing numerous laws and regulations already in place and for failing to make the necessary revisions in the new agreement to accurately address the problem of appraiser fraud.