Appraisal Scope

With our last blog posting, some of you have requested a list of key people for voicing your concerns regarding the HVCC. I am providing a list, however the official window for public commentary has passed and it is my understanding that those comments were directed to OFHEO, Fannie, Freddie, and the NYS Attorney General.

Senator Elizabeth Dole was one of the only members of the Senate who seemed to pose any strong concerns about the HVCC. For details, see my first blog posting and this news release from NAR:

http://narblog1.realtors.org/mvtype/appraisalinsight/home_valuation_code_of_conduct/

Her replacement, Kay Hagan, appears to be in favor of HVCC, although it is unclear to me if she will take Dole's seat on the Senate Banking Committee or be assigned elsewhere. Educating her about the reality of HVCC may be a good place to start:

Here are my other suggestions:

• Each member of the Senate Banking Committee

Ask them why they are allowing such a significant document to be developed without legislative input, and share with them your concerns about the current version of HVCC.

• Each member of the Senate Small Business Committee

Let them know how this code will affect independent brokers and appraisers as well as home owners.

• Each member of the House Subcommittee on Financial Services and General Government
• Director James Lockhart and OFHEO are critical players in the final version of HVCC
• As is the Federal Reserve Board (see the letter posted in out first blog)
• And finally, President Elect Obama has a feedback link.

Feel free to cut and paste comments from any of my blogs, but original text from a significant number of voices will have the greatest chance of being heard.

For us at Miller & Perotti, we are now focusing on how to become HVCC compliant AND remain in business, as it feels that all of the prior feedback fell upon deaf ears. If you are an independent fee appraiser or an independent mortgage broker, feel free to contact us directly for our strategies. Kim@millerandperotti.com or 415-459-3517.

Oh, and just one more bit of irony:

In the same week that OFHEO publishes a document that asserts the need for greater appraisal regulation, the federal bank, thrift and credit union regulatory agencies jointly issued for comment proposed Interagency Appraisal and Evaluation Guidelines. The irony is that within the proposed guidelines are new appendices:

• Appendix A provides clarification on real estate transactions that are exempt from the agencies' appraisal regulations and
• Appendix B addresses acceptable evaluation alternatives and use of automated valuation models.

So appraisals need further regulation, but in the same breath are not always needed in the loan process?????

This document is not yet in final form so now is the time to give feedback to this document.