My letter to NCAB in regards to the HVCC/their response

Discussion in 'Fannie Mae, Freddie Mac, USPAP' started by Gajope, Jan 19, 2009.

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  1. Gajope

    Gajope Junior Member

    0
    Jan 8, 2008
    Professional Status:
    Certified Residential Appraiser
    State:
    North Carolina
    go to bottom and read up:






    http://www.washingtonpost.com/wp-dyn/content/article/2009/01/09/AR2009010901920.html

    This is a really good article you might want to use in some way if you have not seen it.

    There really are a lot of nervous appraisers out here.

    Please let me know how I can help.

    I was very impressed with how the NCAB was one of the only State Boards to actually have an immediate official response to the HVCC. It would be great if our State could take the lead somehow on this. This is a story ripe for national attention.

    My cell phone is ****** if you wish to contact me.










    The North Carolina Appraisal Board will have legislation introduced in the next session of our legislature to require AMC’s to be regulated in order to do business in this State. Our proposed legislation is very detailed and will give us oversight over these companies. More information will be out soon on this issue and we will need the support of appraisers to get this passed into law.

    Philip Humphries





    I was wondering if the NCAB had been keeping track of the progress and changes which have been made to the HVCC and its proposed implementation date of May, 2009.

    The HVCC was supposed to free appraisers from undue influence, but I am afraid that the new revisions will do just the opposite as well as create a further danger to the general public.

    The new revised code apparently releases any lender from the original limitations which addressed the major concerns the HVCC was supposed to correct. It now only imposes these on brokers. The HVCC went from prohibiting a lender from owning or having an interest in an AMC to letting the lender own one, have staff appraisers, etc. but only the brokers’ restrictions haven’t changed from the original proposed code

    I have no idea how this will affect my business, but I do know that I do not do any work currently with AMC’s or directly for large lenders such as Bank of America or Wachovia/Wells Fargo. These AMC’s and Lenders require us to give up half or more of our fee to them. So when a borrower is paying $350, $100-$200 goes to the lender or AMC. All of my business is with brokers or correspondent lenders who do not play games like that and rip off the borrower. Last year we turned down requests from Bank of America’s EappraiseIT for full appraisals for $90 when the going fee is $350-$400. But, of course, someone out there is doing it for this fee or they wouldn’t be asking.

    The new HVCC gives Lenders and AMC’s complete control and influence over appraisers and takes away a big part of the free market/client relationships appraisers rely on to develop business and have a wide client list to get work from and keep any influence from one client to a minimum. If all of an appraiser’s work comes from 1 or 2 AMC’s, don’t you think that this appraiser will be more at the mercy of these 1 or 2 AMC’s rather than 15 or more brokers?

    I hate to bother you all with my email, and I have hesitated to contact the NCAB, but it appears that new regulation and structures are beginning to be implemented without much resistance and time is winding down on this one.

    This is a message from a friend/client of mine:

    Thanks ****. This will be part of my monthly conference call with the NCAMP Board of Directors at 1pm today. We share your concerns. This is just one of many on going attacks against brokers and the wholesale mortgage industry. Our lobbyists and attorneys will continue to represent our interests and concerns. I’ll keep you posted on our end. How does the appraisal board and/or association you may be affiliated with feel about all this??


    [​IMG] Board of Directors – Ethics Committee


    I have been an appraiser for 18 years and I truly believe that the HVCC will significantly change the way we do business and not in a good way.

    If there is anything that I can do to help the NCAB on this issue, I will do whatever I can.

    Sincerely,

    *****
    NC Certified Residential Appraiser #A****

     
  2. James E. Manning

    James E. Manning Junior Member

    0
    Jan 13, 2007
    Professional Status:
    Certified Residential Appraiser
    State:
    California
    "I was very impressed with how the NCAB was one of the only State Boards to actually have an immediate official response to the HVCC. It would be great if our State could take the lead somehow on this. This is a story ripe for national attention."


    In my research, I have uncovered comments by other appraiser boards flat out against the use of AMC's and are in fact, very critical of them including Alabama RE Appraisers Board; Nebraska Real Property Appraiser Board; and Arizona Board of Appraisal, to name a few.

    I am sure that there are more. Arizone has 3,030 appraisers; Nebraska has 907; Missouri has 1,913. California has over 22,000 at last count and don't answer emails...so don't expect anything from them.They are overloaded.

    The wheels are starting to turn. Keep the faith!
     
  3. SmilingDog

    SmilingDog Member

    0
    Apr 22, 2003
    Professional Status:
    Certified Residential Appraiser
    State:
    California
    You really think OREA will do anything?
     
  4. James E. Manning

    James E. Manning Junior Member

    0
    Jan 13, 2007
    Professional Status:
    Certified Residential Appraiser
    State:
    California
  5. silverstreak

    silverstreak Sophomore Member

    0
    Dec 4, 2008
    Professional Status:
    Certified Residential Appraiser
    State:
    California
    Heck no, they won't do a thing. My daughter is a Certified General and MAI and works for a large ag lender. They ordered an appraisal for one of their growers that was buying a small ranch with a home on it. The appraiser completed the appraisal and sent it in to her company and she was asked to do a review on it by her boss. She showed me the appraisal and it was absolutely a joke. The appraiser used bare land comps and added for improvements when there were several available sales of properties similar to the subject with improvements. I have done many reviews and have never seen an appraisal as bad as this. She called the appraiser, a certified residential appraiser, and asked him questions regarding comps he used and other questions regarding the poor appraisal report. He told her that there was nothing wrong with his work and would not change a thing. She told him they could not accept the appraisal and if he was not willing to talk to her about the problem she had to order another appraisal. He said that was fine but still expected to get paid for his work. She told him that she was so mad about him being so uncooperative she was going to turn this matter over to OREA. He said that was fine and hung up. My daughter ordered another appraisal and it was completed professionally with the right comps. She blacked out all the necessary information on both appraisals, wrote a very detailed letter and sent it to OREA. After about a month she had not heard anything so she called and was transferred to the person in charge of the case. She was told by the officer in charge that he had just completed reviewing all and agreed with her and fully understood her anger, but was not going to do anything, not even send a letter to the appraiser reprimanding him for his shoddy work. She was furious but could not convince him to do anything. This is why I am so cynical about expecting OREA to do anything.
     
  6. SmilingDog

    SmilingDog Member

    0
    Apr 22, 2003
    Professional Status:
    Certified Residential Appraiser
    State:
    California
    Why didn't the investigator at OREA do anything? Did he say why? If he agreed that there was something wrong why didn't they do something about it?
     
  7. silverstreak

    silverstreak Sophomore Member

    0
    Dec 4, 2008
    Professional Status:
    Certified Residential Appraiser
    State:
    California
    He told her the same old thing, they were understaffed and pretty much had to pick and choose the ones they wanted to prosecute. He concurred with her and agreed this was one of the worst files he had ever reviewed but still was not going to do anything about it. This happened about 2 years ago.
     
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