[Chris Colston]

Ok everyone, here it is. Effective 5/1/2009. The following should keep you busy reading and posting. It is actually quite interesting reading and some of the rumors and myths have been solved. Mortgage brokers are not going to be happy. Also from what I'm reading, no more CASH AT THE DOOR.

[Riick]

It's not final untill the fat lady sings.

[Jonsey]

Originally Posted by Chris Colston

Ok everyone, here it is. Effective 5/1/2009. The following should keep you busy reading and posting. It is actually quite interesting reading and some of the rumors and myths have been solved. Mortgage brokers are not going to be happy. Also from what I'm reading, no more CASH AT THE DOOR.

1. It's NOT OVER, till it's OVER and written in stone tablets brought down from the mount.

2. None of the rumors and myths have been solved.

3. Neither mortgage brokers nor 4 of the 5 banking regulators are h a p p y.

Last Updated: January 21, 2009

Bank Regulators Elevate Preemption Threat of Home Valuation Code of Conduct
Four of the five federal bank regulators have called for the withdrawal of the Home Valuation Code of Conduct and the Home Valuation Protection Program and Cooperation Agreements saying they could “unnecessarily undermine the safe and sound extension of mortgage credit, reduce the availability of mortgage credit to many consumers, and ultimately lead to less reliability and accuracy in real estate appraisals.” The agreements, entered into by the New York Attorney General, Fannie Mae, Freddie Mac and the Office of Federal Housing Enterprise Oversight, require mortgage lenders seeking to sell single-family mortgage loans to the GSEs to adopt the HVCC and to comply with certain practices imposed by the Code. In a joint letter, the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, Office of Thrift Supervision, and National Credit Union Administration cited concerns of insufficient information collection and analysis and the fact that the Agencies’ rules already address the issues of appraiser independence and protection from coercion.

[Chris Colston]

In a joint letter, the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, Office of Thrift Supervision, and National Credit Union Administration cited concerns of insufficient information collection and analysis and the fact that the Agencies’ rules already address the issues of appraiser independence and protection from coercion.

Like that's been working all this time! Who is enforcing the agencies' so called rules?

[Jonsey]

Originally Posted by Chris Colston

Like that's been working all this time! Who is enforcing the agencies' so called rules?

The FDIC stopped short of calling for a withdrawal of the agreement but promoted the use of notice-and-comment rulemaking instead of a sweeping carte blanche enforcement and supported the recent announcements that OFHEO may pursue amendments to the Code and Agreements based on the comments received by the April 30 comment period deadline.

Kiss May 1 HVCC enforcement goodbye.

The four other regulators stated that, if not withdrawn, “the Agreements and Code should be revised to exempt federally regulated lenders, and the implementation of the Agreements and Code should be deferred until the significantly adverse consequences are prevented and other material legal and policy concerns… are satisfactorily addressed.”

Kiss May 1 HVCC implementation goodbye.

[Randolph Kinney]

Lenders and AMCs pretty much do what they want. The GSEs think they have control but they don't. If they did, they never would have agreed to the HVCC settlement. But they know they are a bunch of crooks and did not want their books examined by the NY AG for fraud and still don't.

It is going to be the courts to decide as well as other regulatory bodies as to who has to participate under the HVCC.

FHA is already exempt. If that turns out to be the significant volume, you can bet that FHFA will revoke the HVCC requirement.

[Hutch Hutchcraft]

Confidence level with anything the government does = ZILCH!
Anybody with the gonads to go after the NY AG for stirring this up?

[Midwest1]

Originally Posted by Hutch Hutchcraft

Confidence level with anything the government does = ZILCH!
Anybody with the gonads to go after the NY AG for stirring this up?

Yes. the national association of mortgage brokers. too bad no appraisal orgainization will do a damn thing.

www.namb.org

[Summer]

I don't see where you can't collect COD at the door.

[mike32716]

I don't see where you can't collect COD at the door.

It's in the HVCC.

Regardless of the probability of the HVCC most large lenders have or are instituting firewalls between appraisers and LO's. The writing is on the wall...