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Independent Appraisers GSE/Cuomo Proposal 3/19/08

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I must say this is a piece of work, however, IMHO the tiered review may bring this proposal to its knees, if accepted. With the added cost of providing and implementing this, it will require and enormous staff of qualified reviewers???.


Pg 10 Section 1

Establish IVPI State Review Panels:​
1. Regional and State Review Staff

and qualified Panel Members :icon_idea:

will be responsible for conducting audits and reviews, investigating complaints and associated responsibility.​
 
PLS SEND YOUR COMMENTS TO EVERY LINK BELOW........THANK YOU.


COMMENTS ON ENTERPRISE APPRAISAL CODE​
[FONT=Verdana,Verdana]Comments on the Home Valuation Code of Conduct, announced on March 3rd, may now be made directly to Fannie Mae and Freddie Mac. The comment period established by the Enterprises is for 45 days, ending on April 30th.[/FONT]

[FONT=Verdana,Verdana]OFHEO will be reviewing comments provided to the Enterprises. [/FONT]

[FONT=Verdana,Verdana]Comments may be sent as provided below: [/FONT]For Freddie Mac: [FONT=Verdana,Verdana]Comments should be submitted through the online form on the Enterprise’s website at http://www.freddiemac.com/singlefami...valuation.html. [/FONT]

For Fannie Mae[FONT=Verdana,Verdana]: Comments should be submitted through the online comment form at[/FONT]

[FONT=Verdana,Verdana]https://www.efanniemae.com/go/appraisalcomment.jsp or,[/FONT]

[FONT=Verdana,Verdana]for additional information and the comment form, use[/FONT]

[FONT=Verdana,Verdana]https://www.efanniemae.com/sf/guides...code/index.jsp. [/FONT]

__________________________________________________ ___________

NY STATE ATTORNEY GENERAL CUOMO

http://www.oag.state.ny.us/contact.html


http://www.oag.state.ny.us/online_forms/email_ag.jsp

__________________________________________________ ___________

http://www.appraisalinstitute.org/ano/current.aspx?volume=9%20&numbr=5/6

OFFICE OF THRIFT SUPERVISON

http://www.ots.treas.gov/resultsort....&dl=104&edit=0

http://www.ots.treas.gov/resultsort....&dl=103&edit=0

http://www.ots.treas.gov/resultsort....&dl=102&edit=0
__________________


Send your comments to Ken Harney here: mailto:KenHarney@earthlink.net


MBA BOARD OF DIRECTORS
http://www.mortgagebankers.org/roster/default.aspx?id=ros34873
__________________

Email Comments on the AG/GSE AGREEMENT and IVPI PROPOSAL to
http://www.mortgagebankers.org/roste...px?id=ros30388



New York
President
Gene Tricozzi Northern Funding Corp. 518-371-6886 518-371-5103 genet@northernfundingcorp.com


Executive
Richard Byrne NYAMB 914-332-6233 914-332-1541 rbyrne@taminc.com


Staff
Edie Tella NYAMB 914-332-6233 914-332-1541 etella@taminc.com


Delegate
Gene Tricozzi Northern Funding Corp. 518-371-6886 518-371-5103 genet@northernfundingcorp.com

Delegate Richard Biondi BJB Financial Consultant 631-249-4005 631-249-4033 rbiondi@rjbmortgage.com
 
Great Job

I want to personal thank everyone who worked so hard in such a short amount of time to put together the proposal and other information.

I believe that the appraisal profession as changed more since early March then we saw in the last 15 years.

I know that many appraisers have ideas and thoughts of just what should be done and they are all important but right now I am willing to put my complete trust in the people I see working hard to correct many of the problems we all share everyday.

If there was ever a time for appraisers to unite and stand up this could be the time.

When I read some of the comments people are already making I wonder just who's side their really on.

Let's all take a step back and give this a chance to work.

I support all of the people who have worked so hard in just a few weeks on this whole new plan so that maybe some day the rest of us will have a better life.

Just my opinion Jim Hill
 
A simpler solution, if it could be done, would be to make the originators buy back the paper if they default within a certain time period. Don't you think that would make the mortgage brokers/loan officers/etc think twice about calling uncle skip to run out and put the rubber stamp on the property?? For example, If Bank A originates a loan, sells it off to Fannie or freddie or whoever the flavor of the week is. Let's say that if within two years the loan goes into default Bank A has to buy the paper back from whoever it was sold to. If this could be done wouldn't it make lenders/brokers think twice about hiring skip to put some unrealistic value on a property?? Just asking

I do greatly appreciate the efforts and energy that has been expended by all involved. Pam has sacrificed her life for our industry and I have the greatest respect and admoration for her.

Financial responsibility for the lenders actions would greatly solve these types of issues. It is evident that when the 'Big Investors' started sending loans back for a refund due to early defaults and 'faulty' packages (not only appraisals but fraud committed by the initiating lender (broker, lo...) on the applications and financial data) the lenders tightened the reigns. Hitting the pocket book almost always makes the masses behave.

I do like the majority of the proposal and do not have issue with the AMC type set up. I do believe that the AMC model in theory is positive; the problem (one of many) is it became a profit center not only for the AMC but also for the lenders that owned the AMCs.

I am confused on how requests will be ordered and assignments be given. Am I correct that lenders will be able to order thru their own appraisal dept to an independent appraiser that they have an established relationship with? Will other AMCs still be in existance and this organization will more or less be another AMC run by the IVPI? IF that is the case, then it is pretty much business as usual with hopefully more enforecment of the rules. Of course, enforcement is where the issue is today - there has been none.

One concern I have is that depending on the way this plays out, there is a strong possibility of a complaint being filed due to business constraints or an anti-trust issue if business relationships are considered null and void. It has happened in other industries similar to ours and we need to consider those lessons as we all know - history repeats itself over and over again.
 
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Why shouldnt the IVPI be purely a review arm? I think it is rather hard to imagine that the many businesses that exist in the form of AMCs will be eliminated. I simply do not think it will happen. From a realistic standpoint while we may wish for this to happen, the simple fact of the matter is it wont. We must live with that and to that end our proposal must be with that in mind.
The Vault is an excellent idea. A repository for appraisals where an appraiser can upload the report, it can be locked, the lender can dowload the report, and use it in loan closing. The borrwer can download their report for review as required by the Cuomo agreement. The Vault would maintain the report for the statutory period or longer should we decide.
It simply seems to me that what is lacking is a means of reviewing the reports for accuracy, competency, and compliance. That should be the sole function of the IVPI and that which we as appraisers can do best.
I would suggest to you that if every appraiser in the country knew their appraisal was going to be reviewed by an experienced peer .. the quality of the work would substantially increase. Those found to not meet the requirements can be counseled, turned into their state board for discipline, or at the discretion of the GSEs can be removed from the approved list as providing acceptable work.
We need to do what we do best ... appraise and review.

I stand ready to help in any way needed. I will work my tail off to help.
 
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In the absence of leadership that is truly interested in our profession a group of natural leaders have come forward with a proposal. It is an opportunity we all had but did not avail ourselves of. They saw the breach in the wall and sent out the rallying call. We can live on our knees, and continue to be abused or we can rise up together as a potent force whose time has arrived. These self appointed leaders have done the work and placed themselves in the cross hairs and I respect that initiative, courage and commitment.

Right now our profession has an opportunity that we never have had before and will likely never have again. In life, timing is everything. We have no expensive lobbyists. Our numbers are few and we have virtually no political power. The forces that have worked to subjugate us are now on their heels and teetering backwards. We can choose to sit and watch and hope for change or we can rise up off our knees and strike back while we have the advantage.

The plan is not without difficulties but it is a plan and as I said timing is everything. There will be time for refinement and adjustment. In the earlier part of my life I commanded a Field Artillery Battery and studied all the great masters of warfare. One of the quotes I often return to was from General George S. Patton who said:

"A good plan violently executed right now is far better than a perfect plan executed next week."

All of us sitting on the sidelines need to stand and be counted. Bickering and infighting will surely doom us.
 
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Answering the call

"The call" was the individual, internal recognition that massive change is pending with or without appraiser input. It's a euphemism, folks. People who answer "the call" are acting on their own sense of urgency.

Posters on this thread are constantly crying out for leadership, always complaining that some entity or the other has failed to step up to the plate and begging for someone else to take action, write a letter, mount a lawsuit, or spoon feed the masses with an on line petition that is mindlessly easy to click on and sign.

These people in this thread who have answered their own internal call have not waited for someone else to make it easy for them. They took action. Who cares if they are self appointed? If I want to submit a proposal, I'm certainly not going to wait around for someone to appoint me. And I'm certainly not going to wait around for a herd of cats to reach a consensus on a public forum.


The urgency

Massive change is pending with or without appraiser input. And there are powerful people who do not have the best interests of appraisers or the public trust at heart that are, as we speak, bringing massive amounts of pressure on the people in power with their own proposals. The timing is urgent. Input needs to those in power has to happen fast.

The proposal in this thread had to be in Cuomo's hands quickly. Speed was a strategic necessity.

Membership?

Pam put out a question, "if there were an AMC that insured appraiser independence, would you be interested?" She made an electronic sign up sheet available and stressed that, for now, it was just a show of interest. That did not make anyone a "member" of anything except a member if a group that had expressed interest.

Furthermore, all of the posts in this forum have gone into the thinking process of this committee. After the settlement agreement was posted, Pam posted more than once (on our long threads) that "this is good stuff please keep the ideas comming." In this indirect way, we all had input.

Public input

Now that these self starters have answered the call and formulated their own proposal, which is an organizational outline, they are simply asking for your support. And they are asking now for your further input for ideas or pitfalls that may occur during the actual development stage.

It's great that people are questioning aspects of the proposal and offering ideas to make it more palatable to them. But the basic concept might not change. If one were to think that the basic concept were so off that no amount of tweaking would get them to support it, then they need to get busy with answering their own call to formulate a proposal. And they need to do it fast.

Because if this is the only proposal that Cuomo gets that actually protects appraiser independence, and all the other proposals he gets are nothing more than the usual plausible deniability loopholes for lenders, then it is imperitive that he (and the feds) see a show of support from appraisers. **Quickly**



The proposal

It is an outline of a plan that accomplishes two main goals; it works in conjunction with the already signed settlement agreement and it actually enhances (and does not diminish) appraiser independence. That's the basic starting point.

Appraiser independence, not just a good idea, it's the law

The economic meltdown has engendered new interest on the part of those in power in enforcing the existing banking laws regarding appraiser independence. Bank LOs, MBs, and AMCs should never have been allowed to be in a position to pressure appraisers, it's illegal. It may be painful for us, but we simply must remain of the side of begging for enforcement for those laws. Every single attitude of ethical appraisers must be filtered through that concept.

Just because one has a client pool that does not pressure, or that only pressure in a way that allows one to not cave in to it and remain ethical, does not change the fact that the law says those clients should never be in that position.

Frankly, any position espoused that does not make appraiser independence the primary focus is seen by me as a protectionist attitude that favors the status quo of leaving clients in a position to pressure appraisers.

Lamenting for the old days has it's place but accepting the reality of what we have to work with, now, is urgent if we are to have any say at all in what happens through the actions of those in power.

I'm endorsing. Now.
 
Mr. Hatch, Ms. Crowley, Mr. Kennedy, Mr. Dodd and the rest, thank you all for your efforts. Consider me a supporter. I suggest ignoring the vocal naysayers profiting from the current system, they would be deriding anything that changes the status quo.
 
Marcia,

Well said!!!!! You wrote the exact post that was forming in my head as I read this thread.

People - It's a start and someone had to make it.
 
Methinks there's a lot of hurt feelings, some thought they were in a clique but aren't. George, Pam and...well I forget the others, submited a proposal. If you don't like it you still have time to round up the cats and submit your own. You won't be alone, I'll bet every AMC (heck Zaio already brown nosed Coumo) has either submited something or will.

I kinda enjoy watching newbies and people who've been registered for years with nary a post getting bent out of shape. Everything was fine for them until the Fannie/Freddie announcement. Oh well, that's life in the big city.


Exactly my thoughts, 5000 people showed up to bit*h, Where was your proposal? Where was your input? Pam, George Etc. took the initiative to develope a solution to the very dark looking future and show us some light. Am I happy I am loosing a lot of my client base, NO!. Would I rather sit back and let every AMC tell the NYAG and the GSE that they are the best solution, HELL NO!!

If you're not interested O'well, go think of something else, show a plan, and quit bit*hing
 
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