Folks,
While I do not believe this is totally "much ado about nothing" I also do not believe the ultimate outcome- if there actually is one- will look much like what has been proposed.
So- OK I'll just tell what my sources tell me and they are fairly reliable.
Even in the face of threatened lawsuits, charges of rule breaking (I am not sure if Mr. Cuomo is actually breaking a federal law or if the consent order signed with OFHEO does that), it is very clear to me that the NY AG's office is going to proceed with this to whatever degree thay can.
They appear to be totally unafraid of lawsuits (no surprise- their staff are trial lawyers for the most part), do want to push certains portions of it, and do believe they will prevail- at least in part.
They have received all those responses from Mr. Biggers' crusade and are paying little attention to them. In fact, they are paying little attention to anyone opposing their plan- but they do seem willing to make modifications to certain parts.
I have heard no movement on staff appraisers except that it is not intended to remove an ib-house review function. I have heard they may be willing to move on the IVPI. I have no movement on brokers being able to order appraisals- they seem firm on that. So, if that part stands most of you will be working for AMCs for at least a portion of your mortgage work.
Will it happen this year? Almost no chance. There is some pending legislation by one PA senator but I have not yet read that, and in an election year, you may not see that happen either.
Only thing for sure is that nothing is for sure.
Brad