Lee Ann,
It's true, everything is up in the air.
To date, there have been no published changes to the HVCC but there is significant widespread commentary regarding it, most importantly from the banking regulators. If they were to achieve some sort of preemptive regulation, they could affect it greatly.
I imagine the rumors you have heard about implimentation deadlines in the fall are refering to the GSEs' individual policy changes that are not a direct implementation of the HVCC but are perceived by some observers to be related to it.
Originally, the GSEs, OFHEO, and Cuomo expected to report the results of the comment period or it's effect on the agreement sometime in mid to late summer. It will be interesting if they actually do that in light of the regulatory changes that are being proposed.
It will also be interesting to learn how that changing regulatory environment might affect Cuomo's decision to drop the GSE investigation in the event that the agreement gets gutted. I'm thinking he will get most of what he wanted regarding appraiser coercion one way or the other.
From the beginning I have said that regardless of the outcome, Mr. Cuomo's effort has been the only attempt to actually define appraiser coercion and to try for an actual policy that would have some effect on minimizing it. I'll always be greatful for that.
If the HVCC had never been published and distributed on national stage in such a way as to get everyone's attention, we'd still be whining that no one seemed to be reading our petition.
You'll recall that Cuomo's investigation of the GSEs stemmed from his investigation of FirstAm/Eape and their WaMu memos.
Did you notice the news that FirstAm/Eape is now the target of an investor's class action suit stemming from those same inflated appraisal accusations?
I have a feeling these things are just the tip of the iceberg. I'm very glad that the HVCC's description of what appraiser coercion is is "out there."
