Code of Conduct and the Feds.

[Kevin A. Spellman]

This was sent to me from the MBREA a private appraisal organization here in MA.

An interagency effort by Federal banking regulators to have the Code of Conduct withdrawn by the Office of Federal Housing Enterprise Oversight is spelled out in a letter dated June 19, 2008.

The Office of the Comptroller of the Currency, The Board of Governors of the Federal Reserve System, the Office of Thrift Supervision and the National Credit Union Administration jointly signed a 5 page letter addressed to James Lockhart, III, Director of OFHEO. In the letter the agencies elaborate on their concerns about the consequences of the Code and, in the final paragraph, state, "We strongly encourage that the Agreements and the Code be withdrawn."

A final decision about the future of the Code will be announced sometime in the future. The good news is that pressure from key players to scrap the deal keeps mounting. MBREA will provide updates as they become available.

 

[Marcia Langley]

"We strongly encourage that the Agreements and the Code be withdrawn."

Of course they do.

The problem with the HVCC is that it describes exactly what appraiser coercion is. Industry participants (all of them/us) have made it clear that what's wanted is vague, lip service, easily circumvented language similar to what already exists in the federal banking regs. Everyone agrees and applauds that more safeguards be in place but their alternative language proposals to that in the HVCC is, to a one, just a continuation of vagueness.

All of the proposed bills in congress very carefully reduce the subject of appraiser coercion to something that can provide plausible deniability.

Let's keep those wheels greased.

Maybe what's needed is to reduce the HVCC to Section I and expand that section to a more thorough description of what appraiser coercion actually is and to expand the list of obligated entities to be more comprehensive of all potential coercers.

 

[RSW]

Wow, Marcia. You are my hero!