HVCC Complaint Form Just Released

[Francois K. Gregoire]

This is my favorite part:

Thank you for your submission of a Complaint Regarding Improper Appraisal Conduct as described in the Home Valuation Code of Conduct. You may not hear anything further related to your complaint or the outcome of the resulting investigation. Your complaint will be taken seriously and appropriately investigated.​

For some reason, I thought the IVPI was supposed to offer a "hotline" for complaints? Here's the language in the HVCC:

The Independent Valuation Protection Institute

An Independent Valuation Protection Institute (Institute) shall be created as approved by the parties. Subject to section IX, when the Institute is established, the lender will provide information to appraisers and borrowers regarding the availability of the Institute's services, which are expected to include: (1) a telephone hotline and email address to receive any complaints of Code of Conduct non-compliance, including complaints from appraisers, individuals, or other entities concerning the improper influencing or attempted improper influencing of appraisers or the appraisal process, which the Institute will review and report as provided in IV.B(8) and IV.C(2) of this Code of Conduct; and (2) the publication and promotion of best practices for independent valuation. The lender shall not retaliate, in any manner or method, against the person or entity that makes a complaint to the Institute.​

 

[Mike Kennedy]

The lender shall not retaliate, in any manner or method, against the person or entity that makes a complaint to the Institute.


AND IF A LENDER, OR IT'S AMC SUBSIDIARY OR AMC AGENT, DOES??

 

[JRS at OBX]

The lender shall not retaliate, in any manner or method, against the person or entity that makes a complaint to the Institute.


AND IF A LENDER, OR IT'S AMC SUBSIDIARY OR AMC AGENT, DOES??

And it's not like the HVCC is a law so you probably wouldn't win if you sued them.

 

[Bearslide]

The lender shall not retaliate, in any manner or method, against the person or entity that makes a complaint to the Institute.


AND IF A LENDER, OR IT'S AMC SUBSIDIARY OR AMC AGENT, DOES??

Already happening - nothing changes. Different song, same old dance, do the deal, do the deal. And let's not let a pesky honest appraiser get in the way.........

The only difference, now, instead of one lender blacklisting you for being "un-co-operative", the AMC's blacklist you from dozens of former good clients. No notice, no written explanation, no recourse. This is a far, far cry from the intent of the original HVCC - and all slanted to do the deal, do the deal. The current program rewards skip and punishes the ethical, knowledgeable appraiser to a level individual lenders never dreamed of. Complaint site? Feel good, no teeth, no action, no change. Forgive my negativity, but if anyone was serious this would have been implemented from the git-go, not months after the AMC's have taken hold.

 

[Mike Kennedy]

And it's not like the HVCC is a law so you probably wouldn't win if you sued them.

December 2008 HVCC

VII. Referrals of Appraisal Misconduct Reports
Any lender that has a reasonable basis to believe an appraiser or appraisal management company is violating applicable laws, or is otherwise engaging in unethical conduct, shall promptly refer the matter to the applicable State appraiser certifying and licensing agency or other relevant regulatory bodies.
VIII. Representations and Warranties ​

A lender shall certify, warrant, and represent that the appraisal report was obtained in a manner in compliance with this Code of Conduct. If the Enterprise determines, on its own or from a referral made by the Institute, that a lender is in breach of a material aspect of this Code of Conduct or in violation of a provision of the Code by a complaint referred from the Institute, the Enterprise will enforce all applicable rights and remedies, including suspension or termination of the lender’s eligibility to sell loans to the Enterprise, if the lender fails to remediate.

Strongly suggest that any ACTUAL, LEGITIMATE, violations of the HVCC by lender personnel or AMC/agent personnel be documented on the Complaint Forms - NOW, then ........forwarded AS SOON as the Website is up and running in NOVEMBER. IMO, Flooding the Complaint website with opinions, frivolous, non-specific or generic "complaints" will bog down the complaint resolution process and will be entirely counterproductive.

ANYONE who does not have a copy of the Revised December 2008 version of the HVCC, or the original Home Valuation Protection Agreement - March 2008 can:

visit Freddie or Fannie's websites

http://www.freddiemac.com/singlefamily/home_valuation.html

Freddie, via Ms. Doty, has posted the Complaint form for a REASON. :icon_idea:

Suggest those with ACTUAL incidents of HVCC violations - it's time to let your voices be heard.

my 0.02

 

[JRS at OBX]

The problem is....

You'll still be on the "list" you just won't get any work.

 

[panappr]

Why do they want to know if you forwarded your complaint to any other government agencies? And the names of other people you contacted? It will be interesting to see how all this plays out.

 

[Mr Rex]

Why do they want to know if you forwarded your complaint to any other government agencies? And the names of other people you contacted? It will be interesting to see how all this plays out.

That way they know whether to throw it in the round file or if they should hold on to it until someone else makes a stink over it, and they can then claim it is an ongoing investigation.

 

[Mike Kennedy]

Home Valuation Protection Agreement March 2008 - Pgs 5-6 Governing authority for the COMPLAINT process:

II. FORMATION OF THE INDEPENDENT
VALUATION PROTECTION INSTITUTE ​

2. The parties hereto acknowledge that the integrity of the valuation processes involve federal and state laws and regulations as well as market practices and standards. This complex area requires a high level of expertise and coordination to ensure truly sound, accurate, independent and reliable appraisals.
3. To that end, the parties agree that an independent entity, the Independent Valuation Protection Institute (the "Institute"), will be established to monitor and study this area. The Institute may, from time to time, propose amendments to the Code which the parties to this Agreement will review and consider.
4. The Institute will establish a complaint hotline for consumers nationwide to contact if they believe the appraisal process has been tainted or if they have been harmed by appraisal fraud.
5. Appraisers themselves will be able to contact the Institute if they believe their independence has been threatened in any way, including by undue pressure. Appraiser complaints will be handled in confidence to protect the appraisers from ​

possible retaliation. The Institute, in its judgment, will mediate complaints or forward complaints to federal or state regulators. The Institute, in its judgment, may also forward complaints to state or federal law enforcement agencies for possible investigation or prosecution.

 

[LI-Appr]

Mike

It looks good on paper but that is where it will stay.