twinkle
Freshman Member
- Joined
- Jul 22, 2008
- Professional Status
- Certified General Appraiser
- State
- Arizona
Feel free to correct my facts...As many of you know, HVCC was created when Cuomo (New York attorney general) planned to sue WaMu and discovered some damning correspondence implicating Fannie in something naughty. Fannie said, let's make some nice rules and not do a big ugly law suite, yeah...since we are a GSE and all, government sponsored entity.
OFHEO, office of federal housing enterprise oversees Fannie (well did) and says you can't make rules and not let us get involved, so they say, yeah, nice rules, now we're involved and now HVCC becomes a federal issue.
BUT HR3221 is now law. OFHEO is lawfully abolished and in its place is the Federal Housing Finance Agency for which the Federal Reserve and Treasury must consult with concerning Fannie and Freddie, I think I nice way to say, will oversee FHFA. Ok, HVCC isn't really officially dead that I know of, but all of the stuff below completely drowns it out, and in my opinion, makes it dead.
Good news, I think, the law HR3221 establishes a nationwide loan originator license program that will set minimum standards and provide oversight of mortgage brokers and bank loan officers. Licensing…hey there’s an idea. Do you suppose “Ethics” will be in their guidelines?
In addition, and if you see my earlier post, I'm hoping that the improved mortgage disclosure requirements to help borrower's understand their loan terms includes mortgage originator’s compensation and "kick backs", well that’s what I call them. I doubt it though, but Truth In Lending says, now mortgage brokers will have to obtain written agreements from borrowers in order to collect yield spread premiums, this is pretty cool....
Lastly, and some nice icing, ta dah, mortgage brokers will now be prohibited...officially (to funny that it was not official before, sorry not really funny) prohibited to coerce appraisers to inflate property valuations based on new rules for Regulation Z, Truth in Lending Act.
I think they got it covered pretty good and the issue of, who can order an appraisal which has us all concerned will create AMC monopolies, distroy business relationships, etc... will die down, it's no law, only a guideline supported by an office that has been abolished!!
How do you guys feel?
OFHEO, office of federal housing enterprise oversees Fannie (well did) and says you can't make rules and not let us get involved, so they say, yeah, nice rules, now we're involved and now HVCC becomes a federal issue.
BUT HR3221 is now law. OFHEO is lawfully abolished and in its place is the Federal Housing Finance Agency for which the Federal Reserve and Treasury must consult with concerning Fannie and Freddie, I think I nice way to say, will oversee FHFA. Ok, HVCC isn't really officially dead that I know of, but all of the stuff below completely drowns it out, and in my opinion, makes it dead.
Good news, I think, the law HR3221 establishes a nationwide loan originator license program that will set minimum standards and provide oversight of mortgage brokers and bank loan officers. Licensing…hey there’s an idea. Do you suppose “Ethics” will be in their guidelines?
In addition, and if you see my earlier post, I'm hoping that the improved mortgage disclosure requirements to help borrower's understand their loan terms includes mortgage originator’s compensation and "kick backs", well that’s what I call them. I doubt it though, but Truth In Lending says, now mortgage brokers will have to obtain written agreements from borrowers in order to collect yield spread premiums, this is pretty cool....
Lastly, and some nice icing, ta dah, mortgage brokers will now be prohibited...officially (to funny that it was not official before, sorry not really funny) prohibited to coerce appraisers to inflate property valuations based on new rules for Regulation Z, Truth in Lending Act.
I think they got it covered pretty good and the issue of, who can order an appraisal which has us all concerned will create AMC monopolies, distroy business relationships, etc... will die down, it's no law, only a guideline supported by an office that has been abolished!!
How do you guys feel?