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HVCC Is Dead-HR3221 Is Law

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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?
 
I do agree that HVCC is probably dead however I suspect its influence may not be.

Appraisal ordering is shifting to AMCs everyday because the obituary on HVCC has not been published. As the effective dates draw near financial institutions have to operate on the assumption that it will happen until they get confirmation that it is dead.

I believe in the long term there has to be a flight to quality which should serve appraisers with greater skills, credentials and experience well however the short term game is "survival".

The current confusion in the market and regulatory functions is tearing us up.
 
Licensing individual loan originators will work only to the extent that the rules are enforced. If the government doesn't do a whole lot better with the legion vast of loan originators - some of whom really are crooked - than they did with the measly 100,000 appraisers then I'm afraid it will all be a waste of time, money and effort. A whitewash intended solely for the purpose of enabling the next cycle of abuse and fraud.

Licensing loan originators is perhaps a little better than nothing, but it won't address the root cause of overvalued collateral. If you guys are depending on LO licensing to solve your problems with loan originators then you're deluding yourselves.

But not to worry. You guys will still be able to keep your MB relationships, and after all, that's the only thing that matters here. Right?
 
Licensing individual loan originators will work only to the extent that the rules are enforced.
And since we know how good the regulators are at enforcement, it's all simply more lip service. They need to add some teeth to those lips!
 
Check out states that had licensing of L.O.'s and you find that they have just as many problems as those who had no licensing.

Licensing is not the answer. Enforcement of rules, regulations and laws are.:new_2gunsfiring_v1:


But then again we must open our eyes to see, and right now they are firmly closed in denial. ( It makes us feel feel warm and fuzzy, sorta like lint)
 
Funny isn't it, money cannot be found to enforce the laws, but plenty of money can be found to bail out the law breakers!!
 
The money that we would have spent on enforcement of the existing rules and regs is literally a drop in the bucket compared to the cumlative total losses in the general economy resulting from these unchecked-violations. The cost of this bailout and the losses from the insolvent lenders are just the tip of the iceberg.
 
The money that we would have spent on enforcement of the existing rules and regs is literally a drop in the bucket compared to the cumlative total losses in the general economy resulting from these unchecked-violations. The cost of this bailout and the losses from the insolvent lenders are just the tip of the iceberg.



AMEN..............



Just wait till the public and media as a whole catches on to this!
 
The money that we would have spent on enforcement of the existing rules and regs is literally a drop in the bucket compared to the cumlative total losses in the general economy resulting from these unchecked-violations. The cost of this bailout and the losses from the insolvent lenders are just the tip of the iceberg.

Absolutely, and the ones who allowed this to happen are either grossly inept or grossly corrupt and should be removed from their positions.
 
Licensing individual loan originators will work only to the extent that the rules are enforced.

Will not happen, because the process.., is flawed. Can't enforce a flawed process, no matter how much money is involved; counterproductive.

Sincerely,
 
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