ICBA Comment Letter on HVCC

[panappr]

I find that most all of the reactions coming from the Associations and States at this point have been negative in response to the HVCC, not limited to being overly burdensome and redundant to State and Federal laws already in existence. I believe I read that smaller (ICBA) Community Banks were supposed to be exempt from having to comply with the HVCC. Nonetheless, since most all the authorities have negative issues with the policy where does it stand? Are they re-writing a new HVCC? Amending the existing policy? Are there meetings with TAF and FNMA? Is the ASC back from vacation yet? Who will be deciding the future FNMA? I do assume that Mario Coumo and staff are busy handling phone calls defending the policy as it stands (the barrel of snakes), but who is reviewing all the comments and proposals and who will ultimately make a final decision on the policy?

Actually, I'm just curious if anyone has heard anything.



http://appraisalnewsonline.typepad.com/appraisal_news_for_real_e/files/ICBA_HVCC_Response.pdf

 

[Workbox]

Actually, I wonder if this gives the real culprits time to fill their coffers.

 

[Mike Kennedy]

"In our view, the reporting of quality control testing of appraisal reports (Section VII) to the Independent Valuation Protection Institute unnecessarily creates an additional oversight organization for institutions that already are subject to regulation and close supervision and examination by state and/or federal banking regulators. We do not see a need for the creation of an additional layer of regulator oversight. "

If the existing Regulation and "close supervision" was working........ there would have been NO GSE agreement.

"do not see" .................. = preserve the Status Quo - at all costs.

 

[Ross (CO)]

"I find that most all of the reactions coming from the Associations and States at this point have been negative in response to the HVCC,"..........

- - - - - -

and, probably so, due to the fact that a dominant theme driving this entire string of events is the fact that appraiser independance with no implied biases and coercion from clients is what is being requested ! They, and you know who I mean, do not want to give and grant the appraisers that element of independance. Add an accompanying expectation that appraisers want an appropriate amount of time to properly complete an assignment and a fair and reasonable fee to compensate that effort so as to assure that the best data is utilized and that such is verified during report development.

If bias, coercion, influence are to be driven by haste and half-baked value conclusions.....then the proliferation of AVMs, BPOs and the Zillow factor will surely carry forth as future investors in mortgage portfolios buy their product from the marketplace.

There still has not been enough blood in the streets to really carry the on-going process to a clearer re-organization and placement upon a new track. There are still seven and a half months of 2008 to go. The puzzle pieces are so numerous. Decisions by persons of higher authority and power are yet to be made. Those folks have yet to say how they want things to be......and appraisers await comment on just how much independance they will be granted.

No, I don't do comp checks.

 

[Tudor]

"I find that most all of the reactions coming from the Associations and States at this point have been negative in response to the HVCC,"..........

- - - - - -

and, probably so, due to the fact that a dominant theme driving this entire string of events is the fact that appraiser independance with no implied biases and coercion from clients is what is being requested ! They, and you know who I mean, do not want to give and grant the appraisers that element of independance. Add an accompanying expectation that appraisers want an appropriate amount of time to properly complete an assignment and a fair and reasonable fee to compensate that effort so as to assure that the best data is utilized and that such is verified during report development.

If bias, coercion, influence are to be driven by haste and half-baked value conclusions.....then the proliferation of AVMs, BPOs and the Zillow factor will surely carry forth as future investors in mortgage portfolios buy their product from the marketplace.

There still has not been enough blood in the streets to really carry the on-going process to a clearer re-organization and placement upon a new track. There are still seven and a half months of 2008 to go. The puzzle pieces are so numerous. Decisions by persons of higher authority and power are yet to be made. Those folks have yet to say how they want things to be......and appraisers await comment on just how much independance they will be granted.

No, I don't do comp checks.

my bold

And you will be rewarded with no work because of that. m2:

Ross,

I agree, they don't want the strings cut, they like being the puppet masters.

 

[Mike Garrett RAA]

I don't do free comp checks.