Someone says Regulate the Lenders
-- H*ll there are already lots of regulations on Lenders, they skirt them,
ignore them, give them lip service, or obey them, depending on what they
can get away with.
Just because regulations have not been enforced in the past does not mean that new and better regulations cannot be drafted and actually enforced.
Someone else says Unfair: Competition from less competent newbies.
-- And when pray tell was it any different?
Right now Newbies at least have to go out and round up some clients, if they are able to do so, then that is fine, I have no problem with open competition....but why should they just be given something that they do not have to do any work to obtain?
Most everyone screams Who sets the Fees?! What will they be?
The only thing certain is they'll certainly be better than the AMCs are
paying, since this is set-up as a Co-Op, not a profit making enterprise.
Really? and how exactly do you know this? Maybe Fannie Mae and the lenders will tell the Co-op that the fee will be $200 period if you want us to use your system exclusively...who knows? Maybe the Co-op, having no profit motive, will be run very inefficiently and have to take a piece of the appriaiser's fee to stay afloat ( do you think that running this huge system which includes reviewing 10% of appraisals will be inexpensive?) Anyhow, that's not the point...I do not care what the AMC's pay, because I do not work for AMC's, I only care if the Co-op is willing to pay my going fee. It is simply un-American for an entity to be able to dictate fees for an entire industry.
Key to me is that this plan, as it's written, finally puts enforcement
in the hands of appraisers, and not in the hands of either the lackeys
of the Lenders, nor (finally) in the hands of State Boards which are
undermanned, underpaid, under trained, and underfunded for the job
they are supposed to do.
I say enforcement is in the hands of the appraisers, because if the IVPI
sends a complaint to the State Boards and they continue to take
2 years to investigate a complaint, and another year to set a date for a
hearing << typical for Pennsylvania, unless something changed >>
the IVPI would have enough political clout to scream to the individual
State, and to the GSEs and get something done about funding enforcement.
Is that right? What is the IVPI going to do about it when the PA state board essentially tells the IVPI to shove it? The IVPI is not an elected or political entity. What do you think will happen if the IVPI starts referring a large number of complaints to the state boards...my guess is that the state boards are evn going to get slower in resolving the complaints, since most of them cannot even handle the complaints they have now. Besides a slow resolution will not have any affect on the IVPI, because the IVPI is going to suspend the appraiser before the state board acts....thus, why would the IVPI even care? Additionally, who is to say that appraisers will do any better at enforcement than anyone else. Frankly, from some of the comments and ridiculous questions that I read on these boards everyday, I find it quite frightening that some of the people (but not all) on this board may have any say over enforcement.
"Quis custodiet ipsos custodes" --- "Who guards the guardians"
We need someone to look over the guards shoulders and see they
doing their jobs, and the IVPI is the one who will do that.
Your analogy here is incorrect in that under the proposal, the IVPI will acting as the guards and the question is who will be looking over the IVPI's shoulder?
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