Independent Appraisers GSE/Cuomo Proposal 3/19/08

[Marcia Langley]

It's a great proposal. I'm endorsing it.

I'm blown away by the depth and breadth of the proposals. It's a huge undertaking.

terry & Ion,

Send it to all the links in mike's post where you found the link to the proposal.

 

[Shelley4146]

All signed and read to go...just waiting to see where to send it!!

 

[Smokey Bear]

The appraisers who contributed, were they approached, or did they volunteer.

Yes. <extra characters to meet minimum>

 

[KYLECODY]

Thank you Pam and all others involved for your GREAT work!!

 

[Alison Swain]

....the end might be near, but before I contrary any efforts, intentions or work of those who are attempting to help us "row to a better shore", I should expended more effort than passing the wind of comment without being more justifiablely deserving by thought and active participation....best to all.......rs

Say what???? :Eyecrazy:



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[PropertyEconomics]

....the end might be near, but before I contrary any efforts, intentions or work of those who are attempting to help us "row to a better shore", I should expended more effort than passing the wind of comment without being more justifiablely deserving by thought and active participation....best to all.......rs

It took me a few times reading .. but ......

 

[Bill_FL]

I have only made it through page 10, but there are a few things I would like to have some clarification on:

First, on page 2, the word creditable is used. Is that the right word? Should it be credible?

Second, on Page 9 - Requires every appraisal to be an interior inspection. Now lets stop and think about this. There were no caveats for land; how about when you do a huge apartment complex? You think you are going to get into all 1000 units? How about a pre-foreclosure drive by? I do them often. Hostile owners, etc. Please, when you guys are crafting these rules, do not keep your single-family-purchase-loan blinders on. When you use the term "appraisal" and "regulations" you are starting to cover a heck of a lot more than just a purchase loan.

Third, on Page 10 - Automatic forensic review when a loan goes into default. Shouldn't you not spend other people's money until you know a little more? Why not wait for the foreclosure appraisal to find out if there is an issue? Someone gets laid off, house goes into default and an automatic forensic review needs to be done?

Overall, its pretty good, for single family purchase lending, proposal. But I think in the heat of the moment when it was written, a way, way too narrow a point of view was being looked at.

 

[LA Woman]

Pam, et.al.

I had no idea that the task you had taken on was this monumental and I am completely humbled by your foresight and intelligence.

Thank you to all concerned for your time, efforts and sacrifices.

Does anyone now doubt that Pam needs our financial support? And, that it is in our own best interest to help support her?

 

[George W Dodd]

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[PropertyEconomics]

P.E.

What we propose is a tiered system. The Reviewer thinks there is a problem with the appraisal. The report is then sent for a field review by another IVPI Review Appraiser (either staff of panel member). The results of the field review are then given to a Senior IVPI Reviewer. And based on the results of the field review, they have the option of dismissing the complaint (with reasons), issuing a warning, or sending it to a formal hearing committee. When we use the term "due process" it is to infer that the Panel Member has the right to fairly represent themselves and that everything is done in a fair and open manner. Perhaps "due process" is not the best terminology.
The process must be fair and open. IVPI can only suspend active status pending State Appraisal Board Action. IVPI is bound by the decision of the State: if they say no violation than that's the result and the Panel Member is reinstated to active status. If the State says take a 40 hour course, etc. then when those things are completed the Panel Member is back on active status.
IVPI is not going to be the judge and jury. Period. It will work with State Appraisal Boards and leave it up to them to make the final decision. That's the way is should be IMO.

Thank you Mr Dodd .. your comments here should have been in the document. It seems to me only the states have the power discussed in the proposal .. yet they are never mentioned. I am glad you see this issue as being one for the states to handle as needed.
This is just one reason comment should have occurred prior to delivery.