- May 15, 2004
- Professional Status
- Certified Residential Appraiser
- New Mexico
TAF responds to the HVCC proposal.
In underwriting a loan, unless appropriate controls are in place to ensure appraiser
independence, the lender shall not utilize any appraisal report prepared by an appraiser employed
(1) the lender;
(2) an affiliate of the lender;
(3) an entity that is owned, in whole or in part, by the lender;
(4) an entity that owns, in whole or in part, the lender
(5) a real estate “settlement services” provider, as that term is defined in the Real Estate
Settlement Procedures Act, 12 U.S.C.§ 2601 et seq.;
(6) an entity that is owned, in whole or in part, by a “settlement services” provider.
and/or the lender.
5. Allow mortgage originators or borrowers to pick an appraiser from a list of previously approved appraisers, as the commercial banks currently do.
So, you support (B) 5 that allows mortgage originators to keep their "pet" appraisers?
It seems to me that this will defeat the purpose of the entire concept. Appraisers should be selected on a rotational basis from the National Registry. That way, everybody gets a fair shot. Fees should be national and published in order to defeat the "cheaper is better"
concept that now exists with AMCs.
Other than that, I think the Alabama revision is good. Did they send that to TAF?
Following is 10 pages of stuff our lawyers and the lending industry wrote.
Following is 10 pages of stuff our lawyers from the lending industry wrote.