TAVMA responds/condems HVCC again?

[Elliott]

Here's the FTC's opposition,

"For example, a potential competitive concern raised by Section III of the Code of
Conduct involves the apparent prohibition on mortgage brokers directly ordering appraisal
reports. To the extent that such brokers rely on the ability directly to order an appraisal and then
shop around a complete loan package (including the appraisal) to multiple lenders, the Code of
Conduct would appear significantly to hamper the ability of mortgage brokers to compete in the
lending market. Even if the Code of Conduct could be interpreted as merely requiring a lender
to obtain another appraisal in addition to the broker-ordered appraisal, the cost of dual appraisals​

will raise the cost of such loans for consumers. If implementation of the Code of Conduct

results in it being more difficult or expensive to use mortgage brokers than lenders to obtain a
mortgage, then consumers may lose some of the benefits brokers may provide as a significant
mortgage distribution channel. The FTC staff thus recommends that Freddie Mac and the other
parties to the settlement agreements fully consider the potential impact on the lending market​

and, ultimately, consumers of the prohibition on mortgage brokers directly ordering appraisals.

 

[Elliott]

And who knew Home Builders cared so much,

NAHB is specifically concerned about the provision in Section V of the Code that would prohibit appraisers who are employed by lenders from conducting appraisals on behalf of those lenders, particularly if these lenders are overseen by federal financial institution regulatory agencies. This provision of the Code appears to be unnecessarily restrictive, particularly since no reports are available that demonstrate problems with appraisals that have been conducted by appraisers who are employed by these lenders.

(who forgot to write that report about CW appraisers?)

 

[Mike Kennedy]

Ever get the feeling there are a lot of associations who like appraiser's who
are in oversupply and hit numbers. Here are the associations in opposition
to HVCC:



American Bankers Association
American Financial Services Association
Appraisal Institute
American Land Title Association
American Society of Appraisers
American Society of Farm Managers and Rural Appraisers
Consumer Bankers Association
Consumer Bankers Association (Joint Trades)
Consumer Mortgage Coalition
Consumer Mortgage Coalition (Joint Trades)
Federal Reserve Board (Joint Regulators Letter)
Federal Trade Commission
Housing Policy Council, The Financial Services Roundtable
Independent Community Bankers Association
Independent Community Bankers Association (Joint Trades)
Mortgage Bankers Association
Mortgage Bankers Association (Joint Trades)
National Association of Home Builders
National Association of Independent Fee Appraisers
National Association of Realtors
National Credit Union Administration (Joint Regulators Letter)
Office of the Comptroller of the Currency (Joint Regulators Letter)
Office of Thrift Supervision
Office of Thrift Supervision (Joint Regulators Letter)
Real Estate Services Providers Council
The Appraisal Foundation Title Appraisal Vendor Management Association

MANY of whom conveniently >>>>>>>>>>>>> STILL

 

[Elliott]

Mike,
A little agreement with Fannie/Freddie/Othelo and man, nobody is going
to let it see the light of day. I've come to the conclusion, we're just
chair makers, everybody else wants to tell us how we should make the
chairs because they have plans for our chairs and we shouldn't get
uppity because they are much more important than us and spend lots more
dollars on lots of lobbyist and congressmen. Its sad, really sad. Its
eventually going to f-up our housing and mortgage markets and
they only care about themselves.