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Violations of HVCC

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avaziri

Freshman Member
Joined
Sep 11, 2008
Professional Status
Certified Residential Appraiser
State
Indiana
Can some one please let me know if an appraisal managment company reviews your apprasial and then suggest you review sales information in the area that they feel are better comparables?? Can I please get some feedback on this. Do they violate the HVCC

Home valuation code of conduct

#10 any other act or practice that impairs or attemps to impair an appraisers objectivity, or impartiality or violates law or regulation, including, but not limited to, Truth in lending Act and Regulation Z, or USPAP
 
Can some one please let me know if an appraisal managment company reviews your apprasial and then suggest you review sales information in the area that they feel are better comparables?? Can I please get some feedback on this. Do they violate the HVCC

Home valuation code of conduct

#10 any other act or practice that impairs or attemps to impair an appraisers objectivity, or impartiality or violates law or regulation, including, but not limited to, Truth in lending Act and Regulation Z, or USPAP

I doubt it. There is a provision for underwriters and review appraisers to comment on the report or consider other information.
 
Can some one please let me know if an appraisal managment company reviews your apprasial and then suggest you review sales information in the area that they feel are better comparables?? Can I please get some feedback on this. Do they violate the HVCC

Home valuation code of conduct

#10 any other act or practice that impairs or attemps to impair an appraisers objectivity, or impartiality or violates law or regulation, including, but not limited to, Truth in lending Act and Regulation Z, or USPAP

IMO, that isn't even close to a test case. They can ask you to consider evidence. You can decide how to respond. If they demand you give a certain amount of weight to particular comps in your SCA or reconciliation, then, IMO, that is an attempt to modify the appraiser's objectivity.
 
The conflict lies in the fact that certain large AMC's have a history of dropping appraisers who don't cooperate and use their comps, which clearly always point to a higher value. That is the violation of the HVCC, and the problem with AMC's controlling much of the work, with that much power over appraisers, how can appaisers stand up to value reconsiderations knowing they can get dropped in an instant, and since the AMC controls lending work, the appraiser can't then go to lenders directly for the work? This problem and others are being looked at.

There is a provision for underwriters and review appraisers to comment on the report or consider other information.

Imo, this is different than a review appraiser, or an underwriter looking at an appraisal and asking for more information. Review appraisers and underwritiers are not the client, in charge of ordering appraisals. Here, the CLIENT, with the power to give out or withdraw future work, is the one contacting the appraiser to look at other comps. ( higher value comps, who woulda thought)
 
I don't like the AMC model because it makes it easier to herd cats.

HVCC, as a policy statement, is OK. How it is to be implemented, may be highly problematic.

The largest influence appraisers can have in the process is a vote with their feet toward the models that offer the most compensation for the least amount of risk and the best feeling about one's work product.

Since there is a general over-supply problem with residential appraisers, I suggest the way to hold out for reasonable opportunities is to work as appraisers part time, if necessary to preserve one's personal standards. When market conditions permit, shift back to full time appraising, if that best suits you.
 
good advice, Mentor!
 
Very Good Advice....
 
HVCC is not in force yet. In fact, the new administration put it, and all other proposed new ideas such as this, on hold.
 
I don't like the AMC model because it makes it easier to herd cats.

HVCC, as a policy statement, is OK. How it is to be implemented, may be highly problematic.

The largest influence appraisers can have in the process is a vote with their feet toward the models that offer the most compensation for the least amount of risk and the best feeling about one's work product.

Since there is a general over-supply problem with residential appraisers, I suggest the way to hold out for reasonable opportunities is to work as appraisers part time, if necessary to preserve one's personal standards. When market conditions permit, shift back to full time appraising, if that best suits you.

Good advice on a personal level but sad that the better appraisers end up fading away and those that have no integrity get to stay "in".
 
Based on what seems to be coming
AMCs will drop non-compliant appraisers until no one but Skippy is left.
Then Skippies will be dropped when one by one they are not able to "make" $250,000 out of sales under $180,000.
Then the BPOs will be scrapped when they can't make $250,000 out of listings at $160,000
Lastly, the AVMs will be scrapped when they can't make $250,000 out of
no sales over $140,000 within 35 miles for last 5 years.
 
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