HVCC WILL CAUSING AN APPRAISER SHORTGAGE
I am predicting an appraisal shortage shortly because of the new requirements to be a Certified Residential Appraiser, appraisal fees reductions for appraisers of 40% to 50% by AMCs and mainly the HVCC introduced by AG of NY, which has caused appraisal fees to be reduced because of a middleman the AMC and putting appraisers out of business.
The new requirements to be a Certified Residential Appraiser are 200 Hours of education covering 10 modules, including 15 hour National USPAP Course and an Associate Degree. In lieu of a Degree, 21 college credits (7 courses) in English Composition, Economics, Finance, Algebra or Geometry, Statistics, Intro to Computers, Business or Real Estate Law. A minimum 2,500 hours encompassing at least 30 months (2 ½ years) of acceptable experience as a trainee with a Certified Appraiser. Pay scale is usually 50% of the Certified Appraiser fee.
The HVCC Code’s main purpose is to protect appraisers and the quality of appraisals from undue influence and conflicts of interest. It is not doing that. It is putting appraisers out of business because of the creation of AMCs. Ask the majority of appraisers. The HVCC is enriching the AMC’s. They are unregulated, send appraisal orders to the lowest bidder ($200 –250), charge $400-500 for an appraisal adding extra cost to borrowers, cause more time to close loans because of the paperwork exchange, have little knowledge and understanding of business and do relatively little work for their fee. There has been a large increase in the number of AMCs during the past year.
I like many of appraisers and mortgage brokers are going out of business after many years in the business because of the deal AG Cuomo cut with FHFA/FANNIE/FREDDIE---the HVCC. The process for getting a mortgage was simple, straightforward and efficient prior to the HVCC. Previously the mortgage brokers collect data on the borrowers and ordered appraisals. They had access to many banks and would select the best for the client’s needs sometimes more than one. They could send the appraisal to different banks without additional cost to the borrower. When the data was sent to the banks, the banks’ underwriter and appraisal departments reviewed the data and the appraisals respectively. If there were any questions from the underwriters, they were answered swiftly, no third party (AMC) involved. If it passes, it was sent to FANNIE/FREDDIE who reviewed the appraisals prior to acceptance. The Banks and FANNIE/FREDDIE made the decisions on approving loans not the mortgage brokers and appraisers. They caused the meltdown. They failed because of greed as indicated in the news and the world knows, Unfortunately, the mortgages brokers and appraisers are paying for it. As requested by several organizations the NY AG and FHFA should implement a moratorium on the HVCC and have congress pass legislation.