Already Encountering Problems Caused by the HVCC?

NAMB wants to know!

NAMB has been requested by the Federal Housing Finance Agency (FHFA) to collect personal experiences from mortgage professionals or consumers of problems directly caused by lenders already implementing the HVCC. These problems can consist of increased costs, appraisal quality, portability issues, regulatory issues, etc. You must include specific, tangible evidence of how the HVCC has prevented you from conducting business.

Send an email, including your contact information, to hvcc@namb.org explaining the problem and it will be included in NAMB’s report to the FHFA.






Already Encountering Problems Caused by the HVCC? NAMB wants to know!



NAMB has been requested by the Federal Housing Finance Agency (FHFA) to collect personal experiences from mortgage professionals or consumers of problems directly caused by lenders already implementing the HVCC. These problems can consist of increased costs, appraisal quality, portability issues, regulatory issues, etc. You must include specific, tangible evidence of how the HVCC has prevented you from conducting business.



Send an email, including your contact information, to hvcc@namb.org explaining the problem and it will be included in NAMB’s report to the FHFA.









Dear NAMB Members:

Although the Home Valuation Code of Conduct (HVCC) goes into effect today, May 1, NAMB is continuing the fight! Unfortunately, on Wednesday, April 29, the House Financial Services Committee voted against attaching the Miller/Childers Amendment to H.R. 1728, “The Mortgage Reform and Anti-Predatory Lending Act of 2009” requesting a delay of the HVCC, by a margin of only 5 votes.

This does not mean the cause is lost! The fight continues!

H.R. 1728 is tentatively scheduled to be voted on by the entire House of Representatives on May 7, 2009. NAMB continues to work closely with members of Congress and is exploring all possible options resulting in the withdrawal the newly implemented rule. NAMB will update members on new developments as soon as possible. Please visit the new HVCC Resource Center for more information.

https://www.namb.org/namb/HVCC_Resource_Center.asp

I would like to report one persistant problem with HVCC--- Catherine Coy.

Smile a little, would ya?

I'll go for a roll any day--- better than nuthin'.

Catherine,

You have not demonstated any statistics on the negative impact that the "influence" has on the lending process.  You have not supported your argument at all.  Please refer me to a source that has actually done a statistical analysis of the problem you believe exists.  The analysis should determine if there is a statistical significance to the value associated with appraisals that were performed by appraisers who were "pressured".  It should then address any negative financial impact on the resulting transactions. 

Your claims stem from surveys that only determine if pressure was felt by appraisers (which is subjective) not any objective analysis that could validate your speculation. 

I think that what he may have been trying to say is that "the survey" does not qualify as "statistics".

Did I get that right, Kent? 

Adding my own two cents:  The information we've been able to glean from "the article" is anecdotal and subjective at best.  What's more, by the time the survey responses were gathered, manipulated and turned into a report, synthesized by a reporter and now cited by you, the "statistics" you speak of have become third or fourth-hand.

C'mon..... we all know that surveys like the one you seem to like to characterize as "statistics" can not only be engineered to support a given position, but also have their answers manipulated for the same purpose.  

Along different lines, there's a huge difference between asking an appraiser if he can validate a certain opinion ("the parties think the house is worth X, what do you think?" -- something Mr. Hummel characterizes as "dialing for value") on one hand, and a large lender (WAMU) telling its AMC (eAppraiseIT) to rewrite values on threat of losing hundreds of thousands of dollars worth of business (fraud).

If appraisers had to hit the number to stay in business, then get out.  Writing the report to keep people happy isnt a viable defense in any court I have ever heard of.  Appraisal fraud is perpetrated by appraisers, loan fraud by loan officers.  There will never be a truly perfect system for valuating real estate as long as it remains a subjective report.  A home is worth what someone is willing to pay for it, period.  In a refinance situation, a home is worth what a similar structure, of comparable size and amenities has sold for in the last 90-120 days.  Good appaisers take the time to look for the best comps, research court records for all sales, etc.  Bad appraisers take the first three that pop on their MLS search and you get what you get.  I dont want one of the bad appraisers doing my loan files and hanging my hat on their poor work ethic.  My livelihood depends on all components working well in order for me to be effective.  Pulling the cog out of the machine in this manner breaks down the process.  I have already lost clients to the lack of 2nd mortgage initiatives tied to all of the "help" for homeowners, MI co's are killing viable deals right and left, and now we are effectively locked with whatever lender we order the appraisal through.  It's not good business and there is no way of making the appraisal process completely objective so that every appraiser is going to bring in every house at the same value.  It will NEVER happen and having an appraiser do poor work and shorting a property is just as much a crime in my book as over valuation.  The old system was working until lenders stopped using qualified underwriters and solid standards on appraisals.  But the majority of this housing crisis lies at the doorstep of poor lending choices and bad programs with loose guidelines designed to churn a quick profit and then dump the model when it goes south. 

Yes Juan, you are right on. 

There is a difference between doing a survey and asking if someone has experienced "pressure" and determining if the pressure resulted in significantly higher values.  If there were statistically significant inflations to the value, we then need to determine if it had a significant detrimental impact on lending that was caused solely due to the inflated value.

Maybe the appraisers who felt they were pressured should be asked if they caved to the scary pressure of the mortgage boogy men.  If they say yes, take their license away and kick them out of the industry.  It's a shame that the government needs to pass laws to give an industry a back bone. 

Interesting that substance of the article (from 9 years ago) is addressed mostly towards the practices of lender-captive AMC's and that "mortgage brokers" are mentioned once --in passing.

It's as if the guy was saying "Sure, there's brokers who ask us to push numbers....... but hey, look at what these lender-owned AMC's are up to!!!!!"

Some interesting readings

Appraisers aren't happy either

http://www.beaumontenterprise.com/news/local/new_rule_could_affect_quality_of_appraisals__local_appraisers_say_05-05-2009.html

http://www.insidebayarea.com/business/ci_12265664

Same perspective but not from an appraiser

http://www.huliq.com/1/80461/hvcc-appraisal-regulations-bad-real-estate

Finally, good article with even better comments from various appraisers on both sides of the fence

http://www.boston.com/realestate/news/blogs/renow/2009/04/sam_schneiderma.html

Send an email, including your contact information, to hvcc@namb.org explaining the problem and it will be included in NAMB’s report to the FHFA.