Appraisal Scoop is seeking feedback from its readers to help inform the Attorney General, Fannie Mae, Freddie Mac, and OFHEO of issues and concerns arising from the Home Valuation Code of Conduct agreement.
Our readers, as the leaders in the appraisal profession, can and should play a critical role in identifying problems and defining potential solutions to improve the agreement. To accomplish this, we need your comments!
Your comments here will form the basis for a formal petition that will be presented to NY AG Andrew Cuomo, OFHEO, Fannie Mae and Freddie Mac.
The changes proposed by the OFHEO will require significant input, time and effort. The OFHEO announced on March 3rd, a 90-day comment period to gather feedback on the proposed Home Valuation Code of Conduct. This is our window of opportunity! We can help them help us by providing workable solutions for the challenges confronting the OFHEO and implementation of the HVCC.
This means any recommendations must consider the business needs of all participants, including lenders, appraisers, mortgage brokers, etc., to be effective. If we cannot agree on the best solutions or provide policies and procedures that will minimize the business impact of the HVCC, how can we expect the OFHEO to implement a policy that is workable for us?
Please take the time to read the Home Valuation Code of Conduct, consider the principles within it and provide your observations and suggestions for the best ways to put into practice the intents of the agreement. (click here)
This is not the time to criticize the HVCC; this is the time to make it effective and to do so we must have a shared vision of the future. We must consider the business needs of all associated with the appraisal process and work together to formulate practical solutions that will transition the process from where we are today, to where we need to be to meet the spirit of the HVCC, with limited disruption of the lending process.
Given the time constraints and vested interests within the current system, this is a tall order. That is not to say that it cannot be accomplished, only to point out the obvious.
So what are the next steps? Forums, blogs, and appraisal groups ara the logical place to begin. Take a leadership role and get the membership started in the feedback and comment process. You can direct them to this site where their comments will be collected and available for all to see.
The focus should be on the principles outlined in the HVCC, suggested procedures to make them effective and ideas on how to implement those procedures in ways that will minimize disruption of current FNMA and FHLMC business practices.
The goal is two-fold:
We simply cannot provide a list of problems without also providing a set of solutions that address those issues and concerns of their clients.
As of today, we have 90 days to make a difference.