State level appraisal groups, including (unless I’m mistaken) the state of New York’s main appraisal organization, have written letters of protest and called for changes, a cancellation or review of the HVCC to no avail. They almost uniformly say the code will not accomplish it’s goals.

Cumo, the government, Fannie Mae – None of them will respond which appears to be an effective defense – Let your enemy die screaming while you quietly eat your dinner.

Resistance is futile… Consider the response from FHA to my original letter:
“The code focuses on appraiser independence and does not affect business or structure issues in the lending and appraisal industries”

Consider Fannie Mae’s legal defense that they are a GSE with immunity from any challenge in court because they are in receivership. Why didn’t they just use the “go away and leave us alone, we do what we want” defense?

What can we do against the interests that have enough power to have the HVCC re-written in the first place, removing the corporate independence clause against the interests of the consumer/appraiser/brokers?

92 – I will survive, thank you. It is a joke of a charge and my work speaks for itself, so I’m not worried. I am offended though, really, really offended…

Have a great weekend folks.

I have really enjoyed your insights!

No matter where someone comes from, it is easy to overlook the other perspective. It never occurred to me that anyone could go after an appraiser for a LOW value.

I’m sure you will survive, and hopefully prosper. While the world may not always appreciate and reward truth tellers, it certainly always needs them.

Hang in there!

This is a tragedy and I’m still very surprised at how many people are not aware of what’s going on and how much this will impact transactions.

Danger due to consolidated ordering point = bingo. There will be fraud on a National scale, it’s just a matter of time. That never would have been possible on such a massive scale until the HVCC came around. The AMCs have iron clad agreements releasing them for liability, and actually making appraisers responsible for “ANY” violations related to the appraisal, which might include an AMC violation of rules (see http://www.appraisalscoop.com). So now I’m going to be responsible for the AMCs mistakes/unethical actions related to my appraisal? That makes sense. They have zero liability locked into their contracts. They don’t even need E&O insurance!!!!

#87 – No offense taken, that is a compliment where I’m from. I’m not sure if appraisals will be high or low on average, I’m just saying they will not be as accurate and it is going to be a crap shoot. You are 100% right about the sole source for appraisals through a given lender. I know there are large lenders that will charge $400 for a review of a provided appraisal, so you basically just have to pay their AMC for a new appraisal because if the review comes back as a bad review, you are out $800 and still dont’ have a usable appraisal.

Anyone got a copy of the RICO statutes handy? RESPA?

Interesting situation today – I’ve seen some posts about appraisers being conservative because “no one is ever going to get in trouble for being conservative”. Let me tell you that being innacurate for any reason high or low can put you out of business in a hurry, which is why I try my best to be dead on every time. As of today I’ve been reported as targeting minorities due to a “low value” on an appraisal I provided to a local bank/borrower. Somehow the borrower has decided that one file represents a “pattern of targeting minorities” with lower appraised values. According to the borrower I’m colluding with the lender to redline multiple neighborhoods. Funny thing about that…I live in her neighborhood so why would I do that? Now I have to defend my appraisal (good thing is it rock solid) to multiple agencies this person sent her letter of accusations to.

All I’m saying is that we appraisers have to potentially defend every appraisal from accusations of being too high, too low, too lenient, too strict, etc, etc. That is why I’m dead on, straight line, best researched, best guess at the value every time. I don’t care if you need $5,000 more to make the loan work, or $5,000 less to make the divorce work in your favor, or whatever your situation is. I appraise to the best of my ability every day, because you never know when you will get challanged or why. The borrower that is coming after me was the sweetest old lady you ever met, and I took my time to provide her with a quality report, and now I”m getting attacked for it.

Thanks to Roger and Rhonda for the ongoing discussions.