November 23, 2017

Seattle Real Estate Owners Stop HVCC Now!

Call to Action!

Its impact on Consumers:
A.    The HVCC negatively affects consumers by increasing the costs to consumers for an appraisal, reducing consumer choice and adversely impacting a consumer’s ability to obtain a reliable and quality appraisal.
B.    The HVCC creates a heightened risk for consumers by requiring the use of unregulated Appraisal Management Companies (AMCs) for appraisals. The original investigation that prompted the HVCC’s creation was of an AMC and WAMU alleging that they engaged in practices of pressuring appraisers on behalf of WAMU.
C.    It increases the time to fund loans for consumers which necessitates longer rate locks or extensions of existing locks thereby increasing costs to consumers. In the case that a new lender or broker is chosen, a new appraisal will be necessitated, increasing the time to fund.
D.    It restricts the portability of an appraisal since each lender, in effect, will require a new appraisal.


Its impact on Small Business:
E.    The HVCC squeezes out small business professionals that are striving to survive and have been working with consumers in the very neighborhoods where they are looking to purchase homes.
F.    The HVCC affects small business appraisers, mortgage brokers, Realtors and lenders in all 50 states without having been reviewed by ANY state or federal legislature or agency.
G.    Small business professionals who have indepth knowledge of local market conditions are being sacrificed for large AMCs who operate on a national scale to distribute orders through a primary processing hub or hubs which can be located up to thousands of miles away from the property being appraised.


Its failure to comply with procedural law:
H.    Although the HVCC is broad regulation having a significant impact on small businesses and consumers, it did not go through the Administrative Procedures Act, the Regulatory Flexibility Act or other procedural laws as required by any regulation issued by a federal agency.
I.    FHFA claims that as Conservator of the GSEs, its actions are not “agency actions” under the APA and that its actions are “expressly precluded from judicial review” as a result of the Housing and Economic Recovery Act.

Appraisal standards exist:
J.    The Federal Reserve issued appraisal independence standards through Regulation Z being implemented this October which applies to every industry participant.
K.    The banking regulators issued interagency guidance on appraisal standards which are expected to become final this year.





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  1. Great job publicizing this, all real estate professionals should get on board. HVCC is killing the housing recovery.

    Sam DeBord
    RE/MAX Seattle Real Estate Broker

  2. sfujita says:


    Thanks for the post! Yes HVCC continues to stall the real estate recovery. Hopefully more and more people will jump on board and sign the petition, we need all the support possible.


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