Tuesday, October 19, 2010

Back to the future.

As we all know the HVCC has expired.  Some appraisers thought the good old days of working for mortgage brokers and loan originators would soon return.  That is not going to happen.  

The rules to protect appraiser independence are here to stay.  After the Dodd–Frank Wall Street Reform and Consumer Protection Act included the provisions of the HVCC, to no great surprise Fannie Mae has also implemented major portions of the HVCC in its policies.   On October 15, Fannie Mae released SEL-2010-14 which describes their appraiser independence policies.


In a nut shell Fannie Mae's policy is that:


1. All members of the lender's production staff;

2. Any person who is compensated on a commission basis upon the successful completion of a Mortgage; and

3. Any person whose immediate supervisor is not independent of the lender production staff and process.


 Are prohibited from:


1.  Selecting, retaining, recommending, or influencing the selection of any appraiser for a particular appraisal assignment or for inclusion on a list or panel of appraisers approved or forbidden to perform appraisals for the lender and

2. Having any substantive communications with an appraiser or appraisal management company relating to or having an impact on valuation, including ordering or managing an appraisal assignment.



For good or bad, the new appraisal business model of working for third parties such as AMCs or for bank appraisal departments is here to stay.