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NAR Calls on Its State Presidents to Support HVCC Moratorium

On July 27, 2009, NAR held a Webinar with State REALTORS Association Executives and Government Affairs Directors to discuss steps states may take to address concerns with the Home Valuation Code of Conduct (HVCC). In the Webinar, state presidents were asked to contact their respective Attorney General’s (AG) office asking that the National Association of Attorneys General (NAAG) support a moratorium on HVCC. State presidents were also asked to write their real estate commission to call on the House Financial Services Committee Chair, Barney Frank, to hold hearings on the Home Valuation Code of Conduct and its impact on the real estate industry.

NAR has been very active in calling for a moratorium on HVCC. In June, NAR reiterated calls for a moratorium on HVCC in a letter to New York Attorney General Cuomo and Federal Housing Finance Agency (FHFA) Director James Lockhart. NAR President Charles McMillan followed up the letter in meetings with the New York Attorney General’s office, FHFA Director Lockhart, and Fannie Mae earlier this month. We also support HR 3044, which calls for an 18-month moratorium on HVCC.

Comments
  1. Please contact your representatives in congress and urge them to co sponsor HR 3044. An 18 month moratorium of the HVCC. The HVCC needs to be rewritten to fix its inherent flaws that are affecting consumers and the economy.
    HVCC has caused havoc for homebuyers and homeowners. It is anticompetitive legislation that sets precedent for more anticompetitive legislation in the future.

  2. Joey Marmo

    We need to speed up this moriatoriam. Buyers, Sellers, Lenders, and Realtors are paying the price everyday. We need implementation of the moriatorium or the complete elimination of this disaster called HVCC. People can’t feed their families!

  3. ANTHONY IORII

    I would like to now when the moratorium will start. I am staving without appraisal work

  4. HVCC is not all bad, as a lot of appraisers were trained wrong to shoot at target values, so not having an est of value for refi’s is good, the major problem is it is putting loan brokers out of business as there is an unfair playing field with banks and direct lenders, not all mgt brokers were bad. Why is the appraisal industry the only one where a product user sets what they are going to pay? to go back to $200 to $250 an appraisal is less than what normal was almost 20 years ago. AMC’s need to be regulated as they are doing the same thing pressuring appraiser’s black list them, and they have much more clout, in the past one broker could never pressure an appraiser, but an AMC that has many many lenders can presurre and do as there are not regs in place, look who runs the AMC’s former sub prime lenders and people who lost their appraisal license. why should we take a 1/2 pay cut, as it is UW’s scrutiny and request for more info has already aded 25% more time into each report. AMC’s also pressure to super fast turn time and go to areas they do not know, they also then cut corners, the biggest one being not driving the comps and taking photo’s from the MLS, so quality has gone down, pay has gone down, who is going to want to be an appraiser? this is the 1st step of banks wanting to get into real estate, they get rid of the brokers, the consumer gets higher costs, the appraiser’s are dumbed down to being just a job and then they will go for selling real estate. How can 1 AG in NY rule the whole country in one swoop that was never under any kind of legislative process not that anyone in DC reas bills anyway. This is terrible and was not the intended outcome but reality is what it is, if there needs to be a middle man, let their fee be tacked onto the normal fee for an appraisal, I am looking at dropping my health ins so I can keep my house and be able to eat. this is not right.

  5. Donald

    I have been a certified appraiser in Massachusetts for almost 20 years. With the failure of the mortgage industry, all you hear about are the overinflated appraised values as the culprit. Nonsense! And who determines the appraisals to be overinflated? A disinterested party or the mortgage lenders themselves? While of course, the are a number of weak or otherwise dishonest appraisers in the industry who played a role, the vast majority of appraisers would not risk their livelihood for an appraisal fee and a veiled threat of no more orders. By and large, the major lenders had the motivation to knowingly wrote bad loans in the sub prime mortgage market and competed with each other to get them. They made billions! The loans that they wrote were misleading at the point of origination and consumers were hoodwinked into signing up for loans with no warning of how much their monthly payment would increase when the rates went up. They never would have written a loan if they had. They also never had to inspect a home where a family was preparing to leave due to foreclosure. They were in the safe confines of their office in front of a computer.
    The HVCC was created by the New York Attoney General’s office as a plea deal for Washington Mutual and Appraise IT to avoid prosecution for mortgage fraud. Thosands of people lost their homes. Why would they not prosecute? This is an example of big money and a strong lobby in action. Pretty gutless! This ill conceived policy now puts more control in the hands of the people who ultimatley caused the mortgage meltdown and dessimated the economy overall. The use of AMCs’ where a lender has an ownership interest of an unregulated “middle man” is a glaring conflict of interest at best. The cost of AMCs’ is passed on to the appaisal industry through substantially reduced fees to the appraiser and higher, undisclosed costs to the consumer. No contribution from the lenders that we bailed out. That money must go to the best and the brightest in the form of corporate bonuses. How bright did you have to be to not see this disaster comming? The truth is, the didn’t care. They made billions! This arrogant, “because I can” attitude still exists among lenders. The New York Attorney General has shown a lack of character and leadership on this issue. Get back to work on this New York and get it right! You are supposed to be the New York Attorney General’s office, not the New York Yankees.

  6. Regardless of what the National Association of Mortgage Brokers would have everyone believe, the HVCC is not the causing lower home values!
    Mortgage Brokers and their AMCs using incompetant appraisers working for below average fees, and using out of town appraisers incompetant in the subject market area is the real problem.
    In many cases, there may actually be a real loss of market value but this was not the fault of HVCC but the economy in general.
    Lower tax values are not caused by HVCC either. In most communities an appraisal does not affect the property tax value unless a borrower orders one to support their claim of a faulty tax valuation or to challenge tax valuations that were done at the height of the bubble.
    The real crux of the problem is Mortgage brokers working for companies that require the use of certain AMCs who only use appraisers that will work for the low fees they offer with no regard to professional competency.
    This is the issue that should concern everyone. It is essentially the same problem that inflated values inappropriately to begin with.
    The HVCC does not require the use of AMCs, just a process whereby the appraiser is insulated from the mortgage broker. Any mortgage office can buy a simple computer program that can be used by a staff person, like an office secretary, to process appraisal orders. Many lenders do this and don’t use AMCs.
    Don’t blame the HVCC. The HVCC is helping appraisers keep Lenders from subjugating their professionalism and the appraisal process. Many appraisers have already used it to hold unknowledgeable and unscrupulous lenders accountable.
    Any issue of low property values should be carefully investigated from the perspective of whether the appraiser was professionally and market area competant to do the appraisal. If it is found that they weren’t and that the values are faulty, the the Mortgage Brokers and the AMCs should be held accountable for not using competant appraisers.

  7. John

    hvccjustice@hotmail.com
    Re: I propose a class action lawsuit to be filed against Fannie Mae and Freddie Mac, the New York AG’s office and perhaps the entire State of New York
    I’ve been in business over 13 yrs as a real estate appraiser. Over the years, I have employed many doing often 200+ appraisals a month with a select group of certified appraisers. With the recession, I was forced to downsize my office and work from home as my volume dropped to 70+/- per month. The overhead was eating me alive. It was unfortunate, but the fact is, the workload wasn’t sufficient for almost a full year prior to my decision. What used to be a bustling professional office complex was now ¾ vacant, as title companies, realty offices, etc left in droves. The writing was on the wall. I either had to make such drastic change or eventually go under.
    Divesting myself of the office expense, I began to thrive once again in November 2008. With a volume of 70+/- reports per month, I had more than enough work for just one appraiser and I began to fee work to appraiser friends that were deserving of some assistance. And than, all hell broke loose.
    The first week of HVCC, I received in only 1 appraisal order. I was alarmed since prior to May 1st, I averaged 15-20 orders a week from a variety of different sources. By the end of May 2009, the total work volume I received was less than 1/4th the monthly volume I was used to handling. In desperation, I signed up with several AMCs and I found that in order to be “competitive” I had to accept a drastically reduced fee. My world was rocked. I turn 40 next year and I’ve spent most of my working career in this industry building a good name for myself locally. Suddenly I was just as employable as the new scrub fresh out of appraisal training school.
    I decided after a couple of months to wake up and to stop selling myself and fellow appraisers so cheaply. During a routine AMC appraisal inspection, the homeowner was angry with me over the fee she was charged by her lender for the appraisal report. She is a senior citizen and a real estate broker so she demanded to know why she was being charged $575 for her appraisal. I was almost speechless when I realized the amount of money this title company owned AMC, with the initials S.L., was actually charging for the appraisal. The homeowner softened considerably when she finally believed me that I was only getting paid $200. What it took to convince her was when I threw cares to the wind and showed her the fee I was to be paid which posted on the order form.
    I’m not proud that I sold my services so cheaply. I have decided to stop accepting the scraps and try to re-invent myself in attracting other types of appraisal work, where I might be able to regain some form of control over my business once again.
    I feel angry that I have to do this in the first place. The fact is, I had previously built for myself over a decade of dedicated service a clientele base that most appraisers would die for. My main clients were mortgage brokers that handled “A” paper borrowers of high net worth with excellent fico scores. My clients have never had any loans go bad or have had any cause to doubt my integrity or value conclusions. If presented with a “low” appraisal that would preclude them from making a loan, they would handle their client appropriately and move on to the next transaction, because they were professional brokers and loan officers that didn’t financially survive from one “deal to the next.” Ironically, some of my appraiser buddies that had financially weaker, FHA driven clients were not hit quite as hard as I was since HUD still allows brokers to order their own appraisals—-.
    Another major impact HVCC has had on me is in the management of funds and the increase in cost to do business. Prior to the HVCC, 90% of all my business was paid by credit card before I even left my door. Now, from what the experts are telling me, doing so may alter my value conclusion in some way or another. It stands to reason for me that, considering my work was “pre-paid”, the argument that my value conclusion may be skewed over monetary reasons doesn’t make much sense. I would imagine an appraiser may be more intimidated and susceptible to stray ethically if he was worried he might not get paid if he didn’t make his client “happy” value wise.
    Interrupting the cash flow in any business can lead to a painful death. The impact that my work is not “prepaid” means I get to wait 45 to 60 days to get paid even though AMCs have already been prepaid for the appraisal. To add insult to injury, now I get to track down monies owed to me. If it weren’t for my wife assisting me, I’d have to hire a secretary just to invoice and chase down money that’s owed. Ironically, although I have much less work orders than before, it seems it’s taking much longer to complete an APPRAISAL ASSIGNMENT, GIVEN ALL THE EXTRA HVCC DATA THAT GOES INTO AN ASSIGNMENT. IN THE PAST I COULD WRITE AN APPRAISAL, POST INSPECTION IN AN HOUR OR TWO. NOW THE TIME TO GET ONE WRITTEN, WITH ADDITIONAL AND ULTIMATELY MEANINGLESS EXTRA PAPERWORK, IT TAKES A GOOD 4+HRS TO WRITE UP A REPORT.
    I WOULD LIKE TO KNOW WHO HAS GIVEN THE ATTORNEY GENERAL OF NY SO MUCH POWER TO DESTROY AN ENTIRE INDUSTRY? FURTHERMORE, THE SAME OLD LENDER SHENANIGANS OF FORCING VALUE OPINIONS AND PRESSURING APPRAISERS IS STILL HAPPENING.
    I HAVE ALREADY BEEN COERCED BY A MAJOR TITLE COMPANY OWNED AMC WITH THE INITIALS S.L. SEVERAL TIMES ON MY VALUE CONCLUSIONS. THEY WON’T COME RIGHT OUT AND SAY IT, BUT IT’S OBVIOUS THEY ARE GETTING HEAT FROM THEIR CLIENTS/BORROWERS/ OR BOTH WHEN THEY FEEL MY VALUE OPINION IS “TOO LOW.”
    IN THE PAST IF A BROKER HAD A VALUE CONCERN ON ONE OF MY ASSIGNMENTS I COULD GET ON THE PHONE AND EXPLAIN MYSELF AND THE STEPS TAKEN IN THE APPRAISAL PROCESS IN DETAIL. FACT OF THE MATTER IS, WITH MY CLIENTS I DIDN’T EVEN HAVE TO EXPLAIN MYSELF. AFTER YEARS OF WORKING WITH ME, THEY HAVE GAINED A TRUST IN MY WORD, AND WOULD RARELY EVER ASK ME TO DOUBLE CHECK MY WORK. THANKS TO YOU, MR. CUOMO, NOW I GET TO TAKE A FEW EXTRA HOURS TO DEFEND MY WORK TO A CORPORATE GIANT THAT WONDERS WHY I’M STICKING WITH THE MODEL MATCH SALES IN THE AREA INSTEAD OF GOING OUT OVER A MILE FOR LESS SIMILAR COMPS THAT CAN ONLY PUSH AN ADJUSTED VALUE SKY HIGH. THIS HAS HAPPENED TO ME ON 3 OCCASIONS NOW AND FOR THE RECORD, IT WAS NEVER HANDLED QUICKLY AND quietly. I was made to feel like the bad guy, with one of the appraisals being kicked back to me 4 times because the homeowner thought her condo was so much better than the 15 other sales in her project. On another file, the homeowner was given enough of my information to be able to track me down and make demands that I consider a higher value on a home he was buying. By the end of the call, the borrower was grateful that I didn’t compromise my values and I gave him/lender a solid valuation.
    So here is my dilemma. I love my profession and I am good at it. I am turning 40 next year and I am faced with having to leave my industry if I can’t think of something fast. Problem is, what else shall I do? I have built a family, lifestyle and a home based around my profession and now I stand to loose the stability I have created for my family. I am angry that some clown forced such industry wide changes upon my profession without even the foresight to consider how this may impact the men and women HVCC claims to protect.
    No one has ever attempted to make HVCC a win-win for all parties involved. What a cluster it was the first day, let alone month, that the HVCC was implemented. Most lenders had no clue how an appraisal was to be ordered to remain “compliant”. What’s more, appraisals were supposed to be “portable” from one lender to the next, and, although the code implies that there will be flexibility between lenders, there is nothing that requires banks to use transferred appraisals. Apparently, nobody actually considered the level of greed that the banks, which now own there own AMCs, would actually resort to, as they now charge the consumers much higher appraisal fees than before and actually pay the appraisers much less for their service. The fox has been let into the hen house for certain.
    This dilemma I am faced with is not a function of a bad market or that my industry has gone offshore to be produced more efficiently. This is a result of an extremely bad and perhaps criminal idea on the part of New York’s Attorney General and the corrupt GSE’s.
    I can’t imagine anything like the HVCC happening to any other profession in existence. What would lawyers, doctors, real estate agents or accountants do if somebody said to them, “We see a “problem” and we plan to HELP you. We are going to take your clients from you that you have cultivated through the years and we’re going to divide them up amongst those possibly less skilled than you. However, before we do that, we are going to charge the consumers of your trade more money than they’ve ever paid before and we’re going to skim 40% to 60% off the top and make you wait to be paid. Incidentally, we’re going to tell you how and when you’ll get paid, if ever. This we are going to do because we are here to keep you feeling safe and compliant.”
    As I sit here figuring out how I get to pay my bills next month, I’m stuffing this sickening feeling I’ve got in my gut that the mafia (AMCs) have muscled into a time-honored profession and now appraisers all get to pay “protection money.” AMCs have descended like vultures on a rotting corpse.
    I calculate that I have lost over $15,000 a month in gross business since the HVCC fiasco began with no measurable benefit to the consumer. I know of many other appraisers and now real estate agents that have lost a great deal of money over this garbage that’s been thrust upon us. Furthermore, the public at large is paying more than ever before.
    I’ve written the media, local congressman and the AZ board of Appraisals to voice my concerns. I contacted an attorney (spent over $8,000 in legal fees) just to find that it would cost me well over $100,000 to initiate a law suit against those that forced the HVCC upon us. Unfortunately, I can not financially afford to fight this battle alone.
    Do we not all have legal grounds to fall back on? Who has given these corrupt purveyors of their own agenda the right to take food off my table and yours? I may well stand to lose not just the table, but the home that surrounds it. I know some very good appraisers that have now already lost their homes over this ordeal. As I said before, what other industry would allow this sham in the first place?
    I am not content to hear that there is a bill proposing a “Moratorium” to the HVCC on Capitol Hill which isn’t even a law in the first place. I’d love for a Congressman to call for an investigation as to how this travesty has befallen the entire real estate industry promulgated by the NYAG’s office and the GSE’s seeking a legal get-out-of –jail free card.
    If appraisers were united, and we all decided to stop doing appraisals for a few days or perhaps even a week, the entire industry would come to a screeching halt. Suddenly we appraisers that are typically the most trained, educated, liable and LEAST PAID entity in a real estate transaction, would garner some measure of respect for ourselves as well as for our industry.
    And speaking of respect, every appraiser knows that the average homeowner will be somewhat put out to schedule even a 1 to 2 hour window of time for our much needed services. On the other hand, people will wait all day and into the night for the cable guy to show up at their door.
    I demand that reparations should be paid by those who should be held liable for their actions. I propose a class action lawsuit to be filed against Fannie Mae and Freddie Mac, the New York AG’s office, and perhaps the entire State of New York demanding an immediate cease and desist to the HVCC and that damages be paid for having either intentionally or unintentionally harming an entire industry without having done your due diligence to determine the impact of your actions upon the Nation.
    Mr. Cuomo, you are a lawyer. You know that ignorance is never a good form of self defense. People have been harmed by your carelessness and apparent inability to own up to your bill of goods you have thrust upon us. We are still being harmed and we are ready to fight you tooth and nail so prepare yourself!
    If you are sick of this and you would join me in fighting back the wolves that are at the door than email me and share your experience of the HVCC so far and lets take back control of our industry.
    You may contact me at:
    hvccjustice@hotmail.com
    Sincerely,
    ~The Appraisinator

  8. John

    hvccjustice@hotmail.com
    Re: I propose a class action lawsuit to be filed against Fannie Mae and Freddie Mac, the New York AG’s office and perhaps the entire State of New York
    I’ve been in business over 13 yrs as a real estate appraiser. Over the years, I have employed many doing often 200+ appraisals a month with a select group of certified appraisers. With the recession, I was forced to downsize my office and work from home as my volume dropped to 70+/- per month. The overhead was eating me alive. It was unfortunate, but the fact is, the workload wasn’t sufficient for almost a full year prior to my decision. What used to be a bustling professional office complex was now ¾ vacant, as title companies, realty offices, etc left in droves. The writing was on the wall. I either had to make such drastic change or eventually go under.
    Divesting myself of the office expense, I began to thrive once again in November 2008. With a volume of 70+/- reports per month, I had more than enough work for just one appraiser and I began to fee work to appraiser friends that were deserving of some assistance. And than, all hell broke loose.
    The first week of HVCC, I received in only 1 appraisal order. I was alarmed since prior to May 1st, I averaged 15-20 orders a week from a variety of different sources. By the end of May 2009, the total work volume I received was less than 1/4th the monthly volume I was used to handling. In desperation, I signed up with several AMCs and I found that in order to be “competitive” I had to accept a drastically reduced fee. My world was rocked. I turn 40 next year and I’ve spent most of my working career in this industry building a good name for myself locally. Suddenly I was just as employable as the new scrub fresh out of appraisal training school.
    I decided after a couple of months to wake up and to stop selling myself and fellow appraisers so cheaply. During a routine AMC appraisal inspection, the homeowner was angry with me over the fee she was charged by her lender for the appraisal report. She is a senior citizen and a real estate broker so she demanded to know why she was being charged $575 for her appraisal. I was almost speechless when I realized the amount of money this title company owned AMC, with the initials S.L., was actually charging for the appraisal. The homeowner softened considerably when she finally believed me that I was only getting paid $200. What it took to convince her was when I threw cares to the wind and showed her the fee I was to be paid which posted on the order form.
    I’m not proud that I sold my services so cheaply. I have decided to stop accepting the scraps and try to re-invent myself in attracting other types of appraisal work, where I might be able to regain some form of control over my business once again.
    I feel angry that I have to do this in the first place. The fact is, I had previously built for myself over a decade of dedicated service a clientele base that most appraisers would die for. My main clients were mortgage brokers that handled “A” paper borrowers of high net worth with excellent fico scores. My clients have never had any loans go bad or have had any cause to doubt my integrity or value conclusions. If presented with a “low” appraisal that would preclude them from making a loan, they would handle their client appropriately and move on to the next transaction, because they were professional brokers and loan officers that didn’t financially survive from one “deal to the next.” Ironically, some of my appraiser buddies that had financially weaker, FHA driven clients were not hit quite as hard as I was since HUD still allows brokers to order their own appraisals—-.
    Another major impact HVCC has had on me is in the management of funds and the increase in cost to do business. Prior to the HVCC, 90% of all my business was paid by credit card before I even left my door. Now, from what the experts are telling me, doing so may alter my value conclusion in some way or another. It stands to reason for me that, considering my work was “pre-paid”, the argument that my value conclusion may be skewed over monetary reasons doesn’t make much sense. I would imagine an appraiser may be more intimidated and susceptible to stray ethically if he was worried he might not get paid if he didn’t make his client “happy” value wise.
    Interrupting the cash flow in any business can lead to a painful death. The impact that my work is not “prepaid” means I get to wait 45 to 60 days to get paid even though AMCs have already been prepaid for the appraisal. To add insult to injury, now I get to track down monies owed to me. If it weren’t for my wife assisting me, I’d have to hire a secretary just to invoice and chase down money that’s owed. Ironically, although I have much less work orders than before, it seems it’s taking much longer to complete an APPRAISAL ASSIGNMENT, GIVEN ALL THE EXTRA HVCC DATA THAT GOES INTO AN ASSIGNMENT. IN THE PAST I COULD WRITE AN APPRAISAL, POST INSPECTION IN AN HOUR OR TWO. NOW THE TIME TO GET ONE WRITTEN, WITH ADDITIONAL AND ULTIMATELY MEANINGLESS EXTRA PAPERWORK, IT TAKES A GOOD 4+HRS TO WRITE UP A REPORT.
    I WOULD LIKE TO KNOW WHO HAS GIVEN THE ATTORNEY GENERAL OF NY SO MUCH POWER TO DESTROY AN ENTIRE INDUSTRY? FURTHERMORE, THE SAME OLD LENDER SHENANIGANS OF FORCING VALUE OPINIONS AND PRESSURING APPRAISERS IS STILL HAPPENING.
    I HAVE ALREADY BEEN COERCED BY A MAJOR TITLE COMPANY OWNED AMC WITH THE INITIALS S.L. SEVERAL TIMES ON MY VALUE CONCLUSIONS. THEY WON’T COME RIGHT OUT AND SAY IT, BUT IT’S OBVIOUS THEY ARE GETTING HEAT FROM THEIR CLIENTS/BORROWERS/ OR BOTH WHEN THEY FEEL MY VALUE OPINION IS “TOO LOW.”
    IN THE PAST IF A BROKER HAD A VALUE CONCERN ON ONE OF MY ASSIGNMENTS I COULD GET ON THE PHONE AND EXPLAIN MYSELF AND THE STEPS TAKEN IN THE APPRAISAL PROCESS IN DETAIL. FACT OF THE MATTER IS, WITH MY CLIENTS I DIDN’T EVEN HAVE TO EXPLAIN MYSELF. AFTER YEARS OF WORKING WITH ME, THEY HAVE GAINED A TRUST IN MY WORD, AND WOULD RARELY EVER ASK ME TO DOUBLE CHECK MY WORK. THANKS TO YOU, MR. CUOMO, NOW I GET TO TAKE A FEW EXTRA HOURS TO DEFEND MY WORK TO A CORPORATE GIANT THAT WONDERS WHY I’M STICKING WITH THE MODEL MATCH SALES IN THE AREA INSTEAD OF GOING OUT OVER A MILE FOR LESS SIMILAR COMPS THAT CAN ONLY PUSH AN ADJUSTED VALUE SKY HIGH. THIS HAS HAPPENED TO ME ON 3 OCCASIONS NOW AND FOR THE RECORD, IT WAS NEVER HANDLED QUICKLY AND quietly. I was made to feel like the bad guy, with one of the appraisals being kicked back to me 4 times because the homeowner thought her condo was so much better than the 15 other sales in her project. On another file, the homeowner was given enough of my information to be able to track me down and make demands that I consider a higher value on a home he was buying. By the end of the call, the borrower was grateful that I didn’t compromise my values and I gave him/lender a solid valuation.
    So here is my dilemma. I love my profession and I am good at it. I am turning 40 next year and I am faced with having to leave my industry if I can’t think of something fast. Problem is, what else shall I do? I have built a family, lifestyle and a home based around my profession and now I stand to loose the stability I have created for my family. I am angry that some clown forced such industry wide changes upon my profession without even the foresight to consider how this may impact the men and women HVCC claims to protect.
    No one has ever attempted to make HVCC a win-win for all parties involved. What a cluster it was the first day, let alone month, that the HVCC was implemented. Most lenders had no clue how an appraisal was to be ordered to remain “compliant”. What’s more, appraisals were supposed to be “portable” from one lender to the next, and, although the code implies that there will be flexibility between lenders, there is nothing that requires banks to use transferred appraisals. Apparently, nobody actually considered the level of greed that the banks, which now own there own AMCs, would actually resort to, as they now charge the consumers much higher appraisal fees than before and actually pay the appraisers much less for their service. The fox has been let into the hen house for certain.
    This dilemma I am faced with is not a function of a bad market or that my industry has gone offshore to be produced more efficiently. This is a result of an extremely bad and perhaps criminal idea on the part of New York’s Attorney General and the corrupt GSE’s.
    I can’t imagine anything like the HVCC happening to any other profession in existence. What would lawyers, doctors, real estate agents or accountants do if somebody said to them, “We see a “problem” and we plan to HELP you. We are going to take your clients from you that you have cultivated through the years and we’re going to divide them up amongst those possibly less skilled than you. However, before we do that, we are going to charge the consumers of your trade more money than they’ve ever paid before and we’re going to skim 40% to 60% off the top and make you wait to be paid. Incidentally, we’re going to tell you how and when you’ll get paid, if ever. This we are going to do because we are here to keep you feeling safe and compliant.”
    As I sit here figuring out how I get to pay my bills next month, I’m stuffing this sickening feeling I’ve got in my gut that the mafia (AMCs) have muscled into a time-honored profession and now appraisers all get to pay “protection money.” AMCs have descended like vultures on a rotting corpse.
    I calculate that I have lost over $15,000 a month in gross business since the HVCC fiasco began with no measurable benefit to the consumer. I know of many other appraisers and now real estate agents that have lost a great deal of money over this garbage that’s been thrust upon us. Furthermore, the public at large is paying more than ever before.
    I’ve written the media, local congressman and the AZ board of Appraisals to voice my concerns. I contacted an attorney (spent over $8,000 in legal fees) just to find that it would cost me well over $100,000 to initiate a law suit against those that forced the HVCC upon us. Unfortunately, I can not financially afford to fight this battle alone.
    Do we not all have legal grounds to fall back on? Who has given these corrupt purveyors of their own agenda the right to take food off my table and yours? I may well stand to lose not just the table, but the home that surrounds it. I know some very good appraisers that have now already lost their homes over this ordeal. As I said before, what other industry would allow this sham in the first place?
    I am not content to hear that there is a bill proposing a “Moratorium” to the HVCC on Capitol Hill which isn’t even a law in the first place. I’d love for a Congressman to call for an investigation as to how this travesty has befallen the entire real estate industry promulgated by the NYAG’s office and the GSE’s seeking a legal get-out-of –jail free card.
    If appraisers were united, and we all decided to stop doing appraisals for a few days or perhaps even a week, the entire industry would come to a screeching halt. Suddenly we appraisers that are typically the most trained, educated, liable and LEAST PAID entity in a real estate transaction, would garner some measure of respect for ourselves as well as for our industry.
    And speaking of respect, every appraiser knows that the average homeowner will be somewhat put out to schedule even a 1 to 2 hour window of time for our much needed services. On the other hand, people will wait all day and into the night for the cable guy to show up at their door.
    I demand that reparations should be paid by those who should be held liable for their actions. I propose a class action lawsuit to be filed against Fannie Mae and Freddie Mac, the New York AG’s office, and perhaps the entire State of New York demanding an immediate cease and desist to the HVCC and that damages be paid for having either intentionally or unintentionally harming an entire industry without having done your due diligence to determine the impact of your actions upon the Nation.
    Mr. Cuomo, you are a lawyer. You know that ignorance is never a good form of self defense. People have been harmed by your carelessness and apparent inability to own up to your bill of goods you have thrust upon us. We are still being harmed and we are ready to fight you tooth and nail so prepare yourself!
    If you are sick of this and you would join me in fighting back the wolves that are at the door than email me and share your experience of the HVCC so far and lets take back control of our industry.
    You may contact me at:
    hvccjustice@hotmail.com
    Sincerely,
    ~The Appraisinator

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