NAR Calls for Implementation of IVPI

On April 6, 2010, the National Association of REALTORS (NAR)® President Vicki Cox Golder sent a letter to Federal Housing Finance Agency (FHFA) Interim Director Edward J. DeMarco asking that the government sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, implement the Independent Valuation Protection Institute (IVPI).

Stating that the IVPI is a critical part of the HVCC, NAR said that it would complement already existing appraisal regulatory bodies at the state and federal levels.  The IVPI should be implemented to fulfill the implementation of HVCC and to help address unintended consequences created by the Code.  Further, the IVPI will be positioned to work with appraisal organizations and state regulatory agencies to ensure the independence of appraisers and the integrity of the appraisal process.

In 2009 Fannie Mae published the IVPI Interim Complaint Form.  According to the Fannie Mae announcement, the form would be found on an interim IVPI complaint Web site until the IVPI could be fully implemented.  The Web site was to be operational by November 2009.  At the latest meeting of the Appraisal Foundation Advisory Committee (TAFAC) meeting in March, Fannie Mae stated that the IVPI Interim Complaint form had been withdrawn at the request of their regulator.

  1. Telicia

    I hope the regulators don’t take implementing the IVPI to mean that we will then be fine with all the problems with the HVCC

  2. Retired Appraiser

    The NAR has made the same mistake that most of the public has. Do they actually believe that HVCC was intended to help protect borrowers and provide for improved appraisal quality? Dear NAR, if you believe that I have a nice little white house I’d love to sell you located at at 1600 Pennsylvania Ave. in Washington D.C.

    Wake up guys. It doesn’t take a genius to figure out that HVCC was merely a scam to put a few billion dollars in the pockets of AMC owning banks…at the expense of consumers and appraisers. Did you really think they would follow through and spend a few million dollars to set up an IVPI? It was obvious months ago that there would be never be an IVPI because it was merely a short term scam.

  3. Telicia

    I’m curious to know why we need a complaint center for a law that extorts appraisers and consumers. How is this law not illegal to begin with.

  4. So NAR cares about appraisers? With NAR’s stance on the illegal use on BPO’s for HAFA, I am surprised by them actually saying anything in favor of appraisers.

    NAR = massive fail for appraisers

  5. Bob Heriford


    You really have done enough to screw us appraisers already. I wish I could have access to the MLS systems without being a member of NAR. WAKE UP!

  6. Ron Styles

    How funny, NAR acts like it cares for appraiser’s. LOL! If NAR was acting in the best interest of appraiser’s they would back ending the HVCC, not implementing it further. The consumer is bieng charged $100. – $200. more for an appraisal, the appraiser’s are being robbed of $100. – $200. of their fee, The banks and AMC’s are filling their pockets and Andrew Cuomo’s run for governor is being funded by the banks and AMC’s as payback for his role in implementing the bill. All a big RIP-OFF!!!

  7. Bill

    As a long term appraiser I frequently do not agree with NAR’s public stance on some issues. However, It is imperitive for all including governemntal agencies and secondary market investors, that the HVCC is CLEARLY hurting the market ! It is a boom for the uneducated in this business including AMC’s, and creates a process for some appraiser and brokers who would otherwise would not be able to work in the appraisal industry due to lack of skills and knowledge to provide value estimates to unsuspecting users. The HVCC creates an shield for them and does not protect the participants in the process or the lenders. Wake-up, no other legeistation or organizations. Let the free makret work without regulation. What other industry precludes a business from having contact with the ultimate client.

  8. Alan A

    The funding for the (do nothing) IVPI will likely go to the political cronies of the genious who has us all over a barrel (IMHO).

    Why on earth would NAR want the IVPI to be implemented? It is toothless. All it would do is to undermine legitimate legislative efforts to bring accountability to those who selfishly undermine the appraisal process.

  9. NAR didn’t ask me about this and as a member and an appraiser I don’t like them implempting something without input from us. Why do you want to do this? You have never done anything for us yet except our money. Now the state (Texas) has put appraisers under the rule of the Texas Real Estate board so you know it just gonna get worse. How do appraisers apply for a government bail out?

  10. Doug

    The IVPI is a joke. This is just another waste of money. The HVCC is not even a government mandate. It is only a mandate foisted upon Fannie and Freddie by Cuomo. These two are probably going to be broken up into smaller agencies. The HVCC is going to sunset soon. If the NAR wanted to do anything for appraisers that pay dues to their corrupt organization they could at least fight to make sure the HVCC goes away for good. Plus they should fight to make sure AMC’s are regulated and can be held liable for appraisals sent up through them. Maybe then they wouldn’t hire the cheapest guy on the block with the least experience.

  11. Hal Gleichmann

    Why is NAR making it harder to do business… You are not protecting the public! It is this stuff that made me retire my appraiser’s license.I was paid $350.00 for an appraisal 20 years ago… AMCs only want to pay a couple of hundrd today and the government wants more and more from the appraiser. AMCs, HVCCs, IVPIs do nothing except muck up the process.

    As a broker I can sell one inexpensive home and make more than appraising 20 homes! I can remember when NAR was helpful in the 60s, 70s, 80s, and some of the 90s… but now they seem like they are shooting themselves in the foot instead of helping the public and or appraisers. I feel actions like this really hurt.

    I’m still an active REALTOR in the business after 47 years… I hope to be in the business for many more… but I sometimes find it hard to look my customers or clients in the eye and tell them the REALTORs are really protecdting them.

  12. William Steinke, SRA

    There are existing regulatory agencies. Work within the system without adding a new bureaucracy.
    If NAR is truly concerned about the appraisal process they would work to assure their members are not illegally selling BPO’s. I smell a rat!

  13. Paul H

    Does NAR really want to help the public. Help implement the REAL SOLUTION:

    A. All mortgage originators must be licensed immediately with their respective Department of Commerce Dept.
    B. Have all mortgage originators be salaried.

    End of all problems. No more illegal activity because mortgage originators can be under the watchfull eye just like us appraisers, (fines or loss of employment). Secondly, if they are salaried not commissioned for income they will quit pushing values at appraisers.

  14. Sue W

    I think its time for us to consider a major boycott of NAR. We pay dues to be represented yet we are continually sold out to the political interests. NAR acts like it cares about us Realtors, yet time and again we are sold down the river.
    Those of us who do REO’s for the banks are being placed at great risk; the banks think we are their personal fall guys. Wait til the lawsuits start.
    When are we as a group going to get some spine? We should be encouraging every homeowner in the country to hold a moratorium and stop paying their mortgages for 3-6 months. We should be refusing to participate in NAR until they choose to represent us.

  15. Rich

    Having been a Realtor since 1981 I have never felt the NAR has had my back or provided anything for me except the right to pay more to belong the the MLS systems. As an appraiser I would like to see NAR quit doing me any more favors! I feel like I have been screwed enough already for the past 29 yrs.

  16. I am suprised that after reading all these posts there was only one comment regarding the regulation of Mortgage origination.

    This is the gate keeper to all mortgages. All services provided to a consumer for the protection of the financial instrument that is choosen is heavely regulated beyond this point.

    It supprises me that the industry has not done more in regulating this entry point.

    Financial advisors are required to maintain a level of education and certification in order to properly educate the consumer of their risks.

    Why has mortgages been eliminated from this requirement till now??

    It is sad when during the meltdown, a person read a help wanted add in the local paper or online which gives you a 30-300k commission based salary range with no education and only requirments are 18 years and sound mind.

    The SAFE act is a benefit to us all but lacks the proper tools for protecting consumers with limited education requirements.

    Three good things of this act I will support include:
    1. No more commission based origination fees.
    2.Certification requiring all persons handling the real estate loan process are attached to the loan.
    3. Such an Act opens up the door for additional requirements if we can come together as an industry to balance the system.

    There is a level of ethics the real estate industry adheres to. We are required as appraisers to be advocates of objectivity.

    We are backed into a corner and need to unite for the purpose of saving our profession from further blame.

    Unhappy Appraiser!

  17. I call this process with AMC’s as paying, extorsion money. You only get so many, based on how much you push the value, so what is their real purpose other than to DESTROY, 18 years of hard and honest work and sacrifice. I was never influenced by anyone in the past because I spoke up and took them on and told them the facts of life.
    My freedom is gone as an independent appraiser, now, the hardest part, is trying to explain this to so many people, why I can’t help them anymore. This great country has turned its back on my profession, just like they turned their back on me in Vietnam.

  18. Joe Johnson

    seems like the NAR should really take a look at all of the comments above as I have not seen one entry that has a positive slant for this action. The implementation of this IVPI will just cost a fortune and will probably eventually be dumped onto the appraisers back with additional fees. The amcs need to be taken out of the equation and the hvcc needs to be removed as the USPAP is and was adequate for competent ethical appraisers to do business. The appraisers that are in favor of hvcc and amcs never would or could stand up against the pressure which, by the way is still evident. The additional cost and method of doing business for appraisers has bankrupted some and left many appraisers out of business due to having no clients.Fees are not negotiable,advertising an appraisal business is pretty much useless and inexperienced and unqualified appraisers are putting additional strains onto the situation by not having either of those to competently complete an analysis of a property. Get rid of hvcc and get rid of amcs, they both are nails in the coffin of the Realty business,and if it can happen to appraisers it can happen to Realtors.

  19. Courtney Gillard

    What a great read of comments! NAR has thrown our appraisers under a bus, and I’m so tired of seeing more money taken out of my pocket to help them do these ridiculously foolish and hurtful things to fellow members. I hate that I have to be a member of NAR to function in Real Estate. I’m all for a boycott!

  20. The NRA should stay out of the Appraisal Business and worry more about the misleading information that the Realtor place on the MLS. Like the way “Short Sales” are listed. Most of the information as well as the listed price are misleading and the sales of such should not be with “Arms length transactions” As a Realtor I have had to explain so many times why the listed price of a “Short Sale” (there is nothing short about a short sale) may not be the “purchasing price’ that a client can purchase the property for. It is like the old “bait and switch” used car technique The NRA has allowed the banking industry to interfere and hurt the recovery of the real estate market, as well as making the Realtor “look bad” to the public. NRA stick To Real-estate you have enough to worry about,

  21. Len

    Licensing mortgage originators doesn’t make AMCs go away (i.e. California). Putting mortgage originators on salary will make them lazy, unproductive, order takers (i.e. how banks formerly operated). Can’t all appraisers just be put on a low salary instead? (just kidding). Incentivized pay is the American way; it breeds productivity. AMCs were determined to be “the wave of the future” due to appraisers whining about real estate agents and loan agents manipulating the appraisers/appraisal values. I say, “Complain about it enough, and government will come.” (i.e. health insurance and health care). Lesson learned: Don’t complain and ask the government for help. When there’s a problem, unite and fix it yourself. Is there a union specifically for appraisers? If not, can’t appraisers unite, then agree to quit the corrupt AMCs and create several of their own fair, lower-cost-yet-higher-paying, ethical AMCs? Wouldn’t every appraiser want to sign up for only those AMCs? Wouldn’t lenders need to use such a dominant, low-priced AMC? Wouldn’t consumers insist that their lenders use such AMCs if it would save each consumer $100-200? AMCs may have eliminated the pressure on appraisers from real estate/loan agents – but there must be a better way to accomplish that goal. So, let’s stop whining. Let’s create a solution for obtaining accurate appraisal reports at a competitive & fair price. Or, we can keep whining and rely on NAR and the government to fix our problems.

  22. Matthew Gloege

    Won’t work. After 37 years as an active RE Broker (Realtor), 20 of which has been spent as a Certified Residential Appraiser as well, I can tell you with a reasonable degree of confidence that it wont work. No mater what you do, pass, promulgate etc. the bad apples will always find away around the law. There is one way however that will work. Its the only fool proof solution. We all get together and pass a law: “It shall be a felony punishable by a $10,000 fine and mandatory five years in prison for an appraisal value, of any kind and in any form, to be delivered by an Appraiser, by any means until the fee for that appraisal be paid in full and the instrument of payment cleared the issuing institution.” Unfortunately its all too idealistic to work. Its like lighting a candle in the darkness at 2:00AM on a mountain top in a fifty mile an hour wind with wet matches. Or like try and outlaw war by making a law that says; whatever you kill you must eat. Just try.

  23. Margie Gosser

    I want to thank NAR for bringing the focus once again to the broken HVCC Code and the stilllllllll missing IVPI . BIG Gov’ got the backs of the money trial…always will be short sighted when it comes to …future of most anything. Again…HVCC allowed banks to OWN Appraisal management companies who charge fees WELL ABOVE what the normal fee would have been…protect the Public??? Are Borrowers “the Public”? are Appraisers who are now out of business…”the Public”??? As I said…Gov follows the money. The FEE we are offered-mandated for an appraisal service …knowing what the BORROWER is being charged…we feel like we are part of the GOV-BANK scam. My Ethical Profession and Reputation has never been as harmed as now where “Gov freely generically tatoos Appraiser’s as having no Morals or Business Ethics”. GOV” implemented the HVCC and must feel the IVPI was such a BIG JOKE anyway…why bother. Big GOV ruined the Appraisal Profession. If Appraiser’s are SO easily swayed, have no morals or ethics …then how can Appraisers be trusted with such an important role in FIXING this GOV” BROKEN Real Estate Crisis. Why do I finish an Appraisal Service in a few days and find out after months of NOT being paid the loan still has not closed? Why is it so many potential Borrowers can afford the upfront Fees (Bank -AMC Mandated Fees) to be able to FIX their Mortgage Payment by Refinancing? Why is it GOV knew years prior, Lending Practices were out of control and DID NOTHING to STOP Lenders from misleading the Type and/or Loan Re-payment? By an Overwhelming Majority, the Problem that drilled a hole in the Real Estate Dam was Big GOV and Big BANKS…not Appraisers or Realtors or THE PUBLIC.

  24. R WEST

    All of the above appraisers and brokers are correct. Appraisal should be left to appraisers, however when a homeowner decides to sells his/ her home, they do not call an appraiser to price it, market it, or even sell it. They do call there local real estate broker (salesperson) to give them a good idea of what the home should sell for. They rely on the very same people that all the above real estate appraisers and AI are saying are incompetent, and this has been the process for years. AMAZING!!!

    Furthermore, aren’t (as much as I don’t like it) banks/ financial institution no more than homeowners trying to sell properties. If so, don’t they have the same right to information as any other person attempting to liquidate an asset, or should they be subject to only one point of view, no matter how narrow it might be.

    The idea of BPO’s is not to value the asset, but to determine a reasonable price for which the holding party can dispose of it. It is as simply as buying a rookie year vintage 1969 Amazing Spider Man Comic off e bay. Had the seller wanted value for the item he/ she would have order an appraisal of the item to determine its true worth, however there goal was to dispose of the item in the quickest amount of time possible, so they settle for less base on a book they bought at Barnes and Noble. Yes, the seller lost out on potential gains, however they accomplished there goal, which was disposition of the asset.

    Lastly, the one thing that all of the above people, AI, and NAR are all forgetting that it is about choice. THE choice in how to run their business, choice in how to dispose of an asset, choice in what value/ price they want to accept. They do not have to use any of us for there own internal results and decision; they could simply (as one person point out) rely on Zillow, or Google earth. With that, yes they still would need an appraiser when a potential purchaser came along, and they still would need a salesperson/ broker to sell/market the asset, however the decision would have been made, and not real estate agents or appraiser would have had any so say in the price/ value they determined. So in the end we should all be thankful, that we have some type of market to work in. Because for now the rules of the game have change, and (as much as I hate to admit it) the BANKS are in CONTROL