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5pence: (February 23, 2010 8:50am)

Amin - you should go to todays blog to ask. It's called breaking FHA news.

Amin: (February 23, 2010 8:40am)

I'm a licensed mortgage broker in Texas. Do I have to take the 20 hr class for NMLS

5pence: (February 23, 2010 6:59am)

SoCal Gal: I'm in Washington State. Before I'd let any appraisers fighting the good fight move into tents, I'd open up my house. This fight can't be in vain

5pence: (February 23, 2010 6:56am)

that's right pipette, ignore that this country is being over run by self-serving interests and be sure you get yours. There are larger problems going on out there and your comments don't contribute. What are doing to fight injustices - probably nothing since your got yours, right?

pipette: (February 23, 2010 4:57am)

Too old at 50, please, I started an indepedent insurance agency @ 53 that generates 450,000 gross income, took 2.5 years to build. This forum would have ZERO traffic if an appraiser would have to pay 1 cent top post their woes.

NorCal Broker: (February 23, 2010 12:05am)

Mikey - take a look at the IRS website regarding the tax credit. It does state that the purchase agreement has to be fully executed by April 30, 2010 with a closing date no later than June 30th, 2010. Always a good idea to go straight to the source that is doling out the coin.

Experience need not apply: (February 22, 2010 10:17pm)

Southern California also....very difficult. For most people that have been doing this industry for the past 20+ years, we are loosing our livelyhood with all these changes....this is "my profession". It is difficult at 50 to go out and start over. Who can pay rent on minimum wage, and that is if you are lucky and can actually be hired in this market. For most of us, we are not collecting unemployment? The worse part of all of this is it has nothing to do with experience or our ability. Appraisers are at the mercy of the AMC companies. Loan officers are at the mercy of the new regulations. All we can do is sit and wait. That doesn't pay the bills.

Socal Appraisal Gal: (February 22, 2010 9:41pm)

5pence: thanks for your comments what state are you from. I am as frustrated as you. I am even more frustrated by the ridiculous conditions I recieve on each file and cannot charge them for their stupidity. I have been an appraiser for over 25 years, never pushed value just ethically provided a sound well supported report. Two of my former clients stated every condition letter I ever had to write I always stood up against the industry and their avm value cuts. I have exposed the AMC's and who truthfully is running them and it is not pretty. I exposed Core Logic for their USPAP violations. I continue this fight but am broke as well. I lost all my FHA clients last week. I am now running an appraisal rebuttal business for buyers and sellers who have been wronged by the AMC. It is a sad day in our industry. Ethical experienced appraisers are losing everything. I will continue the fight but may end up living in a tent, at least I like camping and the outdoors.

Experience need not apply: (February 22, 2010 8:32pm)

Hi Brian & Frank, Can you ask the regulators one thing for me...I have been originating loans for 20+ years (broker). Potentionally, I could loose my so called ability to earn a living. I have already lost my home last year due to my husband being an appraiser...we all know why, and my industry tanking too. With the SAFE Act, I basically need to take the 20 hours of education (like 20 years wasn't enough), take & pay for the test, pay for fingerprint scans and then they do a background check which includes credit. If they turn me down because of credit, I have just spent almost $500? Doesn't seem fair when it is not spelled out what is acceptable? Am I wasting my time & money? I can understand why CFL lenders could possibly be required to be registered because they have had no individual licensing, nor has the loan officers at the banks, but it seems like I now need 2 licenses from different agencies to do the same job? Nothing makes sense anymore.

5pence: (February 22, 2010 7:15pm)

Guys, this ALL directly relates to Cuomo and his illegal HVCC. It appears, all of it.

5pence: (February 22, 2010 7:13pm)

SoCal Gal - you're right, if the lender wants to expand the scope of work after you've completed the assignment then they have to pay for it and not the borrower. Tell them that so they can understand the borrower is done paying bailouts. The borrower would be pissed if they knew. Idz jez rong

Exhausted Fed: (February 22, 2010 5:10pm)

Shouldn't the bigger question be after years of downsizing federal housing agencies how do they plan to spend all that ($1.5 Billion) TARP money when Federal Agencies are running on skeleton crews as it is in those 5 states? It's bad enough when the economy went south banks turned to government backed security mortgages, but instead of meeting the demand the new administration decide not to hire more people and instead hire temp's and part-time retiree's. I'm no rocket scientist but this doesn't seem like a short-term housing crisis.

LSK: (February 22, 2010 4:21pm)

For the regulators: HVCC, HERA and RESPA are HURTING the consumer (even though that was not the intent). HVCC hurts the consumer as they are paying more for an appraisal of less quality that the consumer has to PAY FOR all over again if they want to take their loan elsewhere or if the appraisal needs additional work. The lender is NOT protected as the valuation risk is still there (poor quality) and all the AVM's, additional comps add time and money! HERA just adds time to the borrowers process (and money to the lenders process to manage, increasing borrower cost) and RESPA has LESS transparency as lenders STILL DON'T HAVE TO DISCLOSE! Plus it adds cost as LO's over estimate fees and lenders have to hire additional staff to manage that process! ALL OF THIS EQUALS INCREASED TIME AND MONEY TO THE CONSUMER!!

PA Appraiser: (February 22, 2010 4:19pm)

G-Appraiser go to appraisersguild.org for the Guild.

Mikey: (February 22, 2010 4:02pm)

Regarding the tax credit deadline, the FAQ from federalhousingtaxcredit.com states: "However, the law also allows home sales occurring by June 30, 2010 to qualify, provided they are due to a binding sales contract in force on or before April 30, 2010." The video didn't mention that accepted contracts have a shot at it (if they close by June 30th!).

Carlos: (February 22, 2010 4:00pm)

Have you guys heard anything about this new principal reduction program, being advertise by several companies.; They claim that they have investors that will buy your loan from your lender at a discount and then restructure the loan with a new one based on a current appraisal and give you a fixed rate laon at anywhere from 90 to 80% of the current appraised value, creating equity for the home owner???

Socal Appraisal Gal: (February 22, 2010 3:04pm)

I just recieved a condition letter for fha appraisal report. They have asked me to put an additional 703 after my fha case number, take photos of all bedrooms and baths as well as the smoke detectors...I called the fha connection and they sent me to the local HUD office that stated no those additional numbers don't go on the appraisal and no the photos are not required but a lender could ask for additional requirements but you should know up front in an engagement letter. I was told I should charge a reinspection fee...I called the underwriter who stated the borrower will have to pay for this...This does not seem right as it is the lender who did not tell me up front they wanted all these extra photos. Note I did shoot kitchen, one bath, one bedroom, living room and dining room. I stated the smoke detectors were there, to code and operational...do they think I a lying. I was then told they could not provide me with their investors request ahead of time. Borrower is getting screwed.

Valuequestor: (February 22, 2010 3:02pm)

I keep hearing the words "rotation" and "round-robin" being used concerning FHA appraisal assignments and assigning of AMC work. Where did this information come from? Each AMC has its own system. You might have a rotation within a Lender's own select appraiser panel. I wish more lenders would set them up instead of relenquishing control to an AMC.

SimpleSolution: (February 22, 2010 3:02pm)

Socal Appraisal Gal-Will do thank you....

5pence: (February 22, 2010 3:01pm)

Bravo! Socal Appraisal Gal. See what one phone call can do? Socal Appraisal Gal: (February 22, 2010 1:08pm) "I just got off the phone with Santa Ana Hud appraisal staff. they want you to email them on AMC's who pay below norm. Get their fee quote sheet and send it to your local Hud office appraisal division. They will forward this on to Washington." **Absolutely right that the fees quoted don't include added FHA certifications/work and the MC. I still would argue that customary, usual and typical is the $600+ the AMC is charging the customer. Per Socals Appraisal Gals response, they WANT to know who the low paying AMC's are. Those that can should oblige them. It just might make a difference

Lorley: (February 22, 2010 3:00pm)

Question: Is it true that a currently State Licensed Loan Originator's credit score will be checked and if not at a 620, that LO can be denied an application for the SAFE test and/or License with NMLS?? If this is the case, please explain how that can be a part of any professional license pre-requisite...

IamNowAVendor?: (February 22, 2010 2:46pm)

Since 1989 I've been a very hard working and conciencious real estate appraiser. I am ashamed to say that since HVCC, I've had to accept several AMC assingments for fees much less than the standard 1989 fee in an effort to try and slow my financial descent. On every appointment I would ask the homeowner what fee they are paying for the appraisal. I recieved a phone message from the AMC (still on my cell) ordering me to not discuss fees. Isn't this hiding fees? What happened to truth in lending? Can you say class action?

Socal Appraisal Gal: (February 22, 2010 2:41pm)

SIMPLE SOLUTION. I don't deal with AppraisalLoft nor know who they are. You need to put down the information you know about them and their unreasonable fha fees. You can call the FHA connection 1-800-225-5342 given them you information and ask to be transfered to the FHA HUD center in your area. Give them the information. If they are not forwarding it to Washington the Santa Hud office is so ask for their office your complaint backed with details and they will forward it to Washington.

Dante: (February 22, 2010 2:38pm)

Here's another one for Mr. Stevens: How can a giant like FHA and HUD not have anyone, at any extension, at their office actually answer the phone to listen to what appraisers, or anyone for that matter, have to say about their newest ill policies. I have called no less than 20 different phone numbers at FHA and all of them go directly or indirectly to voice mailboxes and nobody returns the calls. That is unbelievable that they can institute radical changes and then hide behind a vail of voice mailboxes. They should be answering the phone and defending their decision that allows, almost mandates, that anyone, inclusive of convicted felons, must enter the lending industry in the form of an AMC middleman who is only required to fog a mirror. What a solution Mr. Stevens! Allow convicted felons into our industry to save the day you retard. Didn't loans that required someone to fog a mirror only cause calamity in the end? How short his memory is! Someone should embarass him with one.

real appraiser: (February 22, 2010 2:37pm)

Mortgage Man: make no mistake, the lobbyist own the politicians that make the rules/laws. In essence the biggest companies run the US. The bailout is proof. Millions in foreclosure, no bail out for middle class, just banks that pissed our monies on legal high risk gambles. no different if you bought lottery ticket with your whole paycheck each week for a big payoff. See if the govt will bail you out at the beginning of the month when bills are due, No, Hmmm, But its ok for the too big to fail banks, But each party counts on everyone of us to vote party line to keep the system going. I say get rid of them all. If there in office now, they need to be voted out!!!

Dante: (February 22, 2010 2:29pm)

Hey, here is a pointed question that should be brought up to David Stevens, FHA's Cuomo wannabe: "Is is ok that we are going to limit your salary to what has been "reasonable and customary" in the past with no way that he can get a raise due to this clause?" Sorry, no CPI increases for Mr. Stevens. Why does he want to control appraiser's pay again? Why should appraisers have no control over pricing as it relates to the actual amount of work that needs to be done for an appraisal? Hit him with one of these monsters....before we appraisers all declare that the only way we will accept payment across the country is COD at the door.

Mortgage Man: (February 22, 2010 2:25pm)

There can be no housing recovery because we went from if you have a pulse, you're approved to the absolute extreme of clenching down and over controls with government interference in the free markets...or is it true as it appears...This is the large banks that are "above" the rules that are making the rules.

reasl appraiser: (February 22, 2010 2:21pm)

MortgageBlues: I do not get it either, if there was enough money to steal from these companies, the government would find a way to make their friends rich off it, they started with doctors and hospitals by given the insurance companies complete authority, then appraisers, now brokers. The realtors are next, thats a boatload of money per sale that they are gonna want their cut, they tried a while back and the NAR screamed, so now they are going in the backdoor. divide and conquer. Someone please tell me I am wrong, THE NAR SHOULD SEE THE WRITING on wall, but the truth is they only started against HVCC after it started killing sales, most realtors were happy to see us eliminated, Now it is your turn, hope the NAR is better than the AI for your sake. But I think not1

SimpleSolution: (February 22, 2010 2:19pm)

Socal Appraiser Gal-AppraisalLoft admits upfront that they take a 40% cut and they are only accepting Certified or Certified General appraisers that have been specifically recruited to their panel. Please give their name to your contact. Their appraisal fee is $375 so that leaves $225 for the appraiser. Way below the norm for this area and the funny thing is that they admitted it to me upfront.

real appraiser: (February 22, 2010 2:13pm)

One question only. How can banks and AMC's have staff appraisers without a conflict of interest, please do not use the (tissue thin) firewall excuse, how does this promote appraisal independence. Every appraiser working for a bank or AMC cannot establish themselves in the real world probably due to poor quality work, yet they are given the bulk of the work currently. Why does'nt the CONFLICT OF INTEREST apply to banks in every regard, broker and appraiser.

MortgageBlues: (February 22, 2010 2:07pm)

Regarding HVCC: Why should law makers stop with appraisers and lenders? Perhaps all business transactions should be regulated? What about the auto-body shop owner who could conspire with the car owner to over inflate the repair cost and split the additional insurance proceeds? What about the doctor who could ask for additional x-rays and tests which he knows the patient doesn’t really need but the insurance company will pay for? What about the pawn broker who might tell the customer his coin collection is worth much less than it really is? Do we need more government regulation for all business transactions? HVCC- assumes the potential for appraisal fraud is so great that it rises to the level of necessary government intervention. What do you think?

loan officer of 20+ years: (February 22, 2010 2:06pm)

For all of you wondering how they passed the safe act....talk with the mortgage brokers association in your area. Ic California, they backed this bill? I guess all of them have good credit and was thinking this is a good way to shrink the competition. They should have thought about the affect it would have since the real estate and loan industry have been the hardest hit...or maybe they did. If you think about it, it is really the banks controlling everything...they got the bailout, many banks own AMC companys and they are getting rid of Loan officer competition with the safe act. Yet, they are above all the rules. The people in Congress are "puppets". They have no understanding of our industry. Customers can't get loans that banks don't offer? The banks made the programs and the rules. They were greedy and wanted more money and they STILL DO....the cycle continues.

NORTHERN CALIFORNIA APPRAISER: (February 22, 2010 1:48pm)

To Our Lending Colleagues - When you get a bad appraisal done by some AMC hack, PLEASE report it to the State Board that licenses appreaisers in you state. It might start to attract more attention to the HVCC/AMC problem if these boards get innundated with more complaints about the poor quality of these appraisals. Here is a WEBSITE that lists the names & contact info for EVERY STATE BOARD in the USA: appraiserusa.com/stateboards/index/htm Remember, if you don't complain to the appropriate entity, you will have to keep living with the crap forever.

Liliy: (February 22, 2010 1:35pm)

Question for Mr. Stevens: When will FHA eliminate the recertification process for Mortgage brokers and allow loans to be brokered just like conventional loans?

Strugglig Appraiser: (February 22, 2010 1:34pm)

Question? Back in the 80's. The government stopped a logging of the "old growth" forest because of the Spotted Owl. All of the people in the timber industry were retrained and or relocated. Why is there not something like this for the appraisers????

MortgageBlues: (February 22, 2010 1:34pm)

HVCC regulation has adversely diminished the values of home prices and ultimately caused an already struggling housing market to proceed at an even slower recovery pace. HVCC is an attempt to stop a crime by making it impossible to commit it. HVCC assumes the potential for fraud is so great that it rises to the level of necessary government intervention. Why should regulation stop with appraisers and lenders? Perhaps all business transactions should be regulated? No one would stand for the government regulating every industry because the majorly of business transactions are not dishonest. With all the evidence we have to support the fact that HVCC is a flawed control system why can’t we do away with HVCC and simply ask our law makers focus instead on pursing appraisal and lending laws already on the books and stop senselessly over-regulating the mortgage industry to its further determent?

KILLHVCC: (February 22, 2010 1:15pm)

questions to ask; doesn't the implementation of 90 day sales data in the first 2 positions of the sales comparison grid of an appraisal cause more accurate valuations than putting illegal and anti free enterprize political based 'firewalls' ? why aren't the regulations related to f.i.r.r.e.a. and the late '80s bailout adnered to anymore ? why does 1 state agent get to dictate federal policy when nowhere else in government that is allowed ? isn't there a conflict of interest on several levels with regard to Cuomo, AMC's, and bank control of the lending process ? what is the definition of independence ? what is the definition of a 'free enterprise ? does N.A.M.B. have any plans to operate without government subsidizing ? what gives anyone or thing the right to dictate appraisal fees ? would you sign the new petition and/or contribute to the legal fund to fight bank-rolling of the industry ? are you really striving for appraiser/broker independence?

Socal Appraisal Gal: (February 22, 2010 1:08pm)

5PENCE: Please note the fees Dave Biggers put out were for conventional not fha appraisals..Fha requires more work and therefore I charge more than the fee that was stated as standard for my area. They agreed with me...so don't go by those fees for FHA unless you know they represent your market. I just got off the phone with Santa Ana Hud appraisal staff.they want you to email them on AMC's who pay below norm. Get their fee quote sheet and send it to your local Hud office appraisal division. They will forward this on to Washington.

fla appraiser: (February 22, 2010 12:53pm)

AMC's are a happy bunch right now. Thanks, Mr. Cuomo. They have all of us scrambling for a dollar, looking to do a $350 job for $175. It makes me sick to think they can get an appraiser to do this, but I guess desperate people do desperate things. All of you taking reduced fees are cutting your own throat, and making sure there will be no one left in this business. They are putting your contact information into a data base, along with your fee, and the lowest bidder gets the job. Are you willing to take $150, or maybe $125? How low can you go and still hold your head up? $75? $50? On top of that, they want you to wait a month to get paid!! Are you all really signing up for this? I am not. My peers are the real problem and they all disgust me.

ILL Appraiser: (February 22, 2010 12:45pm)

sus socal-Is CCAP a new organization in CA? In Illinois we have ICAP which is doing many things for the appraisal communities nationwide including helping other states start organizations for unity. I would encourage all Illinois appraisers to join ICAP for only $50/yr. The info they provide itself is worth the investment, not to mention what they are doing behind the scenes.

tobby: (February 22, 2010 12:42pm)

CarolGator, it depends on your state. Most states require a majority of unit owners to change the bylaws. A board can not change them by themselves. The rule the board is putting in place is an attempt to get the rental percentage down to meet FHA requirements. They must do that within the state law too. They are being reasonable in stating that if a new unit owner buys a unit AND the rental rate is over xx% then that unit can not be rented. This was common before when many associations limited the rentals to 40% or less.

fla appraiser: (February 22, 2010 12:39pm)

No orders for FHA since the 15th. This was the only business I had left, and now it is gone as well. How do we get our lives back? This is totally unfair and illegal. Are we all supposed to fly planes into buildings to show our frustration? No one is listening to us, and the banks have control over everything. How is our appraiser friend who was busted for threatening Cuomo? Can we all go to his hearing? I think he speaks for all of us, we should speak for him as well.

carolgator: (February 22, 2010 12:36pm)

Our condo board just voted to change bylaws to be consistent with FHA condo loan requirement of 20% or less rental units. Can someone clarify the 'grandfather' portion of this. I thought as renters moved out the units had to become owner occupied until we get down to 20% - way over that now - but new renters just come in their place. Board president says that a unit that was already rental can stay rental until new owner buys, then FHA rules kick in. Who's right?

YING: (February 22, 2010 12:35pm)

All so a new privileged class can retire early with benefit packages that are on par with a lottery jackpot. Who knew these folks were paid so well? ... Certainly not most people. READ this : The cost for state employee pensions is up 2,000 percent in the last ten years, while revenues have only increased by 24 percent. The pension fund will not have enough money to cover this amount, so the state — that means the taxpayer — has to come up with the money. This is money that is taken away from important government services. This is money that cannot go to our universities, our parks and other government functions. Now, for current employees these pensions cannot be changed — either legally or morally. We cannot break the promises we already made. It is a done deal. But we are about to get run over by a locomotive. We can see the light coming at us. The Pension Crisis Gathers Steam And while this may be news to most Americans, the brewing municipal pension crisis is about to take another bite out of their pitifully equipped wallets. State and local governments have racked up so much debt funding generous benefit plans that a nationwide p

Mark: (February 22, 2010 12:19pm)

I'd like to send a copy of the column that I wrote for our local paper ("HUD is Hurting Consumers" is the title) but it would total far more than a thousand charachters. Is there an address or fax to which I could deliver my thoughts? And it is funny that with every new loan, I find another issue with the new GFE (eg. why are prepaids described as a "charge for all other settlement services"? Prepaids are now a settlement charge?

SimpleSolution: (February 22, 2010 12:07pm)

It is funny because if you go to AppraiserLoft to inquire about getting on their panel. They tell you straight up that they get a 40% cut from the appraiser fee and that they are only accepting Certified or Certified General appraisers that have been "specifically recruited to their panel". That is funny to me. I don't know any certified and especially any general appraiser that will work for those fees. I am certified and I sure as hell won't. It is funny to me how they are so choosy with what they are paying.

5pence: (February 22, 2010 11:59am)

Dave Biggers of WINTOTAL issued a report showing typical fees county by county across the country. Stick to these fees; don’t let AMC’s dictate FHA fees! You are the professional! The AMC cannot deny that the fees posted are usual, customary and typical. Actually, what the AMC is getting is what's typical but that is somehow being ignored.

5pence: (February 22, 2010 11:49am)

An AG that created and supports an illegal policy? Think that will raise some questions. The reason HVCC is allowed to continue is that it's nefarious activities all occur below the mainstram consciousness. We educate them to this abomination and they just might turn and bite those that deserve it. JMHO. I wrote to all of Cuomo's opponents for the Gov race, including all democrats and republicans and even those that might not even make it but are slated to be in the race. The HVCC is illegal and a man who is supposed to defend the law to the utmost of his ability is supporting an illegal doctrine that he will not allow to go through due process of law.

5pence: (February 22, 2010 11:44am)

The HVCC is the cause of all this. If you want to make a big shout, lets put a large ad in the NY Times asking Cuomo why he supports an illegal policy he created and ask why he won't let it go through due process of law to test if it is or isn't consumer protection or consumer adverse and hurting the situation. There's your shout that will be listened to.

A Appraiser: (February 22, 2010 11:34am)

Another question for the Commissioner: Why is an American Government program so eager to get on board or mirrior a reg. that at a minimum infringes on antitrust laws, is hurting the American Consumer and putting small business out of business? If there is even a distance chance all of what is being said is true about HVCC or similar regs. Why would a government entity at least investigate the potential damage or postpone till a thro investigation can be done considering the potential impact? Especially in the current economic times?

SimpleSolution: (February 22, 2010 11:11am)

Central Valley-This is true becuase we are 100% liable for the appraisals and I can't do what they expect to be done in one day nor am I going to as I am not going to produce bad reports because I have to do 4 or 5 in a day just to make a living. You are 100% correct and I hope it happens sooner than later.... :)

MadasHell: (February 22, 2010 11:07am)

Thanks for your responses on FHA appraisal orders. Thats what I figured. It will start at $300 and slowly go lower because someone else will do it for $290. And on and on. What happens to all our support services when we go out of business. So does software co.s, education co's. etc... and the snow ball keeps getting bigger. We cannot depend on elected officials. We need our voice to be loud and clear.

Central Valley: (February 22, 2010 11:05am)

SimpleSolution: A lot of the appraisers that are doing the AMC work because "they have to pay the bills" are going to have a rude awaking when they find out that they are going to have to defend themselves against a USPAP violation, pay fines,loose their license,and/or end up in jail!!!!!!!

sick of Govt. : (February 22, 2010 11:03am)

I think one of the biggest issues (more than HVCC at this point, from a lending perspective) is the new GFE requirements..

Ancient Appraiser: (February 22, 2010 10:54am)

Frank & Brian; I have a question for Stevens – What the hell happened to Independent Valuation Protection Institute?? What a joke! According to THE CODE “ Any lender who has a reasonable basis to believe an appraiser is violating applicable laws, or is otherwise engaging in unethical conduct, shall promptly refer the matter to the Independent Valuation Protection Institute and to the applicable State appraiser certifying and licensing agency.” They have been stealing our money for a year they should have plenty of $$$$. Stevens is a banking shill so don’t expect an honest answer. I’m sure if you dig deep enough you will find his name on one of the AMC owners or investors lists, along with Cuomo’s!

SimpleSolution: (February 22, 2010 10:52am)

Socal Appraisal Gal-The problem with that is most appraisers can't afford to say no. They have bills that need to be paid. I as of 02/15 no longer do appraisals because I refuse to work for AMC's but I have been able to do that because I worked in a different field prior to doing appraisals and have been able to get into that field but what do you say to the appraisers whom aren't trained in anything else and have bills to pay. That is the problem. These AMC's know this and take full advantage of it and that is fine but let them take the liability not us.

real appraiser: (February 22, 2010 10:26am)

I have not received any FHA work since feb 15, do not know where it all went. My area has Nationawide Appraisal firm that hires on a 33% split (33% to Nationwide firm/33% local Owner/34% to fee appraiser). They are getting most work even from AMC'c, paying appraisers 80-100 for amc 1004. No future in this business

real appraiser: (February 22, 2010 10:20am)

refiorpurchase: let appraiser get paid at door by home owner, $350, same fee as always, let AMC bill client fee for order process, whatever it wants- let bank pay for service it needs, not home owner or appraiser. If the AMC gouges bank who cares,= happy homeowner, happy appraiser, bank-who cares, correct fee shows on HUD

Allison Appraiser: (February 22, 2010 10:19am)

I just send the link to today's show to [email protected] this is the fraud hotline for FHA maybe if we all do this every day, they will re-think their policies

Socal Appraisal Gal: (February 22, 2010 10:19am)

Mad as hell...to answer your question I was asked by a client to get on with Trimarvin AMC in Southern California...I got the their fee list and was upset as yes they wanted to pay me $300.00 for a full fha appraisal including 1004mc. I found out who was running this AMC and he was the former cheif appriaser of Ames Home Loan...he went on to tell me that I needed to understand the AMC were like a fee split and he had contacted fha and was fine to state $300.00...my first problem is his idea of a fee split...fee split means you are paying for some of my expenses...therefore I take a reduced fee...AMC's are not paying for any of my expenses therefore I don't see how he could call this a "fee split"...furthermore FHA appraisals have been $400-450+ for at least 7 years in my area...I just don't see how they can decide $300 is a "reasonable fee"...I won't work for that and encourage all FHA appraisers to do the same...together we can stop the madness..just say NO...

refiorpurchase: (February 22, 2010 10:12am)

Customers dislike the increase in costs of appraisals as a result of HVCC. How can we force the cost of this service back down?

Golden Eagles: (February 22, 2010 10:12am)

Mark and dd have woken up to the out of the box options that would work, if they can get enough appraisers, brokers, real estate agents and title/ escrow to join them along with the hundreds of thousands of underwater, short sale homeowners. CAN YOU SPELL CLASS ACTION LAWSUITS ?? Appraiser protecting their home turf and fees is not going to work. ORGANIZE ALL AND NAME IT A SOCIAL JUSTICE, TEA PARTY TYPE MOVEMENT TO GET THE HURTING POPULACE BEHIND YOU.

billybob: (February 22, 2010 10:09am)

went from 3 to 5 a week to zero nice living

Anonymous: (February 22, 2010 10:09am)

Is Harlibuton's Headquarters located in Dubai and as a result are they exempted from paying taxes to the American government, and what is their average profit annually?

billybob: (February 22, 2010 10:09am)

went from 3 to 5 a week to zero nice living

billybob: (February 22, 2010 10:06am)

no orders here since 2/15/2010

Ezradams: (February 22, 2010 10:04am)

G-Appraiser, You can contact me if you're interested in the American Guild of Appraisers. We have the backing of the AFL-CIO (10 million members). We're getting things done in New Jersey...I can give you some ideas about organizing in your state. [email protected]

SimpleSolution: (February 22, 2010 9:57am)

G-Appraiser-Sorry for the typos! Meant to say California Coalition of Appraisal Professionals.

Valueboy: (February 22, 2010 9:54am)

Kay-Matt, your only choice is to report bad appraisers to your state appraisal regulation agency. In california that is OREA (Office of Real Estate Appraisers). But don't expect to much from this, some states do little to nothing in enforcement, others do a little. I've reported several absolute "Fraud" cases to OREA and gotten a some investigations, but the only notice you will get as to a resolution will be a form letter several months later saying they investigated the claim and a resolution has been reached. They will not tell you was action was taken, supposedly there is some privacy issue. In short, the appraiser can screw you, but after he's investigated and sanctioned by OREA, they will not tell you what for. How do you like that.

Mark: (February 22, 2010 9:49am)

Kat Matt - Your State should have a Department that watches over aprpaisers and issues their license. In the State of Ohio it it the Department of Commerce. Your state may/should have the same or something close to it

Kat Matt: (February 22, 2010 9:47am)

Is there a way or agency I can report an unethical appraiser? Due to HVCC we are paying more these days for less accurate work & I have had too many bad experiences to let this one slide. So please whom could I contact about this situation I find myself & my borrower in?

MadasHell: (February 22, 2010 9:36am)

Will the AMC's take a cut out of the Re-inspections to? Of course, they ordered it right. So instead of the customary $75 - $80 will now be $50 at most.

SimpleSolution: (February 22, 2010 9:35am)

G-Appraier-California Coalition of Appraisal. They are based out of Ventura.

L.A.: (February 22, 2010 9:32am)

Question? Are manangement Co's. who are contracted with HUD properties who are responsible for Property condition reports & selling HUD foreclosues,Does any one know if they are considered a 3rd party, and is it illegal for them to negotiate my usual and customary FHA appraisal Fee. Another words take money form me down the line BS.

The puncher: (February 22, 2010 9:29am)

Frank and Brian, just punch one of these regulators in the face and kick them in the balls too, make sure to get this on camera. I think everyone would enjoy that.

MadasHell: (February 22, 2010 9:27am)

Any appraiser's out there get any FHA orders since Feb 15th. Was it through an AMC and how much are they paying? All appraisers are curious.

MadasHell: (February 22, 2010 9:27am)

Any appraiser's out there get any FHA orders since Feb 15th. Was it through an AMC and how much are they paying? All appraisers are curious.

MadasHell: (February 22, 2010 9:27am)

Any appraiser's out there get any FHA orders since Feb 15th. Was it through an AMC and how much are they paying? All appraisers are curious.

jascar: (February 22, 2010 9:27am)

Please try to find out what the FHA is intending to use as "The going Market Rate" for AMC fees to appraisers. Is the FHA aware of the Recent Alamode Standard Fee survey that lists fees by counties for the entire USA? This would seem to be a very good guideline even though the ANC's will probably fight it.

Struggling Appraiser: (February 22, 2010 9:26am)

Charlie- I am in the same boat. I will be 40 this year and I am at the mercy of the AMC's You tell me, What other professional does not get to speak with his or her own clients. I have spent the last 6 years busting my hump to establish the relationships with my clients. Now the cannot use me to do an appraisal for them. I am a hard worker. I know my craft. I cannot pay my motgage payment this month.

Peter Hamilton: (February 22, 2010 9:24am)

The Nuclear question for Commissioner Stevens: as THE PRIMARY CHEERLEADER FOR OPTION ARMS, excuse me, as the head of sales East of The Mississippi River for World Savings Mortgage (Golden West Financial, purchased by Wachovia in the best example yet of caveat emptor)do you feel any responsibilty at all for the housing meltdown? I sat thru several hard sales pitches on Option Arms to mortgage brokers by Mr Stevens. Who I thought was personally a very nice guy.

MadasHell: (February 22, 2010 9:22am)

I live next door to a BofA foreclosure thats been vacant for almost a year. No one comes by and why isn't it up for sale? I believe theres tons of these properties the bank is hanging on to so prices won't drop even more. I'm an appraiser who's looking for another job because HVCC has put me out of business. Another one bites the dust. I thought I could hang on until HR 4173 hopefully gets passed and I can get my own clients again and full fee back. Obama still wants to pass his Healthcare Bill so nothing else gets done. Consumer Protection Bill of 2009 might get passed by 2011 if we are lucky. I don't want to "sunset" the HVCC I want to bury it at the center of the earth and who ever started it.

Mark: (February 22, 2010 9:22am)

If it all goes back to the banks then they have created a monopoly and we then have legal right to sue for restraint of trade, unfair business and discrimination. WE cannot allow it to go to the banks as they already have too much control, make way too much money and they control the market and can dictate rates since there will be no competition and someone keeping the honest.

TX201: (February 22, 2010 9:21am)

Please ask the Commissioner why he is trying to model FHA after the two biggest failed companies in the industry? FNMA & Freddie Mac? If FHA is concerned about appraisal quality, go back to the rotation system that FHA used in the 90's. No AMC needed there. And if seller contribution and lack of skin in the game is an issue for quality mortgages, please ask the commissioner why VA, with 100% financing and allows the seller to pay all the costs for the buyer resulting in a $0 move in, is not having the problems that the rest of the industry is experiencing? Could it be that VA did not participate in sub prime finacing (FNMA & Freddie) and could it be that VA was not forced to participate in refinancing those bad loans? (FHA). Wouldn't the obvious conclusion be that more government control and regulation is not the answer???????

dd: (February 22, 2010 9:20am)

Appraisers are supposed to be reporting the market, not making the market. When appraisers low ball, especially when it is for a sale, they are literally making a bad situation worse and driving down property values. Who benefits from low property values? The federal government because lower values means less write off on interest on the tax return. What a way to increase taxes without legislating. Short sales are another way for the lenders to get all kinds of information that can be used against the borrower. Same thing for loan modification. What would really work would be a mortgage strike. Don't pay, just say nay. If only 40% of homeowners joined in, the banking industry would implode with the weight of past due mortgages. Perhaps we need to look to our neighbor to the north. Canada has a regulated banking industry and homeowners pay their mortgages to the government that backs the loans. Anyone want to comment on how that works?

Anonymous: (February 22, 2010 9:18am)

It seems like that they dont want brokers period. They want it all to go back to the banks where LO's will be salaried and then they have control.

TheBigEasy: (February 22, 2010 9:18am)

I'm on my way to DC. Will arrive tomorrow the 23rd. Where is the meeting?

Folsom Realtor: (February 22, 2010 9:16am)

Would you ask about the various banks lack of progress processing short w/excuses of missing paperwork, assignment of negotiators and unwillingness to give agents a name & number to call to get some answers. I have had a short sale with Chase for over 4 months and they ordered the BPO's and told me 3 times they had everything and would have the negotiator call me within 48 hrs. 2 weeks ago they cancelled it and said it had missing documents. I asked which because I have proof they received the 138 pages and they said their opener misfiled the paperwork and I would have to resend the entire pkg. They agreed to print out the pkg and deliver it to short sale to re-open but I'm afraid by the time they do that the buyer will walk. Are they deliberately waiting until they get past the 120days so the sellers end up with a foreclosure on their credit instead of pushing it through? I understand any sale after 120days shows up as a foreclosure.

sus socal appraiser: (February 22, 2010 9:10am)

I joined the newly formed Calif Coalition of App Prof on Sunday in Reseda, Ca - at a "Townhall Meeting". We had signs & handed out flyers, the local CSUN paper reporter asked us questions & took photo's, local RE agents & even the opposing Canidate who was campainging.. "person" approached us & wanted to join us at any of our future "Rallies". Borrowers may be our Best Voice..if we can get them to realize that the "Appraisal Fee...is 50+% a Managment fee".... Local Officials will be interested in the amount of Local Income being removed due to these Management Fee's... additional uncounted unemployed...... We Appraisers Need to Get off our "blog's" and get out and Get our Message out.... Editorials, articles in the local papers, go to City meetings....... check out the California Coalition of Appraisal Professional on FaceBook...web page in process...thanks Dave & Carrie for getting started

Escrow Queen: (February 22, 2010 9:00am)

In California, maybe other states as well, we seem to go back and forth with short sales being what the banks (sellers) want vs. foreclosures. Middle to End of 2009 was more short sale activity and almost no reo's being listed. Now it appears something has changed and the banks have found a loop hole and are leaning towards foreclosing and "gearing up" to release reo's rather than working out short sales as many recent rejections of short sales are making no sense. Did they find a loop hole that it is more beneficial for the banks to foreclose rather than work out short sales?

SimpleSolution: (February 22, 2010 8:58am)

struggling Appraiser-Exactly! The AMC fees should be listed right there with title, escrow, processing and all of the other closing cost fees. I has and never will make sense to me why it wasn't done that way in the first place. It is written everywhere that appraisal fees should be seperate and an AMC fee is not an appraisal fee. It is a fee paid to order an appraisal.

G-Appraiser: (February 22, 2010 8:58am)

Is there a Guild set up in California yet? I would like to join and help with the forthcoming movement. Is there a particular contact person?

Charlie: (February 22, 2010 8:57am)

PLEASE,PLEASE,PLEASE ask them to eliminate the amc rules immediately. I am at the end of my rope. I cannot pay all of my obligations this month. And I can not run to my grown children for help. I am 73 years old and I have to start all over again.

NBSK: (February 22, 2010 8:55am)

For those who may be considering starting a net branch (or thinking of switching co's), this free 'net branch survival kit' is very useful. It outlines the 25 questions you should ask a prospective net branch company, and includes some minimum expectations that you should have. It's free and very detailed, so I wanted to pass it along to the group so everyone can benefit from it. If you want a copy, get it for free at net branch survival kit. com

BrokeAppraiser: (February 22, 2010 8:53am)

Congrats Frank and Brian for making the front page of the Sacramento Bee on Sunday over the daily show on the IndyMac/FDIC issue. We need MORE publicity about the HVCC and ALL the issues going on with the corrupt banking system. Contact the journalist, Jim Wasserman, at [email protected] with your stories and maybe we can get these issues addressed "above the fold" on the first page!! Most consumers don't have a clue what is going on with the HVCC unless they have recently done a purchase or refinance. Let's get the word out and put pressure on the powers that be with a grass roots movement by the people, for the people.

Mark: (February 22, 2010 8:53am)

WE have to work on the YSP. In the documents pfovided by Marc Savitt to Senators about the YSP issue, he proves that BRokers disclose their income but Banks dont have to. In a 200,000 deal, a bank made $12,000 in income. You know darn well a Broker didn't make that. Brokers are capped so there is no more raping of borrowers - at least that is what the Senators are calling it.

Carlos Sutter: (February 22, 2010 8:53am)

Hey, TINK. 2 things for you: 1) President Obama is the President of the United States. Period. It's a fact. Don't you think that if there would have been ANY problem with his citizenship Hillary would have been all over it? 2) I am sorry to tell you also that ELVIS IS DEAD. Move on.

sus socalappraiser: (February 22, 2010 8:50am)

FHA Questions 1. if the Appraisal Assignment is NOT from a non-commissioned staff member in the LO/Brokers office.. a. does the FHA have a List of "Qualified AMC's" that meet FHA guidelines for appraiser assignments? So Appraisers can sign up? b. Does FHA have a "guideline/standard price fee" for the Management Co charge per appraisal assignment? c. Where do the AMC's get the "Standard Fee for Appraisals Assignments in the Local Market" data? & Where is this Price Sheet for all of us to see? d. Where on the new GFE 2010 is the Breakdown for Appraiser Fee & Management Fee...so the borrower can see where their money is going? e. How does the LO/Broker know how much to charge for the Appraisal/AMC....is this part of the 3 day waiting period b/4 the appraiser is assigned f. The AMC's CHARGE the BORROWER First..then assign the appraiser... the appraiser has no control over any of the FEE's g. Can the Borrower SHOP for a Better Appraiser Fee/Lower Management Fee???

Jen: (February 22, 2010 8:49am)

Not an appraiser, but in the business for 30 years. It's sad that my honest relationships with seasoned appraisers has been stripped from my business. All but a handful of appraisal reports have come in low since HVCC was enacted. I feel like you better not take on a property for a refi if it doesn't have wiggle room in the equity. One came in over value due to appraiser error. He drove over 2 hours to appraise my client's home and did'nt know the area at all. He used comps from an area that always sells higher without any location adjustments. I have had some extremely negligent mistakes on many of my reports and there is NO quick recourse in place to correct the problem. Some lenders don't seem to care about "fixing" the problems or receiving competent work. I get the feeling if the appraisals are low balled in value, they are happy about that. I had one lender ask for an add'l $300 for a review of a bad report. I provided them with all the proof it was in error. Ridiculous process.

struggling Appraiser: (February 22, 2010 8:47am)

That is the way it should be. This question has been asked over and over again. "why do the appraisers have to pay for a third party fee". Tite and ecrow do not have to pay a fee to a third party group.

D: (February 22, 2010 8:45am)

The most important issue has to be YSP and broker income. As long as we are allowed to have income, we can continue to work with or work around the other items. If YSP and/or broker income is cut, we are done instantly.

Carlos Sutter: (February 22, 2010 8:43am)

Getting offers accepted is my number 1 problem. I have plenty of qualified borrowers home shopping. Yes, appraisals can sometimes get in the way of closing a deal, but by far, the problem is even getting to that point: getting my borrowers' many offers to be accepted.

lendershop: (February 22, 2010 8:40am)

Anatru: you are right. Here in CT the licensing system of pulling credit has already been implemented and I know 2 close friends that have already lost their " right " to earn a living due to credit history. These were 2 loan officers that spent most of their day helping people refi out of their adjustable rate mortages to avoid foreclosure.

SimpleSolution: (February 22, 2010 8:38am)

Does anyone know why the AMC fees can't be rolled into the closing costs just as everything else is?

Central Valley: (February 22, 2010 8:34am)

The FHALoanGuy - I was told the same thing directly by and executive for Q/C at FreddieMac....... Low value = Quality Reports

Lender Who Knows Better: (February 22, 2010 8:30am)

Equity lines should work with borrowers. There are BK 7 & 13 judges have no problem striping 2nds off homes.

anatru: (February 22, 2010 8:28am)

HVCC is certainly a huge mess that must be reversed. But there is another issue that concerns me even more... the national licensing requirements that have a May deadline. Did you know that they intend to run your credit report before they'll issue you a license... and that a bad score or lates can keep you from getting the new license, without which you have no more career? Yes folks, if you have some credit problems, then you may not be able to get the national license. Since most of us LOs have lost huge amounts of income in the past 2 years, I'll bet that there are many LO's who may have lates. Those in this situation stand to potentially lose their ability to do loans at all, forcing more out of work. To date there is no set guideline as to what credit factors will result in a license denial, nor whether there is any recourse if a bad decision is made. Just my opinion, but this is something that should be addressed now...before May arrives.

TheFHAloanguy: (February 22, 2010 8:27am)

HVCC will always lowball appraisals because the lender is risk adverse. http://www.everettmortgageonline.com/new-appraisal-rules-lowball-homes-for-sale-in-everett my blog entry is 3 minutes to read.

billybob: (February 22, 2010 8:21am)

yes they should let the appraiser still collect at the door and the AMC fee paid separate by broker or lender the AMC collects our money and who knows maybe they gamble with it for 30 or 45 days then we might get paid or stuck this is crazy

SimpleSolution: (February 22, 2010 8:13am)

A Appraiser-I completely agree with you. The banks should be paying the AMC fees. Not the appraisers. The AMC's need us. We don't need them and it is the banks that are making us go through the AMC's. It is as if we are being punished for their bad loan decisions.

A Appraiser: (February 22, 2010 8:10am)

Questions regarding 2009-28: As per 2009-28 payment of fees for the third party and the appraiser must be seprate. The borrower can pay both parties. Does this mean the appraiser can collect at the door? And why is the borrower once again getting stuck with a senseless fee that is clearly for benefit of the bank? Why once again is the bank the protected asset? Why are the banks not made to pay the fee for the service they find so necessary? Why is 2009-28 so vague allowing AMC's to clearly twist the new reg. and contiune control over the appraiser.

5pence: (February 22, 2010 8:02am)

FHA can set fees. They need to set fees at $450-$600 per appraisal to protect the consumer. That is less than the amc's get. Problem is the amc's will not bother with FHA work if they can't steal enough money from us and the consumer. FHA will hve to bend to amc rules if they want to increase business. So either FHA does the right thing to protect the consumer or they do the wrong thing and we and the consumer and the economy get screwed again by these financial terrorists that have this country in bondage with the ransom being all the wealth and abundance of this great nation. It makes me sick.

Appraisal hell: (February 22, 2010 8:00am)

Another thing that has flown under the radar is the way the AMC's "supposedly" send out order to several appraisers at the same time...Yet 30 seconds later it is gone. Who is getting all these orders? Or are they going to the "buddies" of the AMC company. Someone is getting fat off this. I have been approved with companies since May and never gotten an order, how is that "round robin"? Another item is how the customer pays upfront for the appraisal and 8 weeks later, I am still waiting for my money. When I call to beg for it, I am bothering them and jeopardizing my status?

5pence: (February 22, 2010 7:55am)

Thanks mtggirl : Yeah, if FHA wanted to stay above board why don't they first insist that the HVCC go through due process of law to ensure it's not hurting the consumer? We know that if it went through due process it would be killed. Still FHA isn't in conservatorship and doesn't need to be under the HVCC like the GSE's. So why choose to be willingly under the umbrella of an illegal policy? We have 120k signatures saying it's hurting the consumer and they're ignoring that. Anyone operating under that umbrella of the illegal HVCC are criminals imo, so why does FHA want to join in? They need to set fees at $450-$500 per appraisal if they want protect the consumer.

AppraisernearLAX: (February 22, 2010 7:47am)

I have signed petitions, written letter to my representatives and shouted from the highest mountain tops. When is something going to be done? I need to be able to compete and earn a decent fee. HELP!

mtggirl: (February 22, 2010 7:45am)

5pence, great question, lets see if they can answer it.

5pence: (February 22, 2010 7:43am)

I want to know why FHA wants to throw in with an illegal policy - the HVCC. Apparently they want to join with the other unlimited bailout companies and be considered 1 with them. Now why is that? How can FHA ignore the problems that HVCC has created? JustFrank : There are already lwsuits going on but because the GSE's are in conservatorship, no one can challenge their policies. The government is backing that up. I noticed over the weekend that Obama again blamed loose lending standards and people gaming the system but he forgot to mention appraisers. Are we not to be talked about? Like speak no ill of the dead? Of course it was 100% the banksters fault. They wanted to lend me $75k on my post office box! Financial terrorists that need to be declared war on and not coddled and spoon fed until they burst, again.

Just Joe: (February 22, 2010 7:42am)

wantoknow. Here is a program that you can check out:http://bit.ly/9ancLf. Also, congrats, guys, on getting some major ink in the Sacramento Bee on Sunday. Your efforts ARE making a difference. The article was posted in Sunday's edition and told about numerous lawsuits filed on behalf of borrowers who say they are being forced into foreclosure and that One West is non-responsive with borrowers that are trying to modify their loans.

Tink: (February 22, 2010 7:39am)

What happened to the http://www.youtube.com/watch?v=5FlEbBZLzo0 video about Obama's past and citizenship? Tried to go there. It said it had been removed... "This video has been removed by the user."

Struggling Appraiser: (February 22, 2010 7:38am)

I am with Simple Solution. The HVCC only benefits the AMC's. I work with a small AMC and they told me they have to charge a minimum of $100 per appraisal just to keep their doors open. They never said how many appraisals they order per day. A couple of weeks ago they sent out an e-mail saying there business was down from 40 to 50 appraisal 10 to 15. I understand there are business cost but that small AMC was making $4000 to $5000 per day. For a 20 day month that would equate to about $100,000 per month. Now, I wonder how many appraisals the bigger national AMC's are ordering per day. I am thinking it is into the hundereds and they usually charge double what the small AMC charges. This is while they cut the appraisal fees. I wonder if Andrew Cuomo has any steak in any of the AMC's Hmmmm!!

Old School Mortgage Banker: (February 22, 2010 7:36am)

Willy - Isakson was dead serious and got quite an ovation from the room full of Realtors he was addressing. He feels that the market approach is inaccurate and that a home should appriase for what it would take to rebuild it. All I can say is 'dream on'. I wish my home would appraise for what it would take to rebuild it!! But that's not to say that *maybe* lenders/underwriters shouldn't put a little more weight on cost approach and little less weight on market approach so that they can help us tax payers who bailed them out not so long ago

Old School Mortgage Banker: (February 22, 2010 7:32am)

nohype - GA SB57 is still a 'work in progress'. In its original form the words 'no person' may be paid a YSP or SRP and 'person' was defined as anyone and everyone corporations included. The GA Mortgage Bankers Assn is lobbying hard to get this toned down or reversed.

PA Appraiser: (February 22, 2010 7:31am)

I agree with justfrank101 !! I sometimes use the analogy that appraisers are now like migrant farm workers... we stand on the corner waiting for the Farmers truck to (The AMC's) pull up and dangle an assignment and says " who wants to work today for the lowest fee and take all of the liability ? " And there is always someone in the crowd who doesn't know what they're doing that will do it.

Freercw: (February 22, 2010 7:26am)

Why are they trying to implement the elimination of real Estate Investors from doing their own "owner financing", and elimination of private real estate investing all together? Could it be the New Worlds Order elimination of all private property agenda?

A Appraiser: (February 22, 2010 7:23am)

Some questions I have: Why is this type of change necessary? Is it not understood the appraisal industry had little to do with the current residential situation? (Appraisers were simply recording the demand created by the irresponsible lending and irresponsible loan products created to satisfy the demand for mortgage backed securities). Why would it be thought to be a good idea to model a regulation after a current regulation that has created such chaos? Why are the regulations affecting the industry directed at being so counter productive? Not only in terms damming up the home buying process but in creating job and revenue loss (all the while saying revenue and job loss is priority one)? Why is found to be necessary to intercede now that the damage has been done and banks are lending as they should, by actually qualifing borrowers? WHY IS THE TRUE PROBLEM NOT UNDERSTOOD? Frank and Brian: Your question for claification is HUGE!! I will be looking forward to the responce.

wantoknow: (February 22, 2010 7:21am)

Is anyone looking at what could be the new wave of foreclosure problems when the interest on HOME EQUITY loans adjust when the prime rate goes up? Most equity loans are low right now because of the prime rate. I went to B of A and ask if they would fix our rate for a few years to mitigate the problem in the future. They told me it would be 11% and would not negotiate. The rate at that time was below 5%. When we received the equity loan the house appraised for $425,000, the loan is for $356,000, and the house is worth $250,000. Bank of America is not interested in negotiating and in Arizona with a foreclosure on a home equity loan they get a deficiency judgement. Does anyone have any ideas?

clulessdad: (February 22, 2010 7:20am)

Isaakson implementing the cost approach MUST be pressure from the Home Builders. In many cases now, the price of a home is much lower than its cost. Reminds me when the Indiana legislature passed a law that forever more pi (you know your grade school circle constant) to not equal 3.1416, but 3.00000. LOL

justfrank101: (February 22, 2010 7:19am)

I am an Independent Appraiser accepting full responsibility for the Appraisal Reports I write. I take full responsibility for those I contract work. These were typical measures observing Appraiser Code of Conduct until the HVCC stepped in. I honestly believe a Class Action Lawsuit be established against the HVCC and the United States Government – forcing the Independent Appraiser into Prostitution. Appraisal Management Companies are nothing more than Pimps and we as the Professional Appraiser are given no choice but to work for the AMC accepting less than a full fee and still being solely responsible for all liability issues. Who stands with me? To whom may we count on for legal representation?

LivingInDC: (February 22, 2010 7:16am)

Am going to be roaming around the lobby of the Hyatt around 5:30 tonight... couldn't make the trip to NY the last time you were on this coast, but hope to be able to meet you this evening. While in town you MUST eat at the Cafe Mozart, a very small but awesome German place... www.cafemozartgermandeli.com they also have an extensive collection of European Scotch :)

clulessdad: (February 22, 2010 7:13am)

My big question? Why are they trying to get rid of mortgage brokers? 1) Why are bank LO's not required to take the Fed Safe Act test? 2)Why can a bank order an appraisal, albeit in a "back room," where I having gone thru all the testing,training, experience, fingerprinting and dues, cannot even order an appraisal? 3) Why do banks not have to disclose SRP, while brokers, whose compensation comes from a combination of YSP & SRP, have to disclose every $.01 of both? 4) Why hasn't HUD allowed non mini-eagle brokers to originate FHA loans, like Stevens promised? Why are they allowing all this to happen and reduce consumer choices? Trying to blame the mortgage broker for the housing mess is like blaming the customer service agents for selling 18 tickets on 9/11/2001.

nohype: (February 22, 2010 7:12am)

Several viewers have already commented on your GA SB57 (a bill that passed last year) coverage, and I too have researched this and have found nothing that indicates that YSP has been banned in GA. Something as big as this, I would assume you guys could provide a little more evidence as to it's merits, or at least a source. All public sources mention nothing about this. Can you guys clear this up?

SimpleSolution: (February 22, 2010 7:09am)

Frank & Brian-FHA already has a roster so please ask why they are going the HVCC route with AMC's rather than the VA route where they hold a roster of appraisers and the orders come from FHA directly with no cut out of the appraisers fee.

Willy: (February 22, 2010 7:08am)

OldSchoolMortgageBanker - Is Isakson serious? The cost approach? REALLY? That will simplify the heck out of everything!! We can just have the buyer/borrower supply us with receipts for the materials/labor....add it all up....and VOILA!! We have a value. We can replace appraisers with bookeepers and the HVCC will no longer apply.[heavy sarcasm intended]

MD MORTGAGE BROKER: (February 22, 2010 7:04am)

Please find out from HUD if it is still their intension to lower the seller help from 6% to 3% and if HUD still plans to increase the down payment from 3.5% to 5%. And if these things are to happen what is the time frame? Also, please pass on to HUD that if either one of these things happen it will have devastating effects on our already frail housing market and the economy will continue to suffer! In addition please ask HUD what is the deal with the appraisal ordering process?? I mean man for the love of GOD already enough is enough!!!

Common Sense: (February 22, 2010 6:54am)

Ezradams just pointed out the root of the problem. The bureaucrats and career politicians are creating rules regulating things they do not understand. I think they are regulating for the sake of regulating or at the very least so they can claim to have "done something". Sometimes it is better to do nothing. In this case, you all get it because you understand this business. Do you think government regulation of other industries is somehow better, or does it just sound good from our uniformed point of view? Do you think government regulation is even achieving it's own goals? MDIA, HVCC, HPML, RESPA, are they protecting the public or promoting the recovery of our industry? This is what conservatives have been telling you all along. Maybe it's time to listen.

Socal Appraisal Gal: (February 22, 2010 6:48am)

socalappraisalgal: I would like to ask Stevens who he in bed with and how much money he is making off driving the FHA to a middleman. All HUD appraisal employees that I have talked to thru the FHA connection and seminars I have attended stated they had no input in his decision. The appraisers running each hud/fha office across the nation should have been consulted and allowed to put their input into his decision.

Bear in TX: (February 22, 2010 6:45am)

ezradams, Jonny Isaakson is a total putz, on the same level as Barney Frank. That A-hole worked a $15K tax credit into the stimulus bill last year. He even got Dems to rescind the need to pay back the original $7500 tax credit. When he refused to vote for the bill, the credit language got shredded so Olympia Snowe could reduce the amount of the bill to feel like she did something for once in her life. Total jackass...

PA Appraiser: (February 22, 2010 6:43am)

The HVCC has proven not to solve anything. If anything the situation has gotten worse. JeffinABQ is complaining of lower values, if the market is declining because of the short sales and foreclosures, it's declining. It is what it is.. but when AMC's hire inferior appraisers because of the low fees just to line their own pockets that is the real crime here. The only thing the HVCC has provided is the promotion of AMC's and the end of Small business owners.The Obama Administration advocates Small Business is the core to the economic recovery. Most Appraisers are Small Businesses. How can the small appraisal companies hire or even keep existing office people with the reduced fees when companies have the same expenses? what is wrong with that picture ? This is why appraisers are organizing with the Appraisers Guild. It's going to be the Teamsters of the Appraiser Profession.

Las Vegas Market #1 Foreclosure Rate: (February 22, 2010 6:42am)

Making Home Afforable Program is ALMOST a good program. Ask them why they won't regulate the banks to not only lower and/or lock the interest rates in but MODIFY/LOWER the negative equity as well to market value. The percentage rate of homeowners not walking from that negative would sure change the outcome of foreclosures and short sales. WHY NOT? It makes sense!

LivingInDC: (February 22, 2010 6:38am)

I am going to an event at the New Zeland Embassy tonight... will leave the safety of Northen Virginia to cross the Potomac early to try and meet you guys. Where are you going to be exactly? Would love to meet the "Left Coasters" I watch on the computer everyday... Too bad you came during the Olympic break, I would have taken you to a Caps game :)

Stu: (February 22, 2010 6:35am)

Why can't lenders give GFE before any offers are written so they really can shop the loan as HUD wanted it to be.

willie G: (February 22, 2010 6:31am)

Respa2010 gfe..How about the lender gurantees their fees and the rates and points and the TITLE co guarantees the recordation and transfer taxes and their fees...The title compaies are most familiarwith the various county recoding intricasies, and this simple change would make the most sense and do what HUD really intended to do. The lenders should not be forced to be on the hook for anything but "THEIR" lender fees, points and interest rates

billybob: (February 22, 2010 6:24am)

thats it a HOTLINE because as of now who do you complain to ???? this would be good for the customer also I heard not sure if it is true but if a person pays for an appraisal and the bank that is used does not accept the loan for some reason( even if value is good )---in order to go to a different bank they have to pay for another appraisal to get around same value

syracuseappraiserguy: (February 22, 2010 6:17am)

There needs to be a hotline # established for appraisers to be able to call and report AMC's not paying the customary fee's (APPRAISERS are the ones who should set customary fee's not the AMC's). Prior to AMC's, appraisers were paid $300-$550 for FHA single family appraisals, now post AMC...1/2 that

Ezradams: (February 22, 2010 6:11am)

Senator Johnny Isakson of GA thinks we should base our valuations on the "Cost Approach"...is he nuts? Sure, on a newer improvement in an area where sites are available, this may work. How about the other 90% of properties in my area that are at least 40 years old in built-out cities. The guy must be drinking somebody's Koolaid!

Topdog1: (February 22, 2010 5:59am)

Let's see some discussion on the difference between YSP & SRP. Lenders do not have to show the SRP as an origination charge and then credit it back. Unfair and lacking in transparency in my opinion.

Gnotboxchecker: (February 22, 2010 5:56am)

Wow! Truth revealed the naked green screen and those Home Depot shop lights. That is really being good stewards of the cash flow. Good job.

Frost: (February 22, 2010 5:54am)

Parity Steeds Off Foreclosures – Hope For Homeowners (H4H) Provides Parity Parity between home values and their mortgages is the only way to stem the onslaught of foreclosures. An Answer Already In Place - FDIC Chairman Shiella Bair was a catalyst behind July 2008 legislation directed at saving 400,000 homes from foreclosure through a FHA refinance program currently known as the Hope For Homeowners (H4H). We now estimate that it could save 1.1 million homes from foreclosure...Obama Administration announces new details on Making Home Affordable Program, April 28, 2009 - HUD TG-108). Modifications were signed into law on May 20, 2009. Retired Senator Martinez (former HUD Secretary) and Business were prompted to look into why HUD was not getting this funded program right and why lenders were not participating. The pointed questions prompted HUD's backdated final(?) Mortgagee Letter 2009-43 dated October 20, 2009. see full text and references www.REvelop.org/NAMB-H4H.doc

kdwall: (February 22, 2010 5:45am)

How about getting clarification on when the new financial standards for FHA approval are going into place. I.e. the 1M net worth then opening up FHA to all brokers through those FHA approved lenders.

Outofbusiness: (February 22, 2010 5:33am)

Be sure to PUSH the question about FHA & AMC orders.

billybob: (February 22, 2010 5:13am)

hey guys nice to hear finally something about the appraisers and HVCC main thing is that we get paid what we have been so we could stay in business. AMCs talk about monet for nothing are they going to help us with all the fees we have to pay throughout the year. sick of hearing about guys in business for years and now they might as well close up.

Old School Mortgage Banker: (February 22, 2010 5:10am)

Hey Guys, I recently had lunch with Senator Johnny Isakson of GA. He is/was one of the key proponents of the "all saving" tax credit. Don't know if that helps or hurt his 'cred'. Nonetheless he's a key Washington figure on all things housing. His main push in Congress now is appraisal reform!! His approach is that more emphasis should be placed on the cost approach given that the market is still out of whack and thus the market approach is not a effective an indicator of a home's true value. As a result of his comments, I think you'll be able to get some people's attention on the appraisal related front while at the convention. Go get 'em for us!

Tim: (February 22, 2010 5:05am)

Regarding HVCC, I think it should be mandatory that the AMC discloses what they are paying the appraiser. "strugglingappraiser" below is right, AMC's don't have to answer to anybody. We've caught one of our AMC's in outright lies and nothing happens. Their policy is that any property valued over $600k costs about $200 more because "that's what the appraisers charge." Then after the fact, we talk to the appraiser and they say they charged the same as a normal appraisal and they didn't receive any more from the AMC. It's a joke.

MakoKris: (February 22, 2010 5:02am)

What FHA has failed to understand is that while their appraisal ordering requirements, while not exactly like HVCC, have had the same implementation of HVCC. The fees have not changed to "customary" and it is low bidder from wherever. Getting REAL close to closing the doors as $200 is easier earned in some other industry without the 5 years of liability.

JeffinABQ: (February 22, 2010 4:59am)

I recently posed this question on the HUD Facebook page......maybe you'll have better luck getting a straight answer............does HUD have any control over appraisal guidelines? HVCC, while irritating, is acceptable!...don't get me wrong, but we, like most of the country, are having issues with values coming in even remotely close to where they should be. I thihk the problem stems mostly from Comparable Sales. The Appraisers seem to be using ... See Moresales of foreclosed properties that were obtained at a GREATLY reduced price from Banks, not even reflecting the actual worth of the property.....not to mention destroying what value people who are still in their homes have left. It's unfair to everyone! Can you not implement something with the AMC's to curb the use of "Foreclosed Sales" when doing their Valuations? The Government wants to help the housing market, yet things such as this are doing nothing except making it worse, and making it harder for well qualified borrowers to even remain in their homes, or as you put it, and I quote "the single greatest purchase of their lives".

Puzzled: (February 22, 2010 4:38am)

What does FHA think they are going to resolve ? If the states don’t have the money for personnel to enforce the current laws and regulations for appraisers, then maybe some of the money is being spent on implementing this version of the HVCC or an across the board nominal “policing “ fee ( maybe $100 / per loan) could be charged on each loan to help fund the Appraisal Boards to enforce the laws and regulations already on the books. Maybe if Skippy knows the State Appraisal Boards will be looking harder at his / her reports and if caught will lose their license and face jail time / fines. Why are they going along with a bad idea and making it worse for the CONSUMERS ? The Appraiser is being paid $195 from an AMC is going to take the easiest route to slam 3 comps on the grid, not really do an analysis of the market ( That they are not even familiar with) and not give an accurate opinion of value. There is a saying “ YOU GET WHAT YOU PAY FOR “ !!

strugglingexperiencedgaappraiser: (February 22, 2010 4:14am)

As someone who tried to do a loan modification - this is a total joke - millions of applications - how many have they modified - and most only to very low income with NO REGARD TO HOME VALUE - this only adds fuel to the fire to recreate this entire situation over again - and another way for the government thru fannie, freddie and fha to end up owning majority of properties in the long run. Banks need to actually answer to the programs and restructure the existing loans to keep homeowners - especially out of work homeowners trying to hang on - for a few years - if they can offer interest only loans for self employed - they can offer interest only loans to help people keep their homes in times of high unemployment. Homeowners cannot control losing their employment or underemployment in my case--especially when you are still current.

strugglingexperiencedgaappraiser: (February 22, 2010 4:07am)

We as appraisers also to "follow" the HVCC while the AMC's report to no one. How do we even know there is a rotation process? AMC's do not have to disclose any information to us. Why are they not held to similar standards with regard to "average fees" - at least a number of appraisers on any given panel in any given market area? We are required to provide all sort of personal and business information - yet all we have for them is an email address and maybe an 800 number - many times there on sites there isn't even a way for us to openly ask questions about an assignement or request information needed to do the job. Yet we can be removed for any number of arbitrary reasons - ie not meeting a 48 hour turn time - even over weekends. It's not a two way street - it's all aimed at us and in the favor of the lenders. It all works to the detriment of the consumer in the final analysis - you get what you pay for.

Bobby: (February 22, 2010 4:04am)

Please someone get tell the almighty wizard at FHA to not follow or copy the HVCC rule. They make changes to help make mortgages legitamit but its a rediculous move because it just kills legitamit deals when an appraiser from 1 hour away comes out and kills the deal with no knowledge of the area. Its even more rediculous when you realize that the reason for the entire mortgage meltdown was because of Wall Street not mortgage brokers or appraisers

Valuequestor: (February 22, 2010 3:45am)

You might ask Secretary Stevens why after 22 years as a FHA Panel, Direct Endorsement and FHA Roster appraiser with no problems or issues with HUD I no longer receive FHA appraisal orders. I'll give the answer. Its because I still do my job while around me appraisers from outside my county breeze in and find no problems with REO properties in need of structural repairs, bad plumbing, electrical problems, roofs and chipping paint on pre 1978 homes. I won't do the appraisal for $200 and turn it around in 24 hours.

Valuequestor: (February 22, 2010 3:31am)

Hello Fellas. I would like you to ask Assstant Secretary Stevens to take a more proactive role in securing a minimum reasonable and customary fee to the appraiser for each county in the country. Please stress to him that without quick action the US is going to be relying on inexperienced, easily misled and influenced appraisers. The appraisers that are currently the "preferred vendors" of the AMCs. Fast and Cheap at the expense of quality and accuracy. The most recent data shows that mortgage fraud is way up. Without a reasonable professional wage, experienced, ethical appraisers are going to be a rare commodity. Its time for HUD to take real action.

Sam Shile: (February 22, 2010 3:06am)

If we are to have a regulation, It has to be without hurting our ability to produce income. How do we compete on a rotation system?