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HVCC or FHA (new rules)Compliant Ordering Options:
(Use these options to retain your own appraisal panel and not pay extra fees to AMC's. These options let the appraiser get paid properly for their work and does not cost you or your clients extra money that would go to AMC's for order taking. In fact, typically using these solutions will be cheaper than going through AMC's, Provide higher quality reports, provide faster turn-times, keep you in control, and cost less.)
If you're a mortgage loan officer or a mortgage broker who isn't allowed to order appraisals directly from an individual appraiser and are seeking an HVCC-compliant appraisal ordering system or service, I recommend using the Mercury Network for ordering HVCC-compliant appraisals. I'm already registered on Mercury Network, and it's the fastest, most compliant and effective way to order appraisals from me or any appraiser without overhauling your entire appraisal ordering process.
Because I'm already a Mercury Network member, after you complete your own Mercury Network profile, you can add me to your appraiser panel, if you choose to. Mercury Network's Intelligent Selection System (ISS) enables you to order appraisals "blind", based on pre-set ordering criteria so you can be confident you're ordering appraisals with complete HVCC-compliance. You'll also appreciate Mercury Network's pre-populated status message and text box-driven communications which provide you with an audit trail for each transaction. To order using Mercury Network, click here .
Appraisal Port Users (option 2)
Capuano Appraisal Services currently subscribes to the FNC Appraisal Port Portal. Please add us as one of your approved appraisers. Just e-mail your registration key and we will add you to our client list.
FHA Appraisal Ordering
Use any HVCC compliant ordering process. The ones above are good options with very low costs. Read the Myths about HVCC to see other ordering options that are in compliance. The use of AMC's is in no way required by HVCC and can end up costing you and your clients more money for lower quality reports.
AMC Appraisal Ordering
Capuano Appraisal Services is happy to work with your appraisal management team or with your AMC! Please add us to your fee panel and you can receive high quality appraisals today! We only work with high quality AMC's that pay fair market value for appraisals. If your fees are below market and you work with the cheapest least expensive appraisers, please do not contact us. Thank you.
Home Valuation Code of Conduct
Myths and Realities
http://www.fhfa.gov/webfiles/277/HVCC122308.pdf
The release of the Home Valuation Code of Conduct has raised many questions on the part of lenders, appraisers, and others involved in mortgage lending activities. Lenders that sell loans to Fannie Mae or Freddie Mac are likely reviewing their internal appraisal operations, and some may have to retool or restructure their operations to achieve compliance.
Unfortunately, there is confusion and misinformation in the marketplace regarding HVCC compliance and appraisal policies in general, particularly in regard to use of third party vendor management firms. To help bring clarity to these issues, the information below is intended to identify some of the myths we have identified and state the reality. There will likely be additional questions on this issue in the coming weeks and months. For further information, please contact: insidethebeltway@appraisalinstitute.org.
Myth: The HVCC requires lenders to use Appraisal Management Companies.
Reality : Use of appraisal management companies is not required under the Home Valuation Code of Conduct (HVCC). Lenders may engage appraisers directly without the use of third parties.
Myth: Mortgage sellers cannot achieve compliance without outsourcing the appraisal function.
Reality: Sellers may achieve compliance by establishing meaningful risk management practices, including separation between risk management (appraisal) and loan production. The Code requires that loan production staff not be involved in ordering the appraisal. This separation is currently required under existing federal bank regulation.
Myth: "Loan Correspondents" or "correspondent lenders" are the same as mortgage brokers and they too cannot order appraisals.
Reality: Unlike mortgage brokers, loan correspondents fund loans in their own name and, therefore, have "skin in the game." They are allowed to order appraisals on loans sold to Fannie Mae and Freddie Mac like other sellers that fund loans in their own name or with their own funds. Mortgage brokers no longer will be able to engage real estate appraisers directly.
Myth: Sellers cannot maintain the appraisal function internally (as an in-house operation), without loan production involvement.
Reality: There are several ways in which sellers may staff appraisal functions internally without outsourcing the function to a third party, so long as they maintain separation between risk management functions and loan production staff. To achieve compliance the appraisal function should report to an individual or department outside of loan production. Some examples of eligible individuals or entities within institutions include, but are not limited to, the following:
the risk management department,
the credit department,
the consumer lending department (with no loan production responsibilities),
the compliance office, or
the chief executive office.
For many institutions, the HVCC will not require any changes. However, whether the appraisal function is a fully staffed appraisal department or an individual assigned with the appraisal responsibility, the function can be maintained internally where the reporting line is to someone other than loan production (e.g., any of the entities listed above). Sellers also should make sure that their policies are in compliance with any applicable federal bank regulatory policies by contacting their appropriate bank regulatory agency.
Myth: Loan Production staff is prohibited from communicating with appraisers.
Reality: Loan production staff may communicate with the appraisers, but they cannot be involved in selecting, retaining, recommending or influencing the selection of any appraiser for a particular appraisal assignment. Further, loan production staff cannot have any "substantive communications with an appraiser or appraisal management company relating to or having an impact on valuation, including ordering or managing an appraisal assignment."
Myth: Outsourcing appraisal functions to an appraisal management company can reduce costs.
Reality: Given the diversity in the size and structure of lending institutions, it is difficult to conclude that outsourcing necessarily will reduce costs. Lenders incur costs for appraisal risk management whether done in-house or outsourced. Lenders should consider all the costs of compliance, including the costs associated with ensuring appraiser competence and appraisal quality, before making a decision to outsource their risk management functions.
Myth: Outsourcing appraisal management to a third party reduces lender risk.
Reality: Federal bank regulatory agencies have cautioned against reliance on third-party relationships by reaffirming that such relationships may significantly increase a bank’s risk profile, notably its strategic, reputation, compliance and transaction risks1. According to federal banking guidelines, "Increased risk most often arises from poor planning, oversight and control on the part of the bank and inferior performance or service on the part of the third party, and may result in legal costs or loss of business. To control these risks, management and the board must exercise appropriate due diligence prior to entering the third-party relationship and effective oversight and controls afterward."
Myth: Use of third party vendors ensures the use of competent appraisers.
Reality: Lenders traditionally have been responsible for ensuring the competency of the appraisers and reliability of the appraisals they use for credit decisions. However, the competency of an appraiser is not measured by scoring compliance with seller servicer guidelines. Processing appraisal orders is a separate function that does not specifically include a review of competency. The function of competency review is best performed by individuals with significant education in appraisal standards and theory.
Further, institutions should consider any potential reductions in quality that might result from outsourcing the appraisal function. To this point, federal bank regulatory agencies recently reminded institutions to consider an appraiser’s competency for any given appraisal assignment.2
Myth: The licensing of an appraiser ensures his or her competency.
Reality: Licensing does not necessarily ensure the competency of an appraiser. The Fannie Mae and Freddie Mac Selling Guides require lenders to review the appraiser’s education and experience. Specifically, the Fannie Mae Selling Guides state:
"A lender must not assume—simply based on the fact that an appraiser is state-licensed or state-certified—that the appraiser is qualified and knowledgeable about a market area or is aware of the appropriate market data sources for the area and will be able to obtain access to them. If an appraiser is not knowledgeable about a particular location, is not experienced in appraising a particular type of property, or is not familiar with (or does not have access to) the appropriate data sources, a lender should not give the appraiser assignments in that market area or for that particular type of property." 3
Myth: Professional appraisal designations cannot be used when evaluating the qualifications, education and experience of an appraiser.
Reality: The Fannie Mae Selling Guides state that designations may be helpful in evaluating an appraiser's qualifications, particularly when the designation is from a nationally recognized organization. Specifically, the Fannie Mae Selling Guide states:
"Professional appraisal designations can be helpful to the lender in evaluating an appraiser’s qualifications, particularly when the designation is from a nationally recognized organization that has formal experience, education, and ethics requirements that are strongly administered. If the lender considers an appraisal designation in its evaluation, it should be familiar with the appraisal organization’s specific requirements to ensure that the designation is evaluated appropriately." 4
Myth: "Comp checks" which are prohibited under the HVCC without an engaged appraisal assignment are the only way to determine if there is sufficient value in the collateral before proceeding with a loan application.
Reality: Lenders often want to know if there is sufficient value in the collateral before proceeding with a loan application. To determine this in the past, lenders and brokers would request "comp checks" of the appraiser. The HVCC bars lenders from ordering "comp checks" without engaging an appraiser in an appraisal assignment. Lenders may engage appraisers in appraisal assignments that involve a scope of work that is significantly narrow. For example, the appraiser could provide an answer to the question "is the property worth at least $XX" or "is it within a certain range," rather than a single point value estimate? This still would be an appraisal; the appraiser would need to complete the necessary research and analysis to answer such a question, and would have to document that analysis properly. Alternatively, the appraiser could be engaged in a consulting assignment to provide raw data to the client to help with their analysis.
HVCC (Home Valuation Code of Conduct)
Fannie Mae's New From 1004MC
Important things to know when ordering;
1. Form 1004MC will be required after April 1st 2009.
2. Sales contracts must be provided with appraisal orders starting January 1st 2009.
HVCC FAQ https://www.efanniemae.com/sf/guides/ssg/relatedsellinginfo/appcode/pdf/hvccfaqs.pdf
HVCC Presentation
http://fanniemae.articulate-online.com/p/7778743881/DocumentViewRouter.ashx?Cust=77787&DocumentID=8c52a13c-6bbc-4cfa-9594-cab11a890869&Popped=True&InitialPage=player.html
New Fannie Market conditions form (11/08) https://www.efanniemae.com/sf/guides/ssg/annltrs/pdf/2008/0830.pdf
FAQs on the new form https://www.efanniemae.com/sf/formsdocs/forms/pdf/sellingtrans/appraisalfaqs.pdf
FHA links
- FHA appraisers’ home page - Go here for all your questions!! http://www.hud.gov/groups/appraisers.cfm
- Main FHA link for documents, handbooks, updates, etc. - http://www.hud.gov/offices/adm/hudclips/index.cfm . Read the Manual 4150.2 and mortgagee letters 2005-34 and 2005-48, for details. Appraisers should review the "valuation protocol" found in Appendix D of Handbook 4150.2. Search for the documents by number.
Last month Fannie Mae released a Market Conditions Addendum to the Appraisal Report (Form 1004MC) as part of Announcement 08-30. The form will be required with all appraisals of one-to-four unit properties effective April 1, 2009. According to Fannie, the form provides appraisers with a structured format to report the data and to more easily identify current market trends and conditions. Announcement 08-30 includes new and updated policies regarding the use of supervisory appraisers, the requirement to provide the sales contract to the appraiser and the selection of comparable sales. It provides clarification on the research and reporting of current and prior listings of the subject property, appraising the entire site of a property, time adjustments, verification of sales transactions, neighborhood boundaries and the selection of comps and more. You can find Announcement 08-30 which contains Form 1004MC at WorkingRE.com, Sidebar; Fannie Mae Announcement 08-30.
Go to http://www.freddiemac.com/singlefamily/docs/030308_valuationcodeofconduct.pdf for the Full HVCC Guildlines.
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