By: Michael F. Ford

Michael F. Ford — Fri, 23 Sep 2011 13:00:00 +0000

Good effort Steve. It is appreciated. I hope Congressman Frank is able to do something. HVCC has destroyed our industry. It’s not just the fees. It is also the gap in communication and information gathering that exists now. In ‘the old days’, contrary to the inferences of HVCC, it was very helpful to communicate with the bank to understand the intended use of the report, and where a sale transaction existed, to insure proper follow up in getting copies of the contract so that they could be analyzed to determine if non market incentives or concessions were present. It also helped to disclose variances in public records and what the owners knew (“It was a two bedroom when I bought it, but we added 1,200/sf for two more bedrooms and two more baths, with permits). Like so many things, the efforts at micro management created lower quality across the board, rather than fixing problems. Now, lenders get ONLY the bottom of the barrel appraisers, OR appraisers very upset over being forced to work so cheaply in order to feed their families. Almost zero ‘extra effort’ takes place today. FIRREA had all the protections ended. The only problem is that it was never fully followed.

Anyway, your efforts, and those of the Congressman are sincerely appreciated. I’d recommend the Congressman replace wording after reasonable and customary to the effect that FIRREA must be followed, AND no AMC shall be involved UNLESS the actual order is placed by an appraiser in the state it is being ordered in.

Comments on: MBREA Meeting with Congressman Frank RE C&R Fees

By: Michael F. Ford