VaCAP Expresses Concerns to Legislators
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Last week we shared with you Maxine Waters and Sherrod Brown’s inquiry to the Appraisal Subcommittee inquiring on the parameters used to determine the North Dakota Appraiser Waiver approval. We encouraged each of you to take advantage of the attention on our profession and contact your representatives. VaCAP has sent letters to both the US House of Representatives Committee on Financial Services and the Senate Committee on Banking Housing and Urban Affairs expressing our concerns. The letters are identical and express concern for the safety and soundness of the housing market, the economy, consumer protection, minority discrimination, and lack of standardization in automated valuation models.
If you have not contacted your representatives yet, please take the key points from VaCAP’s letter and write your own. Our regulators are listening!
Many appraisers have refused to complete these types of products due to the lack of credibility of the information being provided as well as the day labor type compensation. Simply stated, this type of product lacks logic and credibility. FHFA never should have allowed the GSE’s to move forward with a product that does not protect the public…
Appraisers have concerns with appraisal waivers as these offerings are only for those who have superior credit scores and substantial assets. Concern is warranted as when the housing market crashed just ten years ago, many of those superior credit score borrowers made conscious decisions to walk away from their properties due to the
unrecoverable loss in value. The losses occurred on higher dollar properties is far greater than lower or middle priced properties. Many view waivers as a form of discrimination to minority or lower income borrowers as those borrowers simply will not qualify…
The Financial institutions Reform, Recovery and Enforcement Act (FIRREA) was passed after the savings and loans debacle in the late 1980’s / Early 1990’s. FIRREA required the licensing of real estate appraisers to set a minimum standard and to instill confidence to the public. Much of what the GSE’s are introducing as modernization is reminiscent of activities that occurred prior to FIRREA. We have come so far over the years, reverting back to questionable practices does not insure the safety and soundness of the market. The housing market plays a key role in the economy, licensed and certified professional appraisers are a crucial component in minimizing collateral risk.
Communities and voters are the back bone of this country. The safety and soundness of the housing market is the back bone of local economies, the national economy and yes, the international economy. We have barely recovered from the major financial crash of 2007/2008. Let’s not do it again!