An outline exposing the unintended consequences created by HVCC and the Interim Rule February 23, 2012, Hon. Richard Cordray, Director, Consumer Financial Protection Bureau Re: Appraiser Independence Regulations Dear Director Cordray: Thank you for taking the time to meet with NAIHP on January 26, 2012. We always appreciate the opportunity to meet with the CFPB and discuss issues of concern that affect consumers and small business housing professionals. Although, our meeting covered a broad range of issues, my comments today are limited to the ongoing problems associated with “Appraiser Independence.” Today’s interim Rule on Appraiser Independence, was built on the...
ASA and NAIFA Send Joint Letter to FHFA, Fannie Mae & Freddie Mac Expressing Concerns on HARP Program Reliance of AVMs and Requesting a Meeting On October 25, the American Society of Appraisers (ASA) and the National Association of Independent Fee Appraisers (NAIFA) submitted a joint letter in response to yesterday’s announcement by the FHFA and the Government Sponsored Enterprises (GSEs) of changes to the Home Affordable Refinance Program (HARP) involving greater reliance on automated valuation models (AVMs) to value collateral property. In the letter, ASA and NAIFA expressed concerns regarding the GSEs quality control standards being used to ensure...
VaCap Second Letter to Attorney General Cuccinelli Regarding UAD 08/29/2011 Kenneth T. Cuccinelli, II Office of the Attorney General 900 East Main Street Richmond, VA 23219 Re: September 1st Implementation by GSEs Dear Sir: In a letter dated July 19th, 2011, the Virginia Coalition of Appraiser Professionals (VaCAP) brought to your attention the serious concerns that we have about the impending implementation of new appraisal reporting requirements by the Government Sponsored Enterprises (GSEs), which are The Federal National Mortgage Association (FNMA) and The Federal Home Loan Mortgage Corporation (FHLMC). Since Fannie Mae and Freddie Mac control a very large percentage...
VREAB Letter to FHFA Calling for Postponement of UAD Implementation August 29, 2011 Mr. Alfred M. Pollard, General Counsel Federal Housing Finance Agency Dear Mr. Pollard: At its August 16, 2011, meeting, the Virginia Real Estate Appraiser Board (Board) received public comment from a number of Virginia appraisers expressing their unease with the September 1, 2011, implementation of the Uniform Appraiser Database (UAD) by Fannie Mae and Freddie Mac under the direction of the Federal Housing Finance Agency (FHFA). These and other Virginia appraisers have concerns that conforming to the UAD might lead to misleading appraisal reports as the UAD’s...
