performed 15 appraisals.

HAVE NOT BEEN PAID FOR A SINGLE DEAL YET……..

MANY OF THE DEALS CLOSED ESCROW WEEKS AGO……

IM ON FIRE!!!!!!!!!!!

On May 1, 2009 the Home Valuation Code of Conduct (HVCC) – the result of an agreement between the New York Attorney General Andrew Cuomo, Fannie Mae and Freddie Mac went into effect.

This in unquestionably the worst agreement and corporate policy to effect the housing industry since Fannie Mae and Freddie Mac began operations. To be compliant with the HVCC lenders can only accept appraisals from a pre-approved list of appraisers or appraisal management companies (AMC’s).

The problems with the HVCC and AMC’s are:

1) The AMC companies, which will be the only ones allowed to order appraisals, are subsidiaries of the nations largest title insurance companies and banks. This is in direct violation of anti-trust laws and FIRREA 12 CFR 34 banking laws. They will have a direct monopoly, not to mention a conflict of interest, as they will be able to dictate their unreasonable demands on appraisers.
2) Appraisers are being asked to perform the same quality of work for1/2 or 1/3 their normal fees, which will result in poor quality of appraisals which is the problem the HVCC was established to solve.
3) The cost to consumers has increased in higher appraisal fees to the AMC companies, who then pay less to the appraisers doing the work. This is a violation of RESPA laws.
4) The HVCC creates huge communication problems, i.e. appraiser finds problem, reports to AMC, AMC reports to client, client responds back to AMC, AMC reports back to appraiser, appraiser corrects problem and reports back to AMC, AMC reports back to client, etc.,etc., etc. (this can take WEEKS before an adequate appraisal can be completed).
5) AMC’s are not regulated. When they violate provisions of HVCC, who do we report to? Nobody, because there is no regulation in place.
6) The success of this country has been based on the foundation of small businesses. This legislation is a direct hit to the small business person affiliated with the real estate market.

There are many other problems with the HVCC which are too numerous to go over in this letter.

I am writing to ask you to do everything in your power to repeal this awful piece of legislation, which can only contribute to the further decline in the real estate and financial markets.

Sincerely,
Thomas Bealle