I just read Friday's Appraisal Scoop article Subprime Mortgage Lending Regs Need to Stress Appraisals. I just love the way Brian edits his blog! All these fancy links to get to things.
I've downloaded and read both the inter-agency proposed underwriting guidelines directed to the sub prime market and the joint appraisal organizations letter of response.
The Inter-agency guideline letter is right on target in my opinion. Well done. I don't see anything to change. I probably won't even comment...who needs to read "I agree!" comments...
The joint appraisal organization letter is another matter.Download Here(247.0K) I don't agree. They want to insert an emphasis on the importance of the appraiser in the sub prime market. The letter brings up fraud, and undue pressure on appraisers. HUMBUG!
I've commented before...I've been watching the sub prime melt down crescendo. Not one agency, or the congress, is trying to blame it on appraisers. Not one!
Geeze Guys!!!! Can't you leave well enough alone?! We ain't to blame here. But you "Appraisal Organization" guys keep bringing this up, trying to push your pet positions, trying to pin the tail on some part of the donkey's anatomy.
In pushing your agenda (appraiser pressure....which I don't agree with, by the way) in order to argue for proposing that lenders only use designated members to supply their needed appraisals, you risk bringing all us innocent appraisers (designated and non) into the blame game for sub prime...a game in which we are not even a participant! Get outta there!!!
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