On June 19th, citing requirements that would undermine the safety and soundness of the mortgage credit system, reduce the availability of mortgage credit, and lead to less reliable and accurate real estate appraisals, the FED, OCC, OTS, and NCUA, in a joint letter to OFHEO, urged Fannie the GSE's and New York Attorney General to withdraw the Cooperation Agreements and Home Valuation Code of Conduct (HVCC) that were announced in March of 2008 - See TAVMA blog.
These requlators were among those that were late to the table in terms of providing leadership and guidance prior to May 1, 2008 (the end of the 90-day comment period). See "11th Hour HVCC Plans and Comments - Where was the leadership".
Most of the joint letter reads to me like they're satisfied with the status quo: "Moreover, issues regarding appraiser independence and protection from coercion are already adequately addressed by current and pending rules and guidance of the Agencies." - Download regulators_jointletter_hvcc.pdf
One interesting item of note was their comment about "Regulation Z" (click image to enlarge) that would prohibit all creditors and mortgage brokers from pressuring an appraiser to misrepresent a dwelling's value and would prohibit all creditors from extending credit if the creditor knows or has reason to know that an appraiser has been coerced to misstate a dwelling's value.
Regulation Z--Truth in Lending, 73 Fed. Reg. 1672, 1726 (proposed January 9, 2008) (to be codified at 12 CFR pt. 226). The proposal was released for comment on January 9, 2008. The proposal's comment period ended on April 2, 2008, and Board staff is analyzing the more than 4,000 comment letters received on the proposal to determine what modifications, if any, to make to the draft regulation.
Click here for the complete letter: Download regulators_jointletter_hvcc.pdf
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