Blog of the Mortgage

Back in Mid-September, when we were all getting back in gear after the Summer, HUD came along and Dropped another BOMB on our business.
They had decided to begin the implementation of HVCC (or at least their version of it) Starting with any case numbers assigned as January 1st, 2010.

We all know how wonderfully crappy HVCC has been to our business and how our customers have had increased costs with lower quality work and stubborn appraisers.
There was a collective *GROAN* in our business as we thought about the importance of FHA appraisal work in a transaction and then about the process of getting repairs handled and having an HVCC paid appraiser jump on the work to get completed by COE.
This 21 day escrow environment will have to go to 30-45 days per contract or NO ONE will close on time.

HUD had this to say in it's ML 09-28 about the importance of Appraiser independence:

FHA has long advised lenders and appraisers of the importance of appraiser independence in the context of generally accepted prudent lending practices.  In this mortgagee letter, FHA reiterates the importance of appraiser independence:
In order to help appraisers avoid conflicts or the appearance of conflicts, no members of a lender's loan production staff or any person (i) who is compensated on a commission basis upon the successful completion of a loan or (ii) who reports, ultimately, to any officer of the lender not independent of the loan production staff and process, shall have substantive communications with an appraiser relating to or having an impact on valuation, including ordering or managing an appraisal assignment. 

Good Grief! 
Well, Yesterday, HUD delayed the HVCC roll out until February 15th, 2010 (case numbers assigned).
here's the Body of the Mail:

Delayed Implementation Date for New Requirements in ML 2009-28

 

Enactment of ML 2009-28, Appraiser Independence, will be delayed until February 15, 2010. ML09-28 (originally planned for a January 1, 2010 implementation) has two parts:  a) prohibition of mortgage brokers and commission-based lender staff from the appraisal process, and b) appraiser selection in FHA Connection.  The effective date for both sections of this guidance will now take effect for all case numbers assigned on or after February 15, 2010.  This extension will provide FHA and lenders additional time to adjust systems to accommodate the changes.

 

Detailed instructions on changes to FHA Connection will be issued in a new mortgagee letter. However, lenders should be aware that the requirement for inputting the appraiser ID and the appraisal assignment date in the FHA Connection case number assignment screen will be removed.  Instead, lenders will be required to enter all appraisal data, including the appraiser ID, in the Appraisal Update Screen once the completed appraisal is received by the lender and prior to closing the loan. 

 

Delayed Implementation Date for ML 2009-51

 

ML 2009-51, Adoption of the Appraisal Update and/or Completion Report, states an effective date of January 1, 2010. The effective date is being extended and will now apply to all case numbers assigned on or after February 15, 2010. This extension will provide additional time needed by FHA and lenders to adjust their systems to accommodate use of the form.

 

So... Merry Christmas to you from HUD! Get those case #'s registered STAT and enjoy the rest of your Holiday week.

  Have a great week!

*********************

Have a great Winter Selling season.

Posted by Raoul Badde on December 23rd, 2009 8:30 AMPost a Comment (0)
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