The credit crunch is making everything harder, interest rates more expensive, lenders much stricter and loans harder to come by. With this credit crunch comes the Home Valuation Code of Conduct, a new Fannie Mae and Freddie Mac rule that will be implemented in January 2009, restricting mortgage brokers or real estate agents from directly ordering appraisal reports (in cases where the loan will be sold to Fannie Mae or Freddie Mac). Since most loans are sold on the secondary market to Fannie and Freddie, this will pretty much apply across the board and I’m sure will become a standard practice.

Currently, when you purchase or refinance a property, the mortgage broker (or sometimes the real estate agent) directly orders the appraisal report from one of his or her appraisers and the appraisal is completed in the broker’s name. Come January, a broker or agent will no longer be allowed to order it; instead a third party (specifically an Appraisal Management Company) will appraise property.

What this Code intends:

  • To decrease mortgage fraud and appraiser coercion or influence
  • To completely neutralize the appraisal process itself (i.e. the broker or agent cannot tell the appraiser that to make a certain deal work, a certain value must be attained)
  • To not artificially inflate home prices due to an appraiser trying to bring value in

I certainly agree with what the Code is ultimately trying to accomplish: a means for battling a troubled and overly-inflated housing market. And of course this is a backlash against the easy days of lending and against unscrupulous lenders and appraisers.

What I don’t like about this Code is that:

  • The cost of getting a loan will increase because appraisal costs will increase
  • Loans will take longer to close because we’ll be at the mercy of these Appraisal Management Companies, in regards to their turnaround times and staffing. By not having a direct relationship with a particular appraiser, we’ll be unable to ask for rushes (or at least getting rush requests accommodated without having to pay extra for them)
  • Because of longer appraisal turnaround times, borrowers will be more susceptible to interest rate market changes over a longer period of time (45 day Close of Escrow periods may become the standard, not 30 day COEs)
  • If a lender requires a change or amendment to the appraisal (often a slight typo or oversight), the Appraisal Management Company will take a few days to turn that change around, causing further delays to closing
  • There will no longer be free comp searches done by appraisers to find out a range of value that your home can go for and to see if a refinance may even be a viable option
  • It will put our independent, hard-working, ethical appraisers out of a job

Does the long-term benefit outweigh the short-term cost? Probably… especially if it does provide a standard for home prices and assuring that we won’t have over-inflated prices. But it will also make the whole home purchase process more expensive, in a time when many people may opt for short-term relief. As an ethical broker who hires ethical appraisers, I’m personally not too happy about this, but I also understand where the proponents are coming from. Any thoughts out there?

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See an update on this post here