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Steve Owen
Certified General
Joined: 14 Aug 2007
Posts: 1760
Location: Joplin, Missouri
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 Posted: Fri May 09, 2008 9:29 am Post subject: ICBA Response to HVCC - Interesting Side Note |
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Of course, you knew that these guys would be against it. A lot of them still refer to the "good old days" as that time gone by when someone from the bank would just drive by a property to see if there was enough collateral there.
http://appraisalnewsonline.typepad.com/appraisal_news_for_real_e/files/ICBA_HVCC_Response.pdf
Anyway, I thought that their response was actually pretty good. But, what really caught my eye was this side note.
| Quote: | As insured depositories, community banks are subject to laws and regulations that require
appraisals for many real estate transactions. Title XI of the Financial Institutions Reform,
Recovery, and Enforcement Act of 1989 (FIRREA) (Section 323.1 of FDIC rules and
regulations) provides protection for federal financial and public policy interests in real
estate related transactions by requiring real estate appraisals used in connection with
federally related transactions to be performed in writing, in accordance with uniform
standards, by appraisers whose competency has been demonstrated and whose
professional conduct will be subject to effective supervision. |
One of my favorite instructors used to say that she thought that any Fannie or Freddie deal was an FRT and had to meet Statement 10 (this was several years ago). Then, ASB corrected her and made it clear that they thought Fannie and Freddie deals were never FRT's. Now, the ICBA comes out and tells Fannie that their deals are FRT's even if they are being sold to Fannie. What a tangled web we fix when we write regs with banker's lobbyists in the mix. (Apologies to Emily Dickinson.)
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The Rembrandt light of memory, finicky and magical and faithful at the same time, as the cheaper tint of nostalgia never is. - Ivan Doig, The Whistling Season
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Edd Gillespie
Certified General
Joined: 13 Aug 2007
Posts: 2282
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| Posted: Fri May 09, 2008 9:57 am Post subject: |
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Isn't there some kind of de-minimus FRT provision? If we are to believe the sub-prime meltdown geneses spin, then de-minimus loans brought the house down. Baloney, this is about the lack of bank liquidity and the beginning of it is clearly in the lack of income growth. What the heck is on the other side of this globalization adjustment for the middle class of the US?
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Edd “In the real estate economy, there are no guarantees that reason will prevail in a market where emotions run high and the amount of misinformation runs deep.” Jonathan Miller in The Matrix. So what’s an appraiser to do?
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