FDIC wants to hear from you about “Financial Reform”
The financial arena and the home loan business in particular, has been in a huge state of upheaval since the HVCC (Home valuation code of conduct) and now the “Dodd-Frank Bill “. Because the bill is uncertain as to particular implementation and the HVCC is ready to sunset, the FDIC is preparing to put into affect specific regulations for financial reform.
FDIC Chairman Sheila C. Bair said, “Now that Congress has acted and the President has signed the bill into law, it is in the regulators’ ballpark to implement the new reforms as quickly and openly as possible. I think transparency is a significant issue for each step along the way. We owe it to the public to have an open door policy so that people can see for themselves how financial services reform is going to be implemented.”
The new policy takes steps taken in the formal notice and comment rule making process. The FDIC will hold a series of discussions with parties on implementation issues. These will be designed to provide balanced public input throughout the process and will be available for public viewing on a web cast. In addition, any interested party can request a meeting withFDIC officials by sending a form that will be provided on the FDIC’s webpage. Along with this new process comes additional public disclosure. The FDIC releases, on a bi-weekly basis, the names and affiliations of private sector individuals who meet with senior FDIC officials to talk about implementing the new law through independent or joint rule makings. The FDIC will release the information from those meetings. The FDIC will web cast all open Board meetings, including those regarding regulatory reform.
To seek input from the largest audience possible, the public can put forth views via email on how the FDIC should implement the new law. These emails will become part of the permanent record and will be posted on the FDIC website. The public will also be able to sign up to receive notices on major developments . The FDIC has also written bill summaries and included a fact sheet that will be updated to reflect policy decisions during the implementation process. This can all be accessed at the financial reform web page, www.fdic.gov/financialreform/.
Because I am an appraiser, I am very interested in appraiser independence and how the government regulates appraisals and appraisal services, I wrote the following to the FDIC:
“Regarding appraiser independence and a simple solution to eliminate appraiser pressure:
My California appraisers volume is down approximately 75% since HVCC has been implemented. This is because my clients can no longer order appraisals from me directly. These clients have been developed and maintained for over 20 years and with a stroke of Andrew Cuomo’s pen have all gone away. This was done to “protect” appraisers from the pressure to appraise a home based on a predetermined value.
Simple solution: Make it illegal to ever mention, discuss or insinuate an estimated value, loan amount or “needs” of the borrower to an appraiser. If there is no predetermined value, then there is no pressure to “hit” that value. Make a national hot line to report abuse. The only exception would be in the case of a purchase appraisal where the sales price is important market data.
In conclusion, I would ask that you please allow loan brokers and others to order appraisals directly from independent appraisers. This will keep costs down for the consumer and restore financial health to a needed group of Americans.
Sincerely,
Chas W. Leeper, SRA “
I hope you will email the FDIC your thoughts on financial reform.
C.W. Leeper ,real estate broker for over 30 years; California Certified Appraiser; an author, surfer and grandparent. He is currently the CEO of Southern California Real Estate and Appraisal Inc. To find out more about Mr. Leeper, SRA www.leeperappraisal.com or call 949-574-5534.