We the undersigned understand that the intentions of the Home Valuation Code of Conduct ("HVCC") were to help curb the potential for fraud with respect to the valuation of residential properties. We must however bring to your attention the reality of the situation that HVCC has already caused.

1. Since "Appraisal Management Companies (AMC’s)" are taking up to 40% of the total appraisal fee, and are not being regulated to ensure that their appraisers are licensed and competent, we are seeing unlicensed and inexperienced individuals performing property inspections with grave data entry errors. These inferior appraisals are then being “signed-off” by other parties that NEVER INSPECTED THE PROPERTY and are creating unnecessary financial hardship for buyers and sellers.
2. With mortgage loans being denied due to inaccurate appraisals, borrowers are being forced to apply with other lenders who in turn have to charge the consumer ANOTHER APPRAISAL FEE to proceed with the transaction. This vicious cycle can go on endlessly costing well intended clients a great deal of money and time.
3. Under HVCC, no one involved the transaction is allowed to communicate these major issues directly to their appraisers so countless real estate transactions that would have otherwise closed are now failing, resulting in continued property devaluation and offering NO stimulus to our economy with the exception of the unregulated AMC’s who are making unjustified profits at the expense of qualified appraisers and homeowners.
4. Licensed appraisers have legal and ethical standards in place already. The emphasis should be on making appraisers abide by these, rather than frustrating the ordering and communication process. This well intended legislation is severely misguided.

Although HVCC has good intentions, its flaws are severely hurting our housing industry, the consumer and our economy. We are requesting that HVCC be discontinued or thought through thoroughly and retooled in order to stop the devastation it has caused and will continue to cause on our housing industry and our economy.

Sincerely,



The Undersigned