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The HVCC as written harms the very profession it is purported to protect. The HVCC is constructed in such a way as to inevitably drive the appraisal ordering process through appraisal management companies (AMC's). AMC's generally cut the fees of appraisers, which in turn we feel will result in poorer quality appraisals. Because most of the more experienced and highly qualified appraisers will not accept the lower fees, the HVCC will likely force many honest, Well-qualified appraisers out of the business.

Because this agreement has negative and unintended consequences for appraisers and is not in the best interest of the public, the Alabama Real Estate Appraisers Board has no confidence in the HVCC and is issuing the following comments on Mr. Cuomo's agreement:

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The Alabama Real Estate Appraisers Board, therefore calls for the amendment of the HVCC for the following reasons:

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The HVCC will likely result in more unreliable appraisals being used by Government Sponsored Enterprises (GSE's) to determine the value of collateral for mortgage loans.
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The HVCC has no authority to penalize those individuals who attempt to improperly influence appraisers.
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The HVCC does nothing to criminalize the improper influence of appraisers or the appraisal process.
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The HVCC could undermine legitimate, ongoing efforts in Congress to pass meaningful legislation, which would criminalize the improper influence of appraisers.
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The HVCC gives shareholders in Fannie Mae and Freddie Mac false hope that collateral for mortgages is being properly valuated.
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The HVCC gives U.S. taxpayers a false sense of security that its GSE's have taken all meaningful steps to address valuation concerns related to the current mortgage meltdown.
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The HVCC gives individuals taking out a conventional mortgage a false sense of security that their house is being properly appraised.

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The Alabama Real Estate Appraisers Board believes the following alternatives should be explored, promoted and implemented before resorting to the extreme measures outlined in Section IV of the HVCC:

1.
State and Federal legislation should be enacted to criminalize the improper influence of appraisers, including stiff penalties.
2.
Mortgage professionals should be licensed and/or certified.
3.
Mortgage professionals should sign a certification that they did not influence the appraisal process in any way. This certification would hold mortgage professionals civilly and criminally responsible. The certification SHOULD be included as a provision in the HVCC as well as in legislation with penalties for individual offenders.
4.
Enact State and Federal law requiring originators/processors ordering appraisals to deliver a copy of ALL appraisals developed at the lender's request to the borrower, the underwriter and/or the lender.
5.
Allow mortgage originators or borrowers to pick an appraiser from a list of previously approved appraisers, as the commercial banks currently do.

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