HVCC immplementation by Washington costs consumers millions . The Home Valuation Conduct Code was supposed to limit a lender's input on appraisals, when in fact the implementation of this law costs consumers millions of dollars in extension fees and costs of additional appraisals. According to this law the broker or lender is unable to have any contact whatsoever with the appraiser. The only fault is that this promotes inaccurate appraisals that are managed by an entity that does not adhere to the high standards that appraisers are held to. Although the consumer has paid for the appraisal the bank does not have to give a copy to them until three days before the closing or three days before the turndown. This creates a disadvantage to Brokers and lenders as they are unable to provide this appraisal to another investor to shop for a lower rate or better terms.

In theory, this might have been fair if it applied to banks as well. However, due to the Bank's powerful lobbyists it did not apply to them at all. Why would Bank of America be allowed to own their own appraisal management company and credit bureau and only require those entities to be used? I feel this is a violation of the Sherman Anti-trust Laws and a violation of Consumer's Rights. This could also promote Red-lining for banks. Our personal experience in the feld has proven that consumers will pay thousands more in loan costs per loan in unnecessary extension fees and appraisal costs, yet the consumer is still being provided with inaccurate , more costly appraisals. Many lead to unnecessary costs and "add-ons through PMI costs initiated as a result of low-balled and unprofessional appraisals. Recently I have had to go to battle for clients that never had PMI but that were required to have PMI on refinances that the Banks reviewed through the use of theses AMC's as implemented through the HVCC. Tell your Congressman or Senator that you disapprove of such laws. For more information feel free to goto: www.namb.org or call Gary J Heinecke,

at : 864-486-8000.