As courses are being updated, it should be noted that HVCC is no longer in effect. Section 1472, Title XIV Mortgage Reform and Anti-Predatory Lending Act of Dodd-Frank Act (HR 4173) called for the sunset of HVCC 90 days after enactment of the Bill. That date was October 21, 2010. As required by the Dodd-Frank Act, the Federal Reserve issued an interim Final Rule on October 18, 2010. This rule was issued in order to ensure the independence of the appraisers and the requirement that appraisers are to receive “customary and reasonable payments for their services.” The Final Rule issued by the Federal Reserve is effective April 1, 2011. At the present time, the Final Rule is in the comment period and is subject to change before the effective date.
In an effort to bridge the gap between the sunset and effective date of the Final Rule, Fannie Mae and Freddie Mac issued notices regarding new Appraiser Independence Requirements. Just like HVCC, the new requirements issued by Fannie Mae and Freddie Mac apply toward conventional 1 to 4 family mortgage loans originated on or after October 15, 2010 and delivered to Fannie Mae or Freddie Mac.
It is important that students understand Appraiser Independence as it relates to Past (HVCC) Present (Fannie Mae and Freddie Mac Appraiser Independence) and Future (Federal Reserve Final Rule).
Dodd Frank Act (HR 4173) http://www.govtrack.us/congress/billtext.xpd?bill=h111-4173
Federal Reserve Final Rule –http://www.federalreserve.gov/newsevents/press/bcreg/20101018a.htm