Letters to the Editor

Letters to the Editor

If you feel the need to voice your opinion, please email us your comments at [email protected]   


Cuomo’s Crossing: an outsider’s appraisal of the new HVCC by Martin Andelman

Martin: I read your article the other day. It was OUTSTANDING!! Clearly the best depiction of the issue I've seen from any writer.

Thanks, Marc S. Savitt, CRMS, Immediate Past President Vice Chair-Government Affairs Committee
National Association of Mortgage Brokers

We’re happy you enjoyed the article Marc, how ‘bout making us the “unofficial” magazine of NAMB?

Fabulous article about the HVCC crisis! I couldn't agree more with your interpretation! Being in this business for 12 years, I am amazed at the stupidity of this system.   Thank you for making me feel like someone is listening!!  

Joy M. Berman CT Prospect Mortgage Group, LLC


Just wanted to say how much I enjoy the articles being written by Martin Andelman. Witty, insightful and timely. What more can I say except that he is kinda cute too.  I look forward to every month’s publication. Keep up the good work.

Maureen Spiegleman, Cherry Creek Mortgage Company 


Mr. Andleman, I just finished reading the article you wrote for the The Niche Report: An Outsider's Appraisal of the New HVCC.  I wanted to let you know I so delighted in your sense of humor and was impressed at the thorough research you obviously did.  That was terrific!

I also want to inform you of another disastrous aspect of the HVCC.  Nearly everyone seems to be completely unaware of this, and I am disgusted and appalled that those who are aware of it....are keeping silent. 

First, state licensed and certified appraisers are required to be used in order for a mortgage appraisal to comply with the new HVCC.  Under the requirements of their licenses, these appraisers must conform to the Uniform Standards of Professional Appraisal Practice (USPAP). 

Appraisal Management Companies are assigning appraisers to properties out-of-town and sometimes out-of-state.  But, the USPAP prohibit an appraiser from appraising a property in a market he/she is unfamiliar with.  Thus, these appraisers are violating USPAP and violating the HVCC.  The lender ends up with an appraisal that is NOT HVCC compliant!  The loan applicant who gets turned down doesn't know what's happening, nor does their mortgage broker, nor does their real estate agent.  All believe there's no recourse!  Sometimes, the loan applicant has even paid for multiple non-compliant appraisals.

The appraisers aren't telling anyone they are violating the USPAP and violating the HVCC, as they'll lose appraisal orders.  The unlicensed and unregulated AMCs aren't telling anyone, because they don't have to and because they'll lose business.  Worse, there is virtually NO enforcement of current appraisal violations across our country because the states are so understaffed. When it is first discovered that an out-of-area appraiser has been assigned, ALL parties (seller, buyer, listing agent, selling agent, mortgage broker) should immediately contact the lender (with written follow-up) to demand that a local appraiser be used.  Otherwise, the appraisal will not comply with the HVCC. Mr. and Mrs. Consumer are screwed again!

Thank you, again, for your article and for your courteous time and attention reading this.

Barb Torres, ASA Accredited Senior Appraiser, American Society of Appraisers; California Certified General Real Estate Appraiser


I would like to compliment you on your recent article in the Niche Report-Cuomo’s Crossing, An Outsider’s Appraisal of the New HVCC Rules.  Your article is well written, amusing and strikingly honest. It uncovers the irony of this ridiculous agreement to placate the Appraisal Management Companies at the expense of the consumer. I am a 30 year real estate appraiser veteran and own a large regional appraisal company in Ohio. Over the years I have developed my company based upon trusted relationships with bank officers, mortgage brokers and real estate agents. The purpose of my profession is to develop an opinion of value based upon the actions of the real estate market. The metaphoric wall constructed by the HVCC not only erodes into my business but creates an impenetrable membrane for accurate valuation analysis and development.

That being said, I would like to note a few important points misrepresented in your article:


  1. The Valuation Protection Institute has never been established. The purpose of this agreement was to protect appraisers, consumers and users of appraisal services from pressure and coercion but there is no mechanism for enforcement. Without the Valuation Protection Institute I believe the agreement is null and void.
  2. The HVCC does not mandate the use of appraisal management companies. HVCC does stipulate a firewall between those ordering appraisals and the appraiser but the mandatory use of appraisal management companies is a well spun fantasy promulgated by TAVMA (the Title Appraisal Vendor Management Association)
  3. The final version of the HVCC does not put limitations on the ownership of Appraisal Management Companies by banks.

Ronald Stickelman, SRA President 


Crisis… What Crisis? By Todd Duncan


Todd reminds me of my grandfather.  These are two of my grandfather’s favorite quotes, “it’s not how life treats you it’s how you treat life.”

The second one requires me to put it into context of the situation.  Here we go, due to my grandfather’s age he had to put his farm into the government’s soil bank sometime in the last 1950s.  The government required him to plant 5000 pine trees so he wasn’t able to grow crops.  Once he told me we need to plant the 5000 pines trees I asked the question, “How are just the two of us going to plant so many trees”?  He turned to me with a clam look and said, “One at a time”.  I will never forget that statement.  Anytime the task seems to be overwhelming I think to that moment with my grandfather standing in the field and saying to me, “one at a time.”

Todd and my grandfather must have known each other in a prior life.  J  Keep the correct attitude and go about your business one step at a time.

Tom Champion

National Sales, Ratelink