The Independent Community Bankers of America's (ICBA) Comments on HVCC

The Independent Community Bankers of America (ICBA) welcomes the opportunity to comment on the Home Valuation Code of Conduct.

The Code of Conduct comes from an agreement reached with the New York State Attorney General, Fannie Mae, Freddie Mac and the Office of Federal Housing Enterprise Oversight to strengthen the independence of the appraisal process. The Code of Conduct would impact mortgages that Fannie Mae and Freddie Mac buy or guarantee.  Download ICBA_HVCC_Response.pdf

ICBA sees significant flaws in the Code of Conduct that make it unworkable and overly burdensome for community banks for reasons described below. The Code of Conduct conflicts with appraisal independence guidelines and requirements already addressed in laws and regulations governing insured depositories, without observable benefits to institutional safety and soundness. This letter, which reflects the views of ICBA members on specific elements of the Code of Conduct, supplements a letter sent to James B. Lockhart III, Director of the Office of Federal Housing Enterprise Oversight, dated April 30, 2008 and signed jointly by ICBA and other financial trade associations.