FHA announced Friday, September 18, 2009, that they are going to adopt many segments of the HVCC. We have felt for some time that this would be a likely path for FHA. Our predictions led us to design and develop the processes necessary to efficiently and effectively process FHA appraisal orders in an HVCC compliant manner.
A few of the segments of the Mortgagee Letter 2009-28 not included in the HVCC which should be given consideration are;
· FHA Appraisers are not prohibited by the lender, AMC or other third party, from recording the fee the appraiser was paid for the performance of the appraisal in the appraisal report.
· FHA Roster appraisers are compensated at a rate that is customary and reasonable for appraisal services performed in the market area of the property being appraised.
· The fee for the actual completion of an FHA appraisal may not include a fee for management of the appraisal process or any activity other than the performance of the appraisal.
· Any management fees charged by an AMC or other third party must be for actual services related to ordering, processing or reviewing of appraisals performed for FHA financing.
· AMC and other third party fees must not exceed what is customary and reasonable for such services provided in the market area of the property being appraised.
