As many of you know, NAIHP has been trying to obtain the approximately 45,000 PUBLIC comment letters submitted to OFHEO, (now the Federal Housing Financial Agency -FHFA) in the spring of 2008.
NAIHP submitted a Freedom of Information Act (FOIA) request months ago. That request has been stalled by the agency. In addition, we made a complaint to the Inspector General’s Office, which is in “process.”
FHFA has publicly admitted they used these letters in the implementation of the HVCC agreement. However, they continue to refuse to release them. We are aware the majority of these comments were anti-HVCC, and once made public, will provide evidence the FHFA and the GSE’s mislead Congress, the former NY Attorney General and the public.
On April 11, 2012, NAIHP wrote to CFPB Director Richard Cordray (CFPB now has jurisdiction over appraiser independence rules), outlining the problem and provided a complete background/timeline of the HVCC. Although, Cordray never responded, a government watchdog group did.
On June 4, 2012, Judicial Watch, Inc. submitted FOIA requests to the FHFA, CFPB, the Federal Reserve Board, HUD, OCC, NCUA and the US Government Accountability Office. The requests asked for the HVCC comment letters, all emails/correspondents and any notes regarding the appraisal code. The document request goes back to 2008.
CFPB denied the FOIA request almost immediately. In response, Judicial Watch filed an appeal. That appeal was GRANTED! CFPB is now compelled to submit the required documentation within 20 days. The other agencies are due to respond any day.
Once these comment letters are made public (not to mention internal emails and notes), they will prove HVCC was a sham designed to remove the GSE’s from Cuomo’s fraud investigation. The code was built on a foundation of lies. Moreover, with media support, it will show this code has already caused the loss of tens of thousands of jobs, and directly led to further depreciation of real estate values.
NAIHP also has the support of a major consumer group, who believes HVCC/Appraiser Independence is NOT working and needs to be changed.
NAIHP members will receive regular updates on this and other issues.