Language to End HVCC in House Offer, Would it Impact the Reverse Business?

NewImage.jpgHousingWire is reporting an amendment to the Wall Street Reform Bill that would eliminate the Home Valuation Code of Conduct (HVCC) has made it into the House Offer.

In efforts to limit the interactions between appraisers and those originating the loan, the Federal Housing Finance Agency (FHFA) implemented HVCC in May 2009 in an attempt to improve the independence of appraisers by prohibiting lenders and third parties from influencing appraisals.

This has led to increasing demand for appraisal management companies (AMCs), while also acting as a magnet for complaints from independent appraisers who claim they’re being undercut out of the market according to HousingWire.

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While many in the reverse mortgage industry like to see HVCC eliminated, the US Department of Housing and Urban Development would have to change its stance on handling appraisals for FHA insured loans to have any real impact on the industry since it didn’t totally adopt HVCC requirements.

The agency announced in 2009 that mortgage brokers and commission based lender staff are prohibited from ordering appraisals, but it wasn’t requiring the use of AMC’s or other third party providers.  However, it does require that lenders take responsibility to assure appraiser independence, which has lead to the use of AMC’s throughout the reverse mortgage industry.

With HUD holding approved mortgagees responsible for ensuring compliance with FHA requirements in all aspects of loan transactions, whether performed by the approved mortgagee or by its sponsored third party originator, industry experts tell RMD it’s unlikely the usage of AMCs would change even if HVCC is eliminated.

Read more at the link below.

House Members Look to Eliminate HVCC, Change Appraisal Process

 

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  • Owltree,rnrnWhat does “on my dime” mean? Who is the appraiser providing his services for, the borrower or you? With each passing day it sounds like we are losing the vision of whom it is we are serving. More and more it is “us vs. them,” instead of “our borrower vs. them.u201d That independent voice of assessment and reason is dying off, a not only disappointing trend but also appalling.rn

  • Arguing u201caccountabilityu201d in the manner you do only vindicates the action of HUD. Appraisers are not and never were accountable to us or to those that engage them other than to provide their best estimate of value. They are first and foremost u201caccountableu201d to a written standard of independence, the state agencies who license them, their employer (if any), and then to those who rely on their services to their own detriment such as lenders. rnrnThe reason for the change was that government listened to the few appraisers who excused their abandonment of the standard of independence by declaring that they knowingly overvalued property to protect their streams of revenue. Rather than launching investigations into this breakdown and prosecuting accordingly, government punted and decided to place insulation between appraisers and those who were directly accused of creating the overvaluation problem. Many lenders reacted by supposedly beefing up their desk review of appraisals. Both of these steps while appearing to be responsible reactions have combined to produce a worse lending situation in the middle of a credit squeeze.rnrnSo letu2019s step back for a minute. It is not a lack of u201caccountabilityu201d to consumers and originators which AMCs have produced but rather it is the muting of two important ingredients in providing an environment of excellence in valuations, natural market selection of the best individual appraisers and the direct voice of consumers and their representatives as to the reasonableness of the opinion of value. Without these two ingredients, complacency and inferior (but u201csafeu201d) valuations result.rnrnHere is what is really needed: a restoration of the former system plus a significant strengthening of the independence standard. To excuse their lack of independence with the theme of protecting their revenue streams reminds one of the flopping seen in World Cup soccer over the last few weeks. Those appraisers should be prosecuted and disciplined through state licensing agencies and sued by lenders based on their own admissions.rnrnWe live in a world where individuals are not responsible for their own actions. Not only did the overvaluations of the past harm the parties who relied on them, but also society, other appraisers, and their own integrity so that today when some of us hear an appraiser describe his services as u201cprofessionalu201d there is a little chuckle down deep inside.rn

  • The issue of accountability is paramount to mewhen it comes to HVCC. Prior to HVCC, If an appraiser did a terrible job (e.g. value is not supported, ridiculous spelling mistakes, incorrect information, use of comps that are not comparable, adding repair issues that are minor and should be omitted, etc.) , they would not get another order from the lender. If they did that consistently, they would not ever get another order from anyone. Today, the appraiser can hide behind his large appraisal company (e.g. LSI, Landsafe, etc.) and behind the AMC, and not even address his errors or choices.More importantly, he can still sit by the phone and get more “random” orders. The pendulum has swung way too much in the other direction and most appraisers are putting values in that are well below actual values to cover their butts and are adding in absurd repair issues to get the reinspection fee. I’m not sure how anyone in the business can see it any other way

  • If AMC’s are here to stay, then local appraisals need to form partnerships that will be compliant with “Post-HVCC” regulations concerning appraisal independence. Speaking as an originator, my issues with AMC’s is mainly that I have no choice as to which AMC I can select. If I don’t have the choice to use a specific appraiser, I see no reason why I can’t at least select an AMC that operates locally, and is owned and operated by local appraiser. Further, I would prefer that whomever answers the phone is a trained appraisal professional, rather than the neophytes that receive on the job training on my dime.

  • Lpassman09 and michaelpinter,rnrnI am bothered by your statements regarding accountability. An independent appraiser has no accountability except to his licensing body and the user of the appraisal in producing an appraisal reflecting market value unless he/she is an employee and then it is also to some measure to his/her employer. It is no different today than last year. rnrnYour statement about accountability almost accuses the appraisal industry of complicity with borrowers or originators to reach an agreed value in prior years. This is a terrible accusation.rnrnHere is where you go astray. It is the pressure of working with the engaging party and their representatives which helps push appraisers to achieve higher quality in their appraisals. Insulating appraisers from such pressures has proved to produce lower quality results. There seems to be a more complacent attitude and less dedication to excellence now than in the last decade.rn

  • Hey Lance,rnrnYou really are seeing red (ridiculous, not rediculous). However, I really liked the spelling. When it comes to quality in appraisals, I am seeing RED as well.

  • The “cure” that HVCC was supposed to represent forced the creation of new companies using new business models. In the absence of a set of well-established precedents and practices, this gave a number of AMCs that had ignorance and opportunism as large parts of their business model a chance to open their doors and grow. Especially on the banking side where 50-state reach was important, the national AMC performance has been good with a few and terrible with others. Beyond the universally more cumbersome ordering process, longer turn times and greater expense, we now have more numerous quality-related complaints and more appraisal-related underwriting declines due to shoddy AMC practices than we ever had with individual appraisers. rnrnOne of our former AMCs, a national title company that jumped on the AMC bandwagon (probably as a loss-leader to try to garner more title business), contacted some appraisers that we knew personally. These appraisers reported that this AMC cared only about driving price down and quick response as a condition of contracting – that approach attracts the hungry and the weak and limits the professional appraiser.rnrnFiring an AMC takes longer than firing an individual appraiser because it takes more time and more harm to borrowers and originators to realize.So besides the originator and borrower headaches, another unintended consequence of HVCC may be that the weaker AMCs threw a lifeline to inexperienced or poor appraisers, making poor quality a problem that may linger.

  • Many experienced appraisers have left the business because they can make a better living elsewhere than what the AMCs are willing to pay, although the cost of appraisals has increased. This has resulted in staffs of inexperienced and inept appraisers, and some of the most off-the-wall valuations and repair requirements ever.

  • I think HVCC is the worst thing to hit the mortgage industry ever. The complete lack of accountability for appraisers has caused some of the most difficult problems I have ever encountered in my 15 years in the business. The concept of making the appraisal process so much more complicated and eliminating all appraiser accountability by adding (usually) two layers between the appraiser (large appraisal company like LSI and then the AMC) and the orderer, would make things better, is prepostorous. The fact that we have to wait 120 days (better than six months) once some appraiser getting paid a fraction of what they used to, comes in 40% below value and writes that the entire property needs to be rebuilt (when it has three paint cracks) is also absurd. I understand that there were a lot of abuses and that we are not supposed to shop for the highest value, but the fact that we can’t even talk to the appraiser to ask him why he didn’t use better comps or why he asked for repairs on items that were fixed five years ago (to get a reinspection fee) is just an unacceptable position that we have been put in.

  • I just had a HECM appraisal done for a successful actress on a beautiful home with an ocean view. One of the most VC-ridden appraisals I’ve seen in my almost 9 years originating HECMs. This would have never happened prior to HVCC. The appraisers have no incentive to do a decent job, they get paid regardless. REDICULOUS!!

  • HVCC is another example of regulation without regard for the consequences. The appraisers have to take what they can get from the AMC, the best one’s won’t. Rather than more accountablity, it ends in less accountability from the appraisers who are now working for a portion of what they did before. To contest a bad appraisal via AMC is as easy as capping the oil well in the Gulf. For the appraiser it is churn out the appraisal as fast as possible and never look back. For the broker take what you get and move on. The consumer stands there holding the bill.

  • One of the principal reasons for going to an AMC system was to relieve appraisers of undue pressure and stress. Has the reduction of stress and pressure under the AMC system resulted in better or worse appraisals?rn rnLittle pressure and stress generally results in complacency and inferiority. Unreasonable levels such as that exerted by the mob in enforcing its will are destructive. Reasonable levels create better results in services and product improvement as well as lower costs. While most of us would love to live life without them, the benefits of reasonable levels far outweigh their costs.rnrnSo how can the old system survive if the undue stress and pressure generally arose from fear of loss in large sources of revenues such as a substantial source of business like a lender? The answer just might lie in limiting the percentage of work which can come from any one source and at the same time reducing the percentage of appraisals which can be provided to any one lender. Of course in some smaller communities exceptions will need to be made or perhaps AMCs must stay in place in those areas.rnrnA firm I once worked for had to deal with a situation where one of its customers grew to be over 50% of its business revenues. The principal product it provided required extreme independence. The pressure that customer exerted to get results biased to the customer almost split up my employer. One year that customer walked. My employer scrambled for business and independence seemed even more in danger. Once that period passed, a decision was made by the owners never to allow any one customer to represent over 3% of company revenues. Although my employer still experienced stress and pressure on its ability to issue independent results, the new level resulted in better products and service.rnrnWhile a standard of this nature will require some additional accounting and monitoring, it would restore the former system with reasonable levels of stress and pressure without the undue levels previously reported by some appraisers. Higher fees will no doubt be required for the additional administration but probably not as high as seniors face right now. Like the cat which got out of the bag, it may be too late to rein in the AMC system. rn

  • it is such an unfortunate tragedy what HVCC has done to the real estate industry. Having been in finance for the better part of 18 years, has something such as HVCC caused increased costs to the consumers with very poor, snotty appraisals being completed by incompetent appraisers. This is costing consumers an enormous amount of money, with appraisals unable to be used by investors due to the poor quality, as well as costing consumers higher interest rates with lenders extending rate locks beyond ordinary times, which these costs are past on to the consumer in higher interest rates. This bill was passed by individuals that do not have the first clue of working in mortgage banking and finance, and they continue to make the same mistakes over and over again. Quit treating people like they are so ignorant in that the government needs to continue passing these programs such as HVCC as well as adopting the new GFE which is confusing to say the least, as well as causing lenders so fearful of making any mistakes, to then have to answer to a bunch of trial lawyers looking for their next meal ticket swarming like a bunch of vultures waiting for their next class-action lawsuit once they have completely bankrupted the asbestos companies. I am undecided what I personally feel will disintegrate the remaining mortgage market; HVCC or the trial lawyers starting the law suits with the new GFE driving banks and mortgage professionals completely out of the market…and then, you think we have troubles now in the real estate market…just wait! If they don’t start repealing both HVCC and go back to the old GFE, turn the lights off on your way out the door! n

  • HVCC was the very last thing our struggling housing market needed. And the results are plain to see: appraisal fraud has actually increased according to a recent industry report; experienced appraisers are being forced out of business; local appraisers are losing business to out-of-towners who are willing to work dirt cheap; customers are being charged higher prices, and sometimes need to order 2 or 3 appraisals if a bank rejects their application on other grounds. It’s no wonder to me that the housing market has been devastated.

  • It is such a shame that the use of AMC has been adopted as standard practice to comply with FHA’s Appraiser Independence Rules. It has increased appraisal costs & processing time, and decreased the quality and accuracy of valuations. Additionally, the senior borrower, the broker/correspondent and the lender are all receiving poor service from AMCs. What motivation does the AMC or individual appraiser have to do a quality job in a reasonable time period for a fair fee when they have guaranteed business regardless of customer satisfaction? It is a disgrace to our industry and reflects poorly on all of us.

  • It is such a shame that the use of AMC has been adopted as standard practice to comply with FHA's Appraiser Independence Rules. It has increased appraisal costs & processing time, and decreased the quality and accuracy of valuations. Additionally, the senior borrower, the broker/correspondent and the lender are all receiving poor service from AMCs. What motivation does the AMC or individual appraiser have to do a quality job in a reasonable time period for a fair fee when they have guaranteed business regardless of customer satisfaction? It is a disgrace to our industry and reflects poorly on all of us.

  • HVCC was the very last thing our struggling housing market needed. And the results are plain to see: appraisal fraud has actually increased according to a recent industry report; experienced appraisers are being forced out of business; local appraisers are losing business to out-of-towners who are willing to work dirt cheap; customers are being charged higher prices, and sometimes need to order 2 or 3 appraisals if a bank rejects their application on other grounds. It's no wonder to me that the housing market has been devastated.

  • it is such an unfortunate tragedy what HVCC has done to the real estate industry. Having been in finance for the better part of 18 years, has something such as HVCC caused increased costs to the consumers with very poor, snotty appraisals being completed by incompetent appraisers. This is costing consumers an enormous amount of money, with appraisals unable to be used by investors due to the poor quality, as well as costing consumers higher interest rates with lenders extending rate locks beyond ordinary times, which these costs are past on to the consumer in higher interest rates. This bill was passed by individuals that do not have the first clue of working in mortgage banking and finance, and they continue to make the same mistakes over and over again. Quit treating people like they are so ignorant in that the government needs to continue passing these programs such as HVCC as well as adopting the new GFE which is confusing to say the least, as well as causing lenders so fearful of making any mistakes, to then have to answer to a bunch of trial lawyers looking for their next meal ticket swarming like a bunch of vultures waiting for their next class-action lawsuit once they have completely bankrupted the asbestos companies. I am undecided what I personally feel will disintegrate the remaining mortgage market; HVCC or the trial lawyers starting the law suits with the new GFE driving banks and mortgage professionals completely out of the market…and then, you think we have troubles now in the real estate market…just wait! If they don't start repealing both HVCC and go back to the old GFE, turn the lights off on your way out the door!

  • One of the principal reasons for going to an AMC system was to relieve appraisers of undue pressure and stress. Has the reduction of stress and pressure under the AMC system resulted in better or worse appraisals?

    Little pressure and stress generally results in complacency and inferiority. Unreasonable levels such as that exerted by the mob in enforcing its will are destructive. Reasonable levels create better results in services and product improvement as well as lower costs. While most of us would love to live life without them, the benefits of reasonable levels far outweigh their costs.

    So how can the old system survive if the undue stress and pressure generally arose from fear of loss in large sources of revenues such as a substantial source of business like a lender? The answer just might lie in limiting the percentage of work which can come from any one source and at the same time reducing the percentage of appraisals which can be provided to any one lender. Of course in some smaller communities exceptions will need to be made or perhaps AMCs must stay in place in those areas.

    A firm I once worked for had to deal with a situation where one of its customers grew to be over 50% of its business revenues. The principal product it provided required extreme independence. The pressure that customer exerted to get results biased to the customer almost split up my employer. One year that customer walked. My employer scrambled for business and independence seemed even more in danger. Once that period passed, a decision was made by the owners never to allow any one customer to represent over 3% of company revenues. Although my employer still experienced stress and pressure on its ability to issue independent results, the new level resulted in better products and service.

    While a standard of this nature will require some additional accounting and monitoring, it would restore the former system with reasonable levels of stress and pressure without the undue levels previously reported by some appraisers. Higher fees will no doubt be required for the additional administration but probably not as high as seniors face right now. Like the cat which got out of the bag, it may be too late to rein in the AMC system.

  • HVCC is another example of regulation without regard for the consequences. The appraisers have to take what they can get from the AMC, the best one's won't. Rather than more accountablity, it ends in less accountability from the appraisers who are now working for a portion of what they did before. To contest a bad appraisal via AMC is as easy as capping the oil well in the Gulf. For the appraiser it is churn out the appraisal as fast as possible and never look back. For the broker take what you get and move on. The consumer stands there holding the bill.

  • I just had a HECM appraisal done for a successful actress on a beautiful home with an ocean view. One of the most VC-ridden appraisals I've seen in my almost 9 years originating HECMs. This would have never happened prior to HVCC. The appraisers have no incentive to do a decent job, they get paid regardless. REDICULOUS!!

    • Hey Lance,

      You really are seeing red (ridiculous, not rediculous). However, I really liked the spelling. When it comes to quality in appraisals, I am seeing RED as well.

  • I think HVCC is the worst thing to hit the mortgage industry ever. The complete lack of accountability for appraisers has caused some of the most difficult problems I have ever encountered in my 15 years in the business. The concept of making the appraisal process so much more complicated and eliminating all appraiser accountability by adding (usually) two layers between the appraiser (large appraisal company like LSI and then the AMC) and the orderer, would make things better, is prepostorous. The fact that we have to wait 120 days (better than six months) once some appraiser getting paid a fraction of what they used to, comes in 40% below value and writes that the entire property needs to be rebuilt (when it has three paint cracks) is also absurd. I understand that there were a lot of abuses and that we are not supposed to shop for the highest value, but the fact that we can't even talk to the appraiser to ask him why he didn't use better comps or why he asked for repairs on items that were fixed five years ago (to get a reinspection fee) is just an unacceptable position that we have been put in.

  • Many experienced appraisers have left the business because they can make a better living elsewhere than what the AMCs are willing to pay, although the cost of appraisals has increased. This has resulted in staffs of inexperienced and inept appraisers, and some of the most off-the-wall valuations and repair requirements ever.

  • The “cure” that HVCC was supposed to represent forced the creation of new companies using new business models. In the absence of a set of well-established precedents and practices, this gave a number of AMCs that had ignorance and opportunism as large parts of their business model a chance to open their doors and grow. Especially on the banking side where 50-state reach was important, the national AMC performance has been good with a few and terrible with others. Beyond the universally more cumbersome ordering process, longer turn times and greater expense, we now have more numerous quality-related complaints and more appraisal-related underwriting declines due to shoddy AMC practices than we ever had with individual appraisers.

    One of our former AMCs, a national title company that jumped on the AMC bandwagon (probably as a loss-leader to try to garner more title business), contacted some appraisers that we knew personally. These appraisers reported that this AMC cared only about driving price down and quick response as a condition of contracting – that approach attracts the hungry and the weak and limits the professional appraiser.

    Firing an AMC takes longer than firing an individual appraiser because it takes more time and more harm to borrowers and originators to realize.So besides the originator and borrower headaches, another unintended consequence of HVCC may be that the weaker AMCs threw a lifeline to inexperienced or poor appraisers, making poor quality a problem that may linger.

  • Lpassman09 and michaelpinter,

    I am bothered by your statements regarding accountability. An independent appraiser has no accountability except to his licensing body and the user of the appraisal in producing an appraisal reflecting market value unless he/she is an employee and then it is also to some measure to his/her employer. It is no different today than last year.

    Your statement about accountability almost accuses the appraisal industry of complicity with borrowers or originators to reach an agreed value in prior years. This is a terrible accusation.

    Here is where you go astray. It is the pressure of working with the engaging party and their representatives which helps push appraisers to achieve higher quality in their appraisals. Insulating appraisers from such pressures has proved to produce lower quality results. There seems to be a more complacent attitude and less dedication to excellence now than in the last decade.

    • The issue of accountability is paramount to mewhen it comes to HVCC. Prior to HVCC, If an appraiser did a terrible job (e.g. value is not supported, ridiculous spelling mistakes, incorrect information, use of comps that are not comparable, adding repair issues that are minor and should be omitted, etc.) , they would not get another order from the lender. If they did that consistently, they would not ever get another order from anyone. Today, the appraiser can hide behind his large appraisal company (e.g. LSI, Landsafe, etc.) and behind the AMC, and not even address his errors or choices.More importantly, he can still sit by the phone and get more “random” orders. The pendulum has swung way too much in the other direction and most appraisers are putting values in that are well below actual values to cover their butts and are adding in absurd repair issues to get the reinspection fee. I'm not sure how anyone in the business can see it any other way

      • Arguing “accountability” in the manner you do only vindicates the action of HUD. Appraisers are not and never were accountable to us or to those that engage them other than to provide their best estimate of value. They are first and foremost “accountable” to a written standard of independence, the state agencies who license them, their employer (if any), and then to those who rely on their services to their own detriment such as lenders.

        The reason for the change was that government listened to the few appraisers who excused their abandonment of the standard of independence by declaring that they knowingly overvalued property to protect their streams of revenue. Rather than launching investigations into this breakdown and prosecuting accordingly, government punted and decided to place insulation between appraisers and those who were directly accused of creating the overvaluation problem. Many lenders reacted by supposedly beefing up their desk review of appraisals. Both of these steps while appearing to be responsible reactions have combined to produce a worse lending situation in the middle of a credit squeeze.

        So let’s step back for a minute. It is not a lack of “accountability” to consumers and originators which AMCs have produced but rather it is the muting of two important ingredients in providing an environment of excellence in valuations, natural market selection of the best individual appraisers and the direct voice of consumers and their representatives as to the reasonableness of the opinion of value. Without these two ingredients, complacency and inferior (but “safe”) valuations result.

        Here is what is really needed: a restoration of the former system plus a significant strengthening of the independence standard. To excuse their lack of independence with the theme of protecting their revenue streams reminds one of the flopping seen in World Cup soccer over the last few weeks. Those appraisers should be prosecuted and disciplined through state licensing agencies and sued by lenders based on their own admissions.

        We live in a world where individuals are not responsible for their own actions. Not only did the overvaluations of the past harm the parties who relied on them, but also society, other appraisers, and their own integrity so that today when some of us hear an appraiser describe his services as “professional” there is a little chuckle down deep inside.

  • If AMC's are here to stay, then local appraisals need to form partnerships that will be compliant with “Post-HVCC” regulations concerning appraisal independence. Speaking as an originator, my issues with AMC's is mainly that I have no choice as to which AMC I can select. If I don't have the choice to use a specific appraiser, I see no reason why I can't at least select an AMC that operates locally, and is owned and operated by local appraiser. Further, I would prefer that whomever answers the phone is a trained appraisal professional, rather than the neophytes that receive on the job training on my dime.

    • Owltree,

      What does “on my dime” mean? Who is the appraiser providing his services for, the borrower or you? With each passing day it sounds like we are losing the vision of whom it is we are serving. More and more it is “us vs. them,” instead of “our borrower vs. them.” That independent voice of assessment and reason is dying off, a not only disappointing trend but also appalling.

  • Arguing u201caccountabilityu201d in the manner you do only vindicates the action of HUD. Appraisers are not and never were accountable to us or to those that engage them other than to provide their best estimate of value. They are first and foremost u201caccountableu201d to a written standard of independence, the state agencies who license them, their employer (if any), and then to those who rely on their services to their own detriment such as lenders. rnrnThe reason for the change was that government listened to the few appraisers who excused their abandonment of the standard of independence by declaring that they knowingly overvalued property to protect their streams of revenue. Rather than launching investigations into this breakdown and prosecuting accordingly, government punted and decided to place insulation between appraisers and those who were directly accused of creating the overvaluation problem. Many lenders reacted by supposedly beefing up their desk review of appraisals. Both of these steps while appearing to be responsible reactions have combined to produce a worse lending situation in the middle of a credit squeeze.rnrnSo letu2019s step back for a minute. It is not a lack of u201caccountabilityu201d to consumers and originators which AMCs have produced but rather it is the muting of two important ingredients in providing an environment of excellence in valuations, natural market selection of the best individual appraisers and the direct voice of consumers and their representatives as to the reasonableness of the opinion of value. Without these two ingredients, complacency and inferior (but u201csafeu201d) valuations result.rnrnHere is what is really needed: a restoration of the former system plus a significant strengthening of the independence standard. To excuse their lack of independence with the theme of protecting their revenue streams reminds one of the flopping seen in World Cup soccer over the last few weeks. Those appraisers should be prosecuted and disciplined through state licensing agencies and sued by lenders based on their own admissions.rnrnWe live in a world where individuals are not responsible for their own actions. Not only did the overvaluations of the past harm the parties who relied on them, but also society, other appraisers, and their own integrity so that today when some of us hear an appraiser describe his services as u201cprofessionalu201d there is a little chuckle down deep inside.rn

  • Owltree,rnrnWhat does “on my dime” mean? Who is the appraiser providing his services for, the borrower or you? With each passing day it sounds like we are losing the vision of whom it is we are serving. More and more it is “us vs. them,” instead of “our borrower vs. them.u201d That independent voice of assessment and reason is dying off, a not only disappointing trend but also appalling.rn

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