Modern residential lending requires much tighter focus on compliance and valuation standards than ever before.
Prior to the inception of the Home Valuation Code of Conduct in May of 2009, credit unions typically did not sell loans backed by primary residential real estate to the GSEs, and thereby felt no need to be concerned regarding compliance. Similarly, banks that portfolio their residential mortgage loans assumed the risk without fear of compliance issues.
With the sun-setting of the HVCC this past November and the introduction of Appraisal Independence Requirements within the Dodd-Frank legislation, any institution lending on primary residential property is required to comply not only with Dodd-Frank, but also with the much broader scope of the Inter-Agency Guidelines as well.
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