CUNA Regulatory Comment Call

April 8, 2008

Freddie Mac and Fannie Mae Request Comment on New Home Valuation Code of Conduct

Please feel free to fax your responses to CUNA at 202-638-7052; e-mail them to Senior Vice President and Deputy General Counsel Mary Dunn at mdunn@cuna.coop and to Senior Assistant General Counsel Jeff Bloch at jbloch@cuna.coop; or mail them to Mary and Jeff c/o CUNA’s Regulatory Advocacy Department, 601 Pennsylvania Avenue, NW, South Building, Suite 600, Washington, DC 20004-2601. You may also contact us at 800-356-9655, ext. 6732, if you would like a copy of the Code. You may also access it here.

BACKGROUND

New York Attorney General Andrew Cuomo and OFHEO recently announced that Freddie Mac and Fannie Mae have agreed to buy and guarantee mortgage loans only from lenders that follow new appraisal standards. These standards are designed to ensure that appraisals are independent and accurate and not subject to undue influence.

Freddie Mac and Fannie Mae have also agreed to fund the Independent Valuation Protection Institute (Institute), which will be a newly-formed independent entity that will operate a consumer complaint telephone hotline that will address appraisal problems. The Institute will also monitor and implement the Code, which incorporates these new appraisal standards.

DESCRIPTION OF THE CODE

Here are the key provisions that are outlined in the Code:

QUESTIONS TO CONSIDER REGARDING THE IMPLEMENTATION OF THE CODE

Eric Richard • General Counsel • (202) 508-6742 • erichard@cuna.com
Mary Mitchell Dunn • SVP & Deputy General Counsel • (202) 508-6736 • mdunn@cuna.com
Jeffrey Bloch • Assistant General Counsel • (202) 508-6732 • jbloch@cuna.com
Lilly Thomas • Assistant General Counsel • (202) 508-6733 • lthomas@cuna.com
Luke Martone • Senior Regulatory Counsel • (202) 508-6743 • lmartone@cuna.com