What do you get when you have three appraisers appraise one house? It sounds like the start to a cheesy real estate joke, but unfortunately there’s nothing funny about this scenario.

A home owner hired me recently for some value perspective after there were three separate appraisals done on his house for sale. Since there was a huge discrepancy between the values and contract price also, the seller wanted to find out what his house was really worth. So he hired me to review the appraisals and talk with him about the market. And yes, I have permission to share this story.

Background: His house in the Sacramento area listed at $210,000 and had 7 offers right around $210,000 (conventional, FHA & VA), and a cash offer at $198,000.  Some offers asked for 1-3% concessions back to the buyer, but others did not. The first accepted offer was $210,000 and the second was $213,000.

Appraisal #1: This appraisal came in at $192,000. The appraiser made an adjustment for a declining market and a hefty adjustment downward for being located on a feeder street too. These adjustments essentially knocked off about $10,000 in value (and they weren’t supported in my opinion). All things considered, this appraisal looked low, especially in light of a pending sale the appraiser used in the report that subsequently closed at $195,000 (and was 200 square feet smaller with less upgrades – located on the same street).

Appraisal #2: After the first buyer moved on, a second buyer came along. The contract price was $213,000 and the appraisal came in right at contract. All things considered, it just seemed the appraiser was maybe reaching for the contract price on this one. Still, it’s amazing to see a $21,000 difference between the first two appraisals.

Appraisal #3: This was a review appraisal from the second buyer’s lender, and the value came in at $185,000. The reviewer did an exterior inspection of the property and the “comps” were simply not comparable. There is nothing similar about dirty distressed sales and the subject as a clean and upgraded home. Just because something has sold nearby does not mean it is a “comp”. This appraisal was good for nothing not the highest quality I’ve seen. The buyer was actually willing to pay the difference in cash between the contract price and a potentially lower appraised value, but the review coming back at $185,000 was a huge amount for the buyer to consider paying. This reviewer was probably paid very little for the job he did, yet his appraisal ended up playing a huge role in the transaction.

Any lessons we can learn? Situations like this aren’t pretty, but there are still some important take-aways to remember in this market:

1. Appraisers, do a better job.
2. Agents, be ready to answer questions and provide market insight to appraisers when they ask you questions about one of your sales or listings. In light of low inventory, it’s critical to obtain insight from real estate agents - especially on listings. Also, here are some tips for talking with appraisers in an HVCC world.
3. Borrowers and owners, if you’ve at the receiving end of a bad appraisal, ask the lender what their process is for doing an appraisal rebuttal or challenge, and then follow their guidelines. You may need to offer new comparable sales, market data or possibly obtain a new appraisal. If the lender is not willing to work with the new data, and you feel strongly the original appraisal is not accurate, you may need to switch lenders. Keep in mind the appraisal sticks with the property for 120 days if it is an FHA loan, but that’s not the case with a conventional loan. It may be worthwhile to consult with an appraiser who is a market specialist in your area also. The appraiser cannot advocate for your cause, but can provide unbiased market research for you. Here are some tips for how to challenge a low appraisal.
4. Let’s remember that market value and price are not always the same thing – even when inventory is low. Despite multiple offers, we won’t always see properties appraise at or above contract price.
5. This market is not easy for anyone to interpret, yet it’s easy to blame various parties for a deal not working out – particularly appraisers. In the case above, the shoddy appraisal work was clearly to blame, yet that’s not always the case when a transaction goes south. All I’m saying is let’s give blame where it is due and when it is due, but be objective in our critique.

Any questions, stories or insight? Why do you think there is such a difference in appraised value in situations like this? I’d love to hear your comments below.

If you have any questions or Sacramento area real estate appraisal or property tax appeal needs, contact me by phone 916-595-3735, email, Twitter, subscribe to posts by email or “like” my page on Facebook

To give comps or not give comps? That is the question. I met up with Realtor Steve Ostrom last week and we talked about whether a real estate agent should give an appraiser “comps” or not when meeting the appraiser at the inspection. Steve talked about why he always meets the appraiser at the property and I gave some tips for interacting with appraisers around this issue. Due to HVCC, there is still some confusion over whether agents can even talk to appraisers, but they definitely can (just don’t try to pressure for a certain value). Check out the video below (or here). Let me know what you think. I’d love to hear from other agents and appraisers especially. Any questions?

NOTE: In quite a few cases the “comps” provided by real estate agents are really not all that “comparable” to the subject property. It can be valuable when agents share their market insight with appraisers, but my advice to agents is to make sure the sales really are comparable and located in the same market area. This comes back to the difference between a property that is truly competitive / comparable (“comp”) to the subject and a sale that meets a certain price level.

If you have any questions or Sacramento area real estate appraisal or property tax appeal needs, contact me by phone 916-595-3735, email, Facebook, Twitter or subscribe to posts by email.

In a post-HVCC world, there is both confusion and frustration regarding talking to appraisers. Agents can no longer directly choose an appraiser for most of their deals, so sometimes it seems like appraisal quality is left to chance. Maybe the appraiser will understand the local market or maybe he won’t. Of course the hope is the appraiser is a local expert who will do a thorough job and also initiate contact with the listing agent to ask questions about the subject property too. But that’s just not going to happen in all cases, so it’s important to be ready to talk with appraisers when you can. And yes, you can still have conversations with appraisers about your listings and the neighborhood market - just don’t pressure to “hit the number”.

Tips for talking to Appraisers:

1. Meeting: If you can’t meet an appraiser at an inspection, be available by phone or email. 
2. List of Updates: Provide a detailed list of all upgrades to the appraiser (with costs if possible).
3. Background Stuff: What helped you establish the listing price? Or why did your buyer choose this specific property and pass on others? Bring market research to the inspection to help show how you arrived at your price level. Don’t tell the appraiser which comps to use and how to do his job, but rather share information to illuminate your perspective on marketing. Say something like, “here is some market data I used in my research” as opposed to ”here are your comps”. You can always share this information on the phone or email too.
4. Offer Activity: Were there many offers or showings? What were potential buyers attracted to? Let the appraiser know things like, “I had 14 offers all above asking price in two days” or “No showings at the original list price, but then I lowered the price and had 12 showings in 4 days and 4 offers.”
5. Inside the Neighborhood: Is there something you know about the property, neighborhood, street or market area that might be helpful and contribute to the overall value? If the property is selling high above all others, why is that? Are distressed sales selling for less in the market? What are the features in the neighborhood that buyers are willing to pay more for? Share your hyper-local insight and any resources you might have.
6. Play Nice: Some agents never return phone calls or act impatient when an appraiser calls. My advice? It’s nice to talk with personable communicators.  

Things NOT to say to an Appraiser:

1. Deal Killers: Talking about another appraiser that “killed your deal” doesn’t help the current deal or paint a professional image of you in the mind of the appraiser.
2. Do your job!: “Here are the best comps” (sounds like you are trying to steer a value conclusion)
3. Higher please: “Get the value as high as possible”
4. Lower please: “Get the value as low as possible” (yes, I do hear that one)
5. Make it Happen: “Is this one going to make value?”
6. The Real Hope: “Is it going to appraise for at least the sales price?”

I hope this was helpful. I’d love to hear any tips you have too. What has worked for you? What has been frustrating for you when dealing with a post-HVCC world? Do you find most appraisers to be open to conversation? Do they ask you questions?

If you have any questions, or real estate appraisal or property tax appeal needs in the Greater Sacramento Region, contact Lundquist Appraisal by phone 916-595-3735, email, Facebook or subscribe to posts by email.

No. A property is worth what it is worth regardless of being distressed or not. With that being said, when a house is a short sale it may need to be marketed at a more aggressive price level to dump the property before a foreclosure date or offset any negative perception in the market for being a short sale. Notice though we’re talking about an aggressive ”price” and not “value”.

Here’s a good question to ask. If a short sale was not a short sale, would it sell for more? The answer is very often “yes” and that leads us to a better picture of what market value is. The truth is that properties are frequently marketed as short sales and end up generating little interest before resulting in foreclosure. But then after these same houses end up as bank-owned they generate very quick offers at or above the original short sale listing price. Of course part of this could be banks not cooperating with the short sale process and buyers tiring of waiting for months for the deal to close, but it’s hard to ignore that short sales often (not always) sell at lower levels.   

Case-in-point: I appraised a house recently in the City of Galt where competitive properties in the neighborhood showed a distinct difference between short sales and everything else. Comparable non-distressed properties were selling around $105,000-$115,000, REOs were selling mostly between $85,000-$100,000 and short sales were selling closer to $85,000-$90,000 near the bottom of the competitive range. It’s certainly true that condition and quality of updates played a role in the price differences, but it’s not an accident either that short sales were consistently finding their place near the bottom of the market.

Why is this important to understand?

1. Appraisers:  From the appraisal standpoint, if short sale comps are used in an appraisal report (without an adjustment upward), then the value in the report may be lower than what it should be. The value could really be a “quick sale” value rather than “market value”. That’s not good on many levels. Please understand though that short sales do not always sell less than fair market value, so an adjustment upward is not always warranted in an appraisal. It all depends on what is happening in the market.
2. Investors:  I just spoke with a Sacramento investor yesterday who has been growing frustrated to see some of his properties compared to bottom-of-the-market short sales by appraisers. This investor found me online and he called me to see if I had any advice on how to deal with his situation. That’ll be a different blog post, but I did give him some tips, a few which I mention below.  
3. Real Estate Agents:  I recommend real estate agents (and investors) provide a detailed list of all updates to appraisers (with costs if possible). Send this via email or provide in person to the appraiser. You can also discuss any relevant marketing information (ie.. “There were 4 full-price offers in 3 days and I am still getting calls and back-up offers”). Lastly, feel free to share market research and properties that helped you establish your listing price. Don’t tell the appraiser which comps to use and how to do his job, but rather share data that helped you establish your price so the appraiser might understand your point of view. You are allowed to talk with appraisers about property specifics and the real estate market, but don’t coerce and pressure for a certain value.
4. Sellers:  Know your market if you are selling. You will have to compete with distressed properties around you, which can impact your price, but that doesn’t necessarily mean you have to price your property the same as neighborhood short sales and REOs. A trusted real estate agent or pre-listing appraisal should be able to give you guidance to understand the market. Misunderstanding what the market is doing can cost you dearly.

What do you think? Agree? Disagree? Any stories to share?  

If you have any questions, or real estate appraisal or property tax appeal needs in the Greater Sacramento Region, contact Lundquist Appraisal by phone 916-595-3735, email, Facebook or subscribe to posts by email.

I spent the bulk of today at the YPC Vendor BBQ at the Sacramento Association of Realtors. It was a very successful event that raised over $5,100 for the scholarship fund. Nice job everyone!! I paid for a vendor booth too, so it was fun to represent, mingle with friends and meet some new faces too. There were quite a number of Realtors wondering why I had a booth since appraisers can no longer be hand-picked for loans. But the truth is there are thankfully so many other avenues of business where appraisers and agents can still connect. Here’s a one-minute video I did while at the Vendor BBQ. 

Thank you again everyone for making this day a great one. A special thank you to Michelle Kaspari of Essential Home Staging for doing an excellent job chairing this event.

If you have any real estate appraisal, consulting, or property tax appeal needs in the Greater Sacramento Region, contact me at 916.595.3735, by email, on our appraiser website or via Facebook.

My industry changed in a huge way two years ago. Many real estate appraisers are actually no longer in business because they were basically sideswiped when something called the Home Valuation Code of Conduct (HVCC) came along.

I get asked quite a bit about HVCC and how I feel about it, so I wanted to offer my two cents. This is probably not what you were expecting to hear, but HVCC has actually been a catalyst to take my business to the next level. Look, I’m not an HVCC groupie by any means, but rather than focus on the problems created for the appraisal industry due to HVCC, I have worked hard to expand niche areas of business instead. It’s in my DNA to find solutions – whether with business or community involvement. Watch the video below to hear my story.

Has your industry experienced changes in recent years? How did you respond to these changes? Why do you think some of us see opportunities during hardships while others only see threats? Is the glass half full or half empty for you?

If you have any real estate appraisal, valuation consulting, or property tax appeal needs, contact me at 916.595.3735, www.LundquistCompany.com or via Facebook.

I run into real estate agents and loan officers in the Sacramento area who say, “I wish I could still refer you business, but I can’t anymore because of HVCC.” The common thought is that because the appraisal ordering process for loans has changed in recent years (basically appraisers cannot be hand-picked by loan officers or real estate agents for specific loans geared toward Fannie Mae), that our paths cannot cross for business any more. That’s not the case though, so I wanted to give you the skinny on how we can still connect for business. I know, this post seems very self-serving, but since I have this conversation at nearly every Chamber of Commerce or real estate related networking meeting, I figured it was definitely relevant blog fodder.

1. Estate Settlement / Probate Appraisals: When an estate has a transfer of ownership due to death or inheritance, it is very common for a real estate appraisal to be needed for tax purposes. Home owners and attorneys order these types of appraisals (www.SacramentoEstateSettlement.com).

2. Divorce Appraisals: I handle appraisals during the divorce / mediation process, and I run a website at www.SacramentoDivorceAppraisals.com.

3. Property Tax Appeals: Do you know anyone who is paying too much in property taxes? Send them to me. I cover multiple counties in the Greater Sacramento Region. I founded www.SacramentoTaxAppeals.com.

4. Second opinion of value: Sometimes a second opinion of value is needed. Maybe the buyer wants an outside opinion in place of the appraisal the lender ordered. Or maybe you as the real estate agent need some additional research to help the lender see true market value. Or maybe a transaction is heading south very quickly, and some value reinforcement is needed (research or full appraisal).

5. Appraisals during a short sale: Sometimes a bank will absolutely not budge to accept an offer lower than what they deem to be acceptable (even though their price is way too high), so the Listing Agent or home owner will hire me to do a full appraisal. I wrote a full post on this topic here.

6. Pre-listing appraisals:What is the current market doing? A pre-listing appraisal helps give some perspective for the home owner or agent.

7. Home owner wants an appraisal: I’m so grateful when local real estate professionals trust me with their clients’ needs. Sometimes a home owner will want to see an actual appraisal before listing their property. Or other times an all-cash buyer wants to make sure the cash purchase is consistent with market value. Or an owner needs an appraisal for some other reason, and their trusted agent will refer the owner to me.

8. Approval List: You can get me on the approved appraiser list for your favorite lender or attorney. I had a fantastic referral this year to a really great local company. They sent me quite a bit of work and they run an excellent shop. In fact, I sent the loan officer a referral this morning because he got me on their approved appraiser list (and he does a fantastic job).

9. Bankruptcy Appraisals: If a home owner needs an appraisal during the bankruptcy process, I can certainly help them with that. Read a full post here.

I sincerely vaule the relationships I have with local Realtors, real estate agents, and loan officers in the Sacramento area, and I appreciate the business we can send to one another. If you have any questions or a need for an appraisal or property tax consulting in the Sacramento area, give me a call at 916.595.3735, send me an email, or catch me on Facebook.

What does a good referral look like for you?

There is much discussion these days about “low” appraisals and even “Appraisal Hell”. Sure enough, these issues showed up again yesterday in an article on Reuters entitled ”Special Report: What’s a home worth? Pick a number, any number“. I wanted to give a few comments about this article as well as some reasons why homes sometimes appraise for less than the agreed upon price between a buyer and seller. My two cents:

1) Price is too high:  Sometimes the agreed-upon price on a home is too high. If one buyer and seller agree to accept a certain amount for a property, the agreed upon price is not always consistent with market value. There is a real difference between price and market value because market value would gauge what a typical buyer would pay for a property, not just what one specific buyer is willing to pay. As appraiser Patrick Egger says, if you lined up 100 buyers to purchase a particular home, what would the majority of these buyers pay for the specific property? The answer to this question would probably produce a pretty good number for what the home is worth. But you might have a small pool of buyers who would be willing to pay far above asking price, right? Maybe it’s a “honey, buy this house at any cost” situation, friends or family live next door, or simply a high offer is presented to beat out all other offers. 

2) Really bad appraisal:  Let’s face it, there has been some very warranted scrutiny of the appraisal industry over the years, and especially since May 2009 when HVCC was implemented. Maybe the appraisal really was bad (inexperienced appraiser, out of the area appraiser, really quick shoddy appraisal, appraiser didn’t know the market and just guessed at value).  You know appraisals are an issue too when phrases like ”Appraisal Hell” are coined to describe that place where Borrowers go when appraisal issues hold them back from getting a loan. However, it’s important to keep in mind that a “low” appraisal isn’t always due to a bad appraisal for reasons explained in this post.

3) Strict Lending Guidelines:  The article above gives a scenario where a couple paid for seven appraisals with different lenders before deciding to call it quits (because the appraisals did not come in high enough for their loan). My heart goes out to the couple for all the money they spent, but part of me wonders if there is more to the story. I wonder why the two appraisals at asking price were deemed suspicious by two different lenders. That’s a red flag in my mind, or maybe it’s just a testimony to hyper-regulation and lenders being finicky. But maybe the appraisals looked inflated for some reason too? Guidelines in lending have certainly become more strict in recent years, especially after the housing bubble burst.

4) Counter-offer to “No Man’s Land”:  Sellers sometimes counter the buyer with a higher price despite the buyer offering at asking price. At times this counter offer works out very well, but other times it might push the property into “no man’s land” (above market value). Many experienced local real estate agents are careful about this scenario as they work with their clients. In these instances, if the appraisal “comes in low” (below the higher accepted contract price), the value might not really be low, but rather indicative of where the sales price should have been. Of course sometimes properties are marketed at lower prices in order to get multiple offers quickly, and it’s not too surprising to see that market value ends up being above the original list price in many of these cases. Ultimately, it’s nice to be able to boost up the sales price and try to fit concessions or credits in a higher sales prices, but sometimes there might not always be room to do that.

In the past few months I’ve been hired multiple times due to bad appraisals. Usually a client or local real estate agent will ask me to do a full appraisal to help give the buyer a better sense of the market (this is usually when buyer’s are coming in with a more sizable down-payment than 3.5% – FHA). Other times clients will hire me as a consultant or reviewer (no value rendered) to take a look at the original appraisal they disagree with. My job in these scenarios is to  review the report and point out some things for the original appraiser to consider.

What do you think? What has been your experience with appraisals? What is your remedy to deal with a “low” appraisal?

If you have any questions or a need for an appraisal or consulting in the Sacramento area, give me a call at 916.595.3735, send me an email, catch me on Facebook, or see my company website at www.LundquistCompany.com.

It’s my youngest son’s birthday tomorrow and it’s also the one-year anniversary of the Home Valuation Code of Conduct. People ask me all the time what I think about HVCC, so I figured on the eve of twelve months of HVCC, it would be appropriate to have a little discussion. In short, I think the Home Valuation Code of Conduct has been difficult for the appraisal industry, the consumer, and the real estate industry.

Appraisers definitely make less money now for loan work. I know, who cares, right? But listen between the lines because what if the government stepped into your industry and said you could no longer do business with clients you’ve had a relationship with for years. Many appraisers have gone out of business because their client-base was swept under the rug last year when HVCC was implemented.

Secondly, the consumer pays more for a real estate appraisal now. Under the direction of HVCC, appraisals geared toward Fannie Mae & Freddie Mac cannot be ordered directly by a lender or broker, but must be ordered from a neutral third-party (often times an AMC – Appraisal Management Company). These companies charge the consumer more than what an appraiser would typically charge, and many times pay the appraiser quite a bit less than what is customary in the market. There are some upstanding AMCs out there that I am thankful to do business with, but on the other hand it’s too bad to see some companies really taking advantage of the situation at hand. For example, I received an email yesterday from an AMC offering appraisers $125 for an appraisal order, while their website shows fees at nearly $500.

Lastly, HVCC has definitely impacted the real estate market. Since appraisers cannot be chosen directly by lenders, loan officers or brokers, the best appraiser for the job may no longer be hired. One might make the case therefore that there is a serious issue right now with the quality of real estate appraisals because of less experienced appraisers being hired to complete appraisals they are not as qualified to do. That’s definitely the case, but on the other hand I also think HVCC has been a bit of a microscope to the appraisal industry in some regards because it has illuminuated some shoddy work in the appraisal field.

Ultimately, I’m thankful that HVCC only applies to loans geared toward Fannie & Freddie (HUD/FHA has something similar in place now too). I still do many appraisals for investors, Realtors, and home owners, and these types of valuations are NOT affected at all by HVCC. Of course I’m not immune to some of the consequences of HVCC as I mentioned above, and the whole thing upsets me, but I’m choosing to focus on other things. I may be limited in business right now with what I can do for loan appraisals, but I can still chase other avenues of appraisal work such as bankruptcy, divorce, estate settlement, investor valuations, and assignments from local governmental agencies. In fact, just yesterday I had another Sacramento estate settlement retrospective appraisal come my way.

I know this almost sounds like a positive spin, but there is something philosophical here for me because it’s about focus. HVCC has been a sincere difficulty, but focusing all my attention on it and being negative won’t do me any good (and it won’t pay the bills either). Therefore HVCC won’t define me today, and it won’t be fuel on the fire tomorrow either on the one-year anniversary. Tomorrow I’ll be burning some hot dogs on a grill, enjoying the company of family as we celebrate my youngest son’s birthday, and intentionally not focusing on HVCC.

I’d like to hear from you as a real estate agent, consumer, or appraiser. How have you seen HVCC impact the real estate market over this past year?

Has a low appraisal destroyed one of your deals this year? We’ve been hearing so much about how real estate appraisers are “killing escrows” ever since the Home Valuation Code of Conduct came into effect last year. I’ve read and listened to countless horror stories from brokers, real estate agents, loan officers, and publications.

I’m not saying there aren’t legitimate complaints to be had about HVCC or certain appraisals. I simply want to provide a helpful resource to maybe clear things up a bit about what type of value appraisers are looking for in the market. My hope is that this article (linked below) will shed light on the appraisal process and give insight into the appraiser’s mind. It’s a good thing when appraisers and local agents can understand each other’s roles and mutually benefit one another.

PDF file: “Closing the Gap Between Sales Price and Appraised Value”

This article was published with permission and comes from Patrick Egger, a Certified General appraiser in Nevada with 35 years of experience in valuation, consulting and real estate studies. Comments are welcome below.

Comments in MLS can be entertaining and also telling of interesting property characteristics. Here are some gems I’ve stumbled upon recently during research that raised my eyebrows in curiosity or made me smile.

Placer County: Water for 1/2 the Year
No well for this property. Currently using irrigation water. Water available only 6 months of year. Must use bottled drinking water.

Auburn House: Where is it?
Somewhere in the junk cars and piles of metal, there is a 1 or 2 bedroom house on a flat 3/4 acre.

Yuba City Superhero Reference
Holy Clutter Batman! This short sale has amazing potential.

Yuba City Fixer: Dog Description
Hi, this is Rosie, Mama Duke’s canine assistant. I hate to say this, but this home isn’t even fit for a dog! But look past the weeds and junk and imagine this home all repaired. I could sun myself on the deck in the huge backyard in summer and lay by the fireplace in winter. Do some fixin’ and have a nice home again. Ahemm, however, in it’s as-is condition, it’s no doggone good! Enter with care and watch your step. By the way, I didn’t create the smell!

Modesto Kitchen
Fixer upper/Handyman special…Entire kitchen missing (I’ve lost count of how many times I’ve seen this in today’s market)

Thank you Realtors and agents for a bit of humor at times, but most of all thank you for being available to talk with real estate appraisers. We rely upon your insight into the local market as well as in-depth information on properties we appraise and consider for comps. It really makes a difference when you take a few minutes to thoughtfully respond to appraiser questions.

By the way, if you are still wondering if appraisers can speak with Realtors and agents due to HVCC, please read: Can Realtors Still Talk to Appraisers After May 2009? and Talking to Appraisers in an HVCC World: Tips for Real Estate Agents

I heard of AppraiserSupport today, and this website is worth a look to see one of the core complaints about the Home Valuation Code of Conduct (HVCC). Certain AMCs (Appraisal Management Companies) are charging Borrowers big money for appraisals, but then turning around and giving appraisers less than 50% of the amount charged, while pocketing the rest of the fee. Ouch!!

The AppraiserSupport website lists a handful of these AMCs - what they charge and what they pay appraisers. Don’t get me wrong though. Despite the “AMC” topic being a sore subject around many appraisers, there are definitely some upstanding AMCs out there who respect appraisers and pay them reasonable fees too (I do business with a handful of the “good guys”). It’s just unfortunate to see what some AMCs are doing because it hurts the consumer, the appraiser trying to stay afloat in this economy, and definitely the overall quality of real estate appraisals (HVCC only applies to certain types of loan appraisals). 

Have a look at www.AppraiserSupport.com and let me know what you think. And just so you know, I did not build this website.

For more on HVCC, have a look at my “Talking to Appraisers in an HVCC World: Tips for Real Estate Agents” and “Can Realtors Still Talk to Appraisers After May 2009? (HVCC went into effect on 05/01/09)“.