1. National “Full Fee Pass-Through” Rule for AMCs

Request:

Require that AMCs pass through 100% of the appraiser fee minus a capped administrative fee ($75–$100 max), permanently ending low-fee bidding and silent fee skimming.

Rationale:

• Aligns with Dodd-Frank’s “Customary & Reasonable Fee” requirement.
• Blocks AMCs from using appraisers as revenue sources.
• Restores appraisal independence.

________________________________________

2. Ban on “Lowest Bidder” and Blind Auction AMC Assignments

Request:

Prohibit AMCs from assigning orders based on lowest fee or fastest acceptance.

Rationale:

• This practice created systemic quality failures and racial-bias accusations.
• It undermines appraisal independence rules and creates unfair pressure.
________________________________________

3. Transfer Appraisal Bias Investigations Out to CFPB or FHFA

Rationale:

• CFPB regulates AMCs, lenders, and ECOA — the correct home for these cases.
• Prevents future political manipulation or fabricated “bias investigations.”
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4. Federal Requirement for a Neutral, National ROV (Reconsideration of Value) System

Request:

Create a single national portal for homeowners, lenders, and appraisers to submit, analyze, and resolve ROVs with equal rights for all parties.

Rationale:

• Eliminates ad-hoc political bias playbook.
• Creates transparency and reduces lender manipulation.
• Protects appraisers and homeowners from being weaponized.
________________________________________

5. Mandatory Evidence Threshold for Any Civil Rights Appraisal Investigation

Request:

Before any bias investigation can open, agencies must:

• verify jurisdiction
• verify lending involvement
• verify federal program connection
• obtain actual evidence (not speculation or “felt undervalued”)
• document statutory authority
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6. Independent Appraisal Review Panels
Request:

Require that all appraisal discrimination allegations be reviewed by:

• a neutral third-party
• licensed appraisers
• legal staff
• not government employees who lack appraisal knowledge

Rationale:

This brings professional oversight to the entire system.
________________________________________

7. National Review and Revision of AMC Regulations Under the CFPB
Request:

Have DOJ require CFPB to reopen and rewrite AMC rules focusing on:
• fee transparency
• anti-consumer practices
• conflict-of-interest bans
• appraiser harassment protections
• mandatory reporting lines
• strict penalties for fee skimming
________________________________________

BOTTOM LINE

• are totally realistic
• fit directly into settlement negotiations
• are tied to your documented evidence
• address the structural problems created
• improve the entire appraisal profession
• protect both homeowners and appraisers

Very well stated Anna

Steve’s situation is not an isolated incident—it exposes a systemic failure in how appraisal disputes are escalated, investigated, and ultimately prosecuted.

What happened here is not just a misstep. It reflects a breakdown in process, safeguards, and accountability that the industry can no longer ignore.

1. Failure of the Reconsideration of Value (ROV) Process

The most basic safeguard in valuation disputes—the ROV process—was completely bypassed.

The proper sequence should always be:

Submit additional comparable sales
Provide factual corrections
Request a formal reconsideration

None of that occurred.

Instead, the complaint jumped directly into:

A state regulatory complaint
A federal bias allegation

That is procedurally backwards. A valuation disagreement was escalated into an enforcement action without any attempt to resolve it at the transactional level.

2. The Real Problem: ROV Is Not Independent

Here’s the uncomfortable truth: even when ROVs are used, they are fundamentally flawed.

Most ROVs today are:

Controlled by lenders or AMCs
Influenced by transaction pressure
Lacking true neutrality

That means they are not functioning as a legitimate dispute resolution mechanism—they’re just an internal checkbox.

What the Industry Actually Needs

The ROV process must be independent. Period.

There are two viable models:

Option A: VA-Style Independent Review Model (Gold Standard)

The VA already operates a system that removes lender influence and creates a structured, neutral review process.

Key characteristics:

Centralized oversight
Separation from lender/borrower pressure
Defined escalation pathways (Tidewater / ROV framework)
Accountability tied to a federal standard

This model works because it removes the financial incentives that distort outcomes.

There is no reason a similar structure cannot be adopted more broadly across conventional and FHA-related transactions.

Option B: Independent Appraisal Review Panel

If not a federal model, then the industry needs a true third-party review panel:

Composed of experienced, vetted appraisers
Assigned randomly (no local or transactional conflicts)
Protected from regulatory retaliation
Required to issue written, supportable conclusions

This creates:

A neutral checkpoint
A documented record of analysis
A buffer between complaint and enforcement
Why This Matters

If Steve’s case had gone through an independent ROV review, one of two things would have happened:

The appraisal would have been validated → case ends immediately
Legitimate issues would have been identified → corrected at the report level

Either way, the situation never escalates into:

A state board prosecution
A federal bias allegation
A career-ending enforcement action
3. Lack of Evidentiary Threshold Before Escalation

There appears to have been no requirement for:

Objective market-based rebuttal
Demonstrable USPAP violations
Evidence of discriminatory conduct

A complaint alone should not trigger enforcement.

Without:

Verified data errors
Methodological deficiencies
Ethical violations

the system is no longer regulatory—it becomes punitive.

4. Chilling Effect on Expert Participation

Two MAI-designated appraisers reviewed the report and agreed it was well-supported—but refused to testify.

That is a serious problem.

When qualified experts:

Agree with the work
But won’t step forward

it signals fear—plain and simple.

Without expert participation:

Due process breaks down
Defense becomes impossible
Outcomes become one-sided

The industry cannot function if experts are effectively silenced.

5. Disproportionate Enforcement vs. Market Reality

The final sale tells the story:

Appraised value (2020): $164,000
Sale price: $185,000

That difference is well within normal market movement.

The market validated the appraisal.

Yet enforcement proceeded anyway.

That raises a serious question:
What standard is actually being used to determine wrongdoing?

6. Pursuit of Discipline After Exit from the Profession

Continuing enforcement after:

Medical disability
License non-renewal
Exit from practice

serves no meaningful public protection purpose.

At that point, it’s administrative persistence—not consumer protection.

Bottom Line

This case highlights a dangerous shift:

Complaints are being advanced without filtering
ROV processes are ineffective or bypassed
Experts are afraid to participate
Enforcement continues even when market data validates the appraisal
The Fix Is Not Complicated—But It Requires Structural Change

The industry needs to implement:

1. Mandatory Independent ROV Review

No complaint should move forward without:

Exhausting an independent ROV process
Documented third-party review
2. Separation from Transactional Influence

ROVs must be removed from:

Lenders
AMCs
Borrower pressure
3. Protected Expert Participation

Experts must be able to:

Review
Testify
Participate

without fear of retaliation.

4. Clear Evidentiary Thresholds

No investigation should begin without:

Data-supported claims
Identifiable USPAP issues
Objective deficiencies
Final Thought

Steve’s case is not about one appraiser—it’s about whether this profession continues to operate on:

Data
Methodology
Independent analysis

or shifts toward:

Complaint-driven enforcement
Process shortcuts
Outcome-based discipline

Right now, the system is drifting toward the latter.

An independent ROV framework—modeled after the VA or built through a neutral review panel—is the correction mechanism the industry needs immediately.

Without it, cases like this won’t be rare—they’ll become routine.

Of course I know their names. I could easily find their addresses. Members of state professional boards are basically immune to civil action, so what’s the point?

Sorry this happened to you Steve. The state of the appraisal industry. Unlike other industries where trade groups and other members highlight and rally to others defense, tap into their treasuries to help struggling people out, form outreach programs, do their best to save their own people, save their business and income positions, advocate on their behalf. That’s not happening with appraisal. Instead we get a never ending lecture about ‘stake holder interests’ while ten thousand small businesses are systematically wiped out every few years, never ending stories of false accusations, all are proven wrong years later.

TAF and the Appraisal Institute have enough funds they could have really helped. Put forth group savings programs, provided independents their own special program access for retirement, medical, insurance, disabled care sort of programs. Put forth legal defense strategies that worked. They could have made a difference in regulatory and legislation activity at the national level that actually mattered. Instead they helped their own insiders capture the lions share of gse work, pandered and paid the same lawyers pursuing innocent appraisers, traveled around the world, peddled influence. Three cheers for the evolved beltway organisms. Chair swapping did not solve anything. What could have been… These people are not ethical experts. Far from it. They represent only their own best interests and nobody elses.

File a seriously well documented complaint against the realty agents and mortgage lenders involved with all this, keep filing that up the ladder. Especially when there is nothing left to lose, time for accountability to come due.

Good to see other appraisers understanding the big picture here. Great post ERME.

Just when we thought things could not get any worse. This; Executive order 03/13/2026; Promoting Access To Mortgage Credit.

I don’t need to spell this out in detail for experienced appraisers, you already know what’s coming. If you thought FHFA directing less use of full service appraisers was troubling, get ready for this. Appraisal modernization just went next level. As far as what else is contained here outside of what I copied below, would be interested to hear others opinions, good or bad?

(Southern rebel voice;) The Demins will rise again! Hey wait…. I thought we did not want that? Pack it up and go home, turn the lights off on your way out. The end is near in the gse space. Data cancer is also here to stay for the time being.

Presidential advisors… The appraisal trade groups failed in their duty to promote a well functioning appraisal industry, yet again. One ponders if they even bothered showing up or perhaps actually asked for this sort of thing. Instead of any attention to save the ten to twenty thousand appraisal small businesses currently going under, we get weekly emails about getting to know the board members. As if somehow personalizing the people whom allow all the rest of us to go out of business somehow provides a positive pr spin to the systemic imbalance. These changes are going up the ladder far beyond the gse realm with this one.
_____________________

https://www.whitehouse.gov/presidential-actions/2026/03/promoting-access-to-mortgage-credit/

Sec. 6. Appraisal Modernization. (a) The Vice Chairman for Supervision of the Federal Reserve, the Director of the CFPB, the Chairman of the NCUA Board, the Chairperson of Board of Directors of the FDIC, the Comptroller of the Currency, and the Director of the FHFA shall consider, as appropriate and consistent with applicable law and their statutory authorities:

(i) modernizing appraisal regulations and guidance to expand the use of alternative valuation models, desktop and hybrid appraisals, and artificial intelligence valuation tools;

(ii) simplifying appraiser qualification requirements; and

(iii) reducing appraisal requirements for low-risk transactions, including low loan-to-value refinancing and small‑balance loans; and setting clear appraisal timelines.

(b) The Secretary of Housing and Urban Development (HUD) and the Secretary of Veterans Affairs (VA) shall consider, as appropriate and consistent with applicable law:

(i) aligning appraisal standards between the Federal Housing Administration and VA Home Loan Program where risk is comparable;

(ii) clarifying the distinction in an appraisal inspection between safety and habitability concerns that necessitate pre-closing repairs versus cosmetic concerns; and

(iii) expanding post-closing repair flexibility.
___________________

This is an interesting somewhat related article regarding automation and artificial intelligence utility. Published from Malwarebytes security labs recently. Did not take long for privacy and digital data security people within the general public to grow rather weary of these new tools. The AI tools immediately abused, as predicted they would be. Yet the gse’s are full speed ahead with the blinders on anyways, also predictable.

https://www.malwarebytes.com/blog/privacy/2026/03/90-of-people-dont-trust-ai-with-their-data

Rather than value shopping based on comp searching for individual deals with individual appraisers, one licensed appraiser communicating with one licensed mortgage broker, leaving licensed brokers exposed to liability, the value shopping is now based on ‘appraiser performance grading’. Statistical based tie ins with frequency of revision, unaccepted orders, shared grading among disassociated clients, managed through centralized tech systems. Among dozens of other performance measurements, when combined, provide a clear indicator whom advocates for the deal and whom does not.

Tiered status of vendors, in turn promoting unnecessary outsourcing and corner cutting, a result of grossly imbalanced appraisal ordering distribution. This eroded the trust of the public, compromised the viability of small business appraisers, drove quality standards down to the point complete substituting with automation can be excused away as a necessary activity.

An additional side benefit of skirting junk fee and unearned fee billing rules for a few extra billion to go atop the trillions of increasingly unserviceable debt which is the American housing markets. For as good as these companies are at keeping statistical track of appraisers individual performance, they remain mysteriously unable to keep track of the relationships of their industries influence on ever rising notices of election and demand, default rates, etc. Because they win on the back end as well, now amc’s are exclusively in charge of default management for FNMA. And if the amc’s are not getting the reo work, first purchase opportunities of defaulting loans are channeled directly at fire sale pricing to corporate investors. The Whole Loan program. Your calculator does not have enough spaces to accommodate all the zeros if one attempts to add up how much principal debt has moved through that system.

Amc’s, the long arm of predatory lending. In order to compete in this space, many lenders whom did not use amc’s or use them as frequently, have also adopted these methods. Amc’s inability to complete their intended task of providing separation from mortgage loan production influence reshaped the industries involved in housing, lending, valuation services, far beyond the amc’s intended scope of participation, which the now inadequate regulatory amc oversight was based upon. Subsequently the amc’s exist in a mostly unregulated space, having gained enough control to influence policy making from the top down through multiple industries.

Appraisers whom are caught up in the aftermath of this now well established pressure based system are merely collateral damage. Lenders exist in a corporate space which individual appraisers are unable to mount sustainable challenges, with inadequate attention from governing agencies, something the IVPI Proposal specifically set to counter by creating an independent institution more resilient to influence peddling. Appraisal trade groups capitulated to stake holder interests, accepting the loss of tens of thousands of their own constituent appraisers small businesses. Policy for sale. Consumers are the most harmed, having no recourse, now facing more uncertainty than ever in an accelerated housing market with steep affordability and trust based challenges that yet again is beginning to unravel.

One interesting and still effective way to counter false claims is to adhere to original uspap tenants of a self contained report rather than utilizing summary reporting strategy. The methods that approach requires are contrary to the principals of modernization, to take longer, provide greater detail, and in turn better liability protection and report defensibility, a more reliable appraisal product. This is how the best of the appraisers left are driven out of the GSE space, subjected to endless restraint of trade policies due to ongoing Sherman Act violations and various other forms of institutional level racketeering.

Missing the IVPI proposal yet?
https://www.workingre.com/wp-content/uploads/2013/08/IVPI-Proposalfinal.pdf

The tangled web of a dysfunctional regulatory system. Image attached. Some say if you can’t beat them, join them instead. Yet interestingly enough the appraisal industry still manages to attract and retain people whom truly do believe in honest business dealings, whom have a dream of managing their own small business, carving out personal independence. The self proclaimed appraisal industry representatives are currently trying to convince appraisers to go with a franchise model, make everyone an employee. Ignoring the reasons for an appraisal licensing program in the first place, to give appraisers space to operate independently apart from lender and employer type influences. So that appraisers would not have to advocate or provide things of value to remain employed. The management rule in uspap. Again, exactly what the IVPI proposal set to counter, an attempt to fulfill the original intention of the national appraiser licensing program.

https://www.danielgreenfield.org/2026/03/mamdani-proposes-white-homes-estate-tax.html

Best comment I’ve read anywhere, any time.

Try “unjustified”

It happens in Red States too. Alabama has the same enforcement attitude.

What is happening to this profession is not a misunderstanding or a slow drift. It is a deliberate dismantling of the only safeguard that ever stood between the mortgage industry and unchecked exploitation of the American taxpayer. I watched it unfold for four decades. The pattern is too consistent to be coincidence.

The profession never built unity. It never built loyalty. It never built the collective backbone needed to defend itself. You cannot fight a coordinated assault when the dominant mindset is every man for himself. People talk because talk is easy. Talk gives the illusion of solidarity. But when it comes time to act, the momentum dies. The profession is loud in conversation and silent in courage.

Too many appraisers believe the path to success is undercutting fees to levels that belonged to another century. They think they are winning business. They are actually sawing off the branch they are sitting on. They are dragging their peers down with them and they cannot see it. That blindness is just one of many reasons the profession is collapsing under its own weight.

While appraisers have been busy fighting each other for scraps, the groups that want them gone have been organized, strategic, and relentless. They see appraisers as an obstacle to profit. They have spent years shaping the narrative, pulling in media, politicians, lenders, HUD, Fannie, Freddie, and the public to paint appraisers as the enemy. They have turned the last gatekeeper into a villain because a villain is easier to eliminate.

Money drives the mortgage industry and the erosion of the profession is not subtle. It is systematic. It is intentional. And it is almost complete.

The final blow has been the accusation that all appraisers are biased and racist. This message has been repeated so often that it has become accepted without evidence. It has poisoned public trust even though no coordinated wrongdoing has ever been shown. When evidence fails to appear, the accusation shifts to unconscious bias, a convenient phrase that allows guilt to be implied without proof. It is a tactic designed to make every appraiser defenseless. You cannot disprove something you are told you are guilty of without knowing it.

This is smoke and mirrors. It is a manufactured crisis. And the endgame is simple. Replace the human gatekeeper with AI that can be shaped to deliver whatever values the system wants. No questions. No resistance. No accountability. Just numbers that serve the interests of those who benefit from a world without oversight.

This is not a warning from the outside. It is the testimony of someone who watched the walls close in from the inside for forty years.