National Association of Realtors - Appraisers Blogs

Appraiser Independence: What Does it Mean & Who Does it Apply to

Guest Author — Mon, 31 Aug 2026 12:30:57 +0000

Why It Matters Appraiser independence is mandated by state and federal laws – not a professional courtesy. Every agent, broker, loan officer, lender and AMC involved in a transaction with a lender-ordered appraisal is legally prohibited from influencing the appraiser’s value conclusion and from interfering in the appraisal process. Violations can cost you your license, trigger federal civil penalties, NAR sanctions, civil liability, and in extreme cases, criminal prosecution.1 “I didn’t know” is not a defense. The Legal Foundation Three federal frameworks govern this area. Title XI of FIRREA (1989) requires all appraisals for federally related transactions to be performed...

No I Won't Work With This Appraiser How much power do agents have over the appraisal process? The lender gets a call. Agent tells them that appraiser…
Violating Appraisal Independence Through Harassment,… It shall be unlawful... to engage in any act or practice that violates appraisal independence... Appraisers, I have written the…
Expert Wants to “Eliminate” Appraisers Mortgage Industry Expert Wants to “Eliminate” Appraisers – A Response The National Mortgage News website just published an interview with…

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NAR Calls Out Unregulated Middlemen: A Wake-Up Call for FHFA

AppraisersBlogs — Thu, 02 Oct 2025 12:30:27 +0000

When unregulated middlemen run the show, appraisers get ghosted, consumers get duped, and regulators get a velvet-gloved slap from NAR. In a housing market that demands clarity, Appraisal Management Companies, or AMCs, continue to operate like the magician’s assistant, always present, rarely transparent, and somehow still part of the act. But the National Association of REALTORS® (NAR) just handed the Federal Housing Finance Agency (FHFA) a letter that reads less like a polite memo and more like a velvet-gloved slap. It’s a bold call to rein in AMC antics and restore dignity to the appraisers who keep the system honest....

A Review of MEIN COMP: The Last Appraiser If Orwell moonlighted as an appraiser, and Kafka had a side hustle in compliance, "MEIN COMP: The Last Appraiser" by…
Dear Representative, FNMA Has Gone Rogue! Dear representative, waiving/eliminating property appraisal for lending purposes is wanton recklessness. Fannie Mae’s decision to waive/eliminate property appraisal for lending…
Tapping States for Backchannel Budget Scofflaw U.S. Agency Taps States For Its Backchannel Budget VENTURA, Calif. (February 4, 2022) – History is replete with cautionary…

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The Great Debate on Appraisal Fees

Isaac Peck — Mon, 28 Oct 2024 12:30:09 +0000

She included several different fee split examples indicating AMCs retained as much as 70 percent of the total appraisal fee paid by the borrower, which prompted her to stop working with AMCs because of the lack of transparency. The appraisal industry is abuzz with a discussion about appraisal fees. The Consumer Financial Protection Bureau (CFPB) recently issued a Request for Information Regarding Fees Imposed in Residential Mortgage Transactions [Docket No. CFPB-2024-0021] in which it solicited feedback from the public and industry stakeholders on the fees charged to consumers by mortgage providers and related settlement services. The CFPB framed it as...

Appraisal Regulation Compliance Council Exposes… The Appraisal Regulation Compliance Council published a detailed breakdown to the CFPB, which showed the median average AMC fee being…
Lack of Fee Transparency: Exposing the AMC Exploitation By keeping the borrower in the dark about the true cost of the appraisal, the AMCs are able to charge…
AMCs Billing Scheme, Hidden Profits & Deceptive Practices Appraisers who do not agree to their hidden billing methods are excluded from the majority of the GSE lending marketplace…

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Insights from CFPB’s Public Comment Period

AppraisersBlogs — Tue, 13 Aug 2024 12:30:20 +0000

The comment period on the Consumer Financial Protection Bureau’s (CFPB) “Request for Information Regarding Fees Imposed in Residential Mortgage Transactions” concluded on August 2, 2024, with a total of 959 comments received. Upon reviewing some of these submissions, several noteworthy perspectives emerged regarding appraisal fees and the role of Appraisal Management Companies (AMCs). The National Association of REALTORS® (NAR) highlighted the lack of transparency surrounding AMC fees, which are often bundled together with the actual appraisal fee on the Closing Disclosure (CD). This opaque structure prevents consumers from understanding the true cost of the appraisal service and hinders their ability...

Lack of Fee Transparency: Exposing the AMC Exploitation By keeping the borrower in the dark about the true cost of the appraisal, the AMCs are able to charge…
The Illogical Reality of Mortgage Appraisal Reviews Reforming the appraisal review process is essential to maintaining the integrity of the real estate market and protecting consumers and…
Exposing Predatory AMCs Exposing the inner workings of these predatory AMCs and their corrosive influence on the housing market. Cindy Chance's recent comments…

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The Lack of Transparency in Appraiser Compensation

AppraisersBlogs — Wed, 06 Mar 2024 13:30:15 +0000

The current system of bundling appraiser compensation with third-party fees can lead to confusion and frustration for both appraisers and consumers. In their letter to the ASC, NAR highlighted the importance of appropriate compensation for appraisers. They stated that fair and reasonable compensation is critical to attracting and retaining high-quality appraisers, as well as allowing them to invest in their skills and education. However, the current system lacks transparency when it comes to reporting appraiser compensation. The issue lies in the TILA-RESPA Integrated Disclosures (TRID) form, which requires an aggregate appraisal fee to be reported. This means that the fee...

Appraisers Not to Disclose AMC Fee? An appraiser/reader sends me this text from an XOME appraisal request: Good Morning, The state of NY requires the appraiser…
AMCs Billing Scheme, Hidden Profits & Deceptive Practices Appraisers who do not agree to their hidden billing methods are excluded from the majority of the GSE lending marketplace…
AMC Fee Impact on Appraisal Fee While the borrower was charged $695 for the appraisal, the appraiser was only paid $301. The AMC fee was $394. …

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Seller Filed a Racial Bias Complaint Against Me

Guest Author — Tue, 07 Nov 2023 13:30:08 +0000

So what’s caused the sudden loss of income? Could it be because of the racial bias complaint filed against me by an unhappy Seller… Fannie Mae accomplished what they set out to do in July 2011, when they initiated their Uniform Appraisal Dataset (UAD) and the Uniform Collateral Data Portal. The goal was to collect enough property data to effectively remove appraisers from the home buying and refinancing process. It all started with Dodd-Frank Act, a several hundred pages Act signed into law by then President Obama, sold to unsuspecting Americans as a protection from the corrupt business practices of...

Low Appraised Value = Racial Bias? When the appraised value didn’t meet the sale price, the first assumption was that the appraiser conspired to lower the…
The Town With No Bank: How Rural America Lost Its… For decades, we’ve been told that the problem is demand. That people don’t want to live in rural America anymore.…
Uncovering Flaws in FHA Appraisal & Loan Review Process The story of this single mother's harrowing experience with a defective home purchase and HUD's negligent oversight exposes deep flaws…

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Agent Management Company, a Familiar Ring

Guest Author — Fri, 03 Nov 2023 12:30:05 +0000

We will call it “AGENT MANAGEMENT COMPANY”. We will ensure that the use of runners is prohibited… Public trust. It’s a real thing. It appears that this recent lawsuit that the NAR LOST has exposed antitrust, collusion and price fixing between agents. I am thinking about creating a new AMC. We will call it an “AGENT MANAGEMENT COMPANY”. We will create a buffer per say between the buyers agent and the sellers agent thereby protecting the buyer and seller. We will have a roster of approved agents nationwide. They will be thoroughly vetted. Routinely background checked. Ensure they are fully...

The Town With No Bank: How Rural America Lost Its… For decades, we’ve been told that the problem is demand. That people don’t want to live in rural America anymore.…
The Great Debate on Appraisal Fees She included several different fee split examples indicating AMCs retained as much as 70 percent of the total appraisal fee…
Uncovering Flaws in FHA Appraisal & Loan Review Process The story of this single mother's harrowing experience with a defective home purchase and HUD's negligent oversight exposes deep flaws…

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NAR Concerns & Survey on Property Data Collectors

AppraisersBlogs — Mon, 05 Jun 2023 12:30:58 +0000

NAR is conducting a survey and wants to know if you have any concerns regarding property data collectors, if the appraisal fees are higher since the involvement of data collectors, if borrowers are made aware of a fee for the appraisal and a separate AMC fee or were the fees bundled, if the property data collector gave the impression that they were the appraiser, whether you have any safety and privacy concerns with the data collection process, quality of data collected and whether they need to be licensed… In a letter to the Federal Housing Finance Agency (FHFA) regarding appraisal...

Fannie Mae Filed a Complaint Against Me An appraiser shared the following with us which was posted on one of the appraisers’ groups. Fannie Mae filed a…
Property Valuation and the Future of Data Collection Property valuation is shifting fast, and the push to regulate who collects the data inside people’s homes will determine whether…
Uncovering Flaws in FHA Appraisal & Loan Review Process The story of this single mother's harrowing experience with a defective home purchase and HUD's negligent oversight exposes deep flaws…

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‘Clean-Slate’ Laws, Bad Policy Could Dispatch More Felons to Borrowers’ Homes

Jeremy Bagott — Thu, 18 May 2023 12:30:02 +0000

The idea of unlicensed individuals being hired off the streets and paid a pittance to video and photograph the interiors of borrowers’ homes, which would include the exact location of valuables and children’s bedrooms, has been unsettling to some. An astute real estate broker recognized the name of a Michigan man awaiting sentencing in an armored-car robbery. The latter had been engaged by one of six companies authorized by mortgage giant Fannie Mae to dispatch so-called “data collectors” to borrowers’ homes. The broker alerted the bank and the National Association of Realtors. New, progressive laws designed to conceal felony convictions...

The New & Improved Fannie Mae “FRAUDULATOR 2.0” Originally known as Fannie Mae’s Collateral Underwriter (CU), and subsequently Collateral Underwriter 2.0 (CU-2)i this always dubious product of Fannie…
Fannie Wants to Script Conclusions of Outside… Government-sponsored mortgage giant Fannie Mae is essentially forcing banks to repurchase any loan it wants if [the appraiser] refuses to…
The Town With No Bank: How Rural America Lost Its… For decades, we’ve been told that the problem is demand. That people don’t want to live in rural America anymore.…

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Look in the Mirror

Mark Skapinetz — Mon, 27 Feb 2023 13:30:14 +0000

The phrase “take a look in the mirror” is a common idiom used to encourage self-reflection and introspection. It is a powerful statement that can evoke a range of emotions and reactions from individuals, from contemplation to defensiveness. At its core, the phrase is a call to examine oneself honestly and objectively. It asks us to step back from our assumptions, biases, and preconceptions and consider our behavior, choices, and beliefs in a critical light. When we take a look in the mirror, we are forced to confront our flaws and shortcomings, but also to recognize our strengths and achievements....

Security Bars Removal Law Debunks Alleged Racial… Complainant stated appraiser told them they should remove security bars from windows. Complainant stated this is evidence of "racist discrimination"...…
From Data to Value: How Mass Appraisal Delivers Fair… Behind every annual notice of assessments is a complex valuation system most property owners never realize exists. The Appraisal Foundation…
Fannie Mae 'Census Block Grid' Adjustment Raises… "FNMA’s collateral underwriter tool has a line item adjustment it makes on every comparable called Census Block Grid." In a…

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NAR Appraisal Survey

AppraisersBlogs — Fri, 14 Oct 2022 12:30:07 +0000

The results of the NAR appraisal survey show more than half of appraisers reported AMCs to be the greatest challenge in their business with 40% reporting not being compensated fairly. Only 3% of members witnessed or experienced discrimination in an appraisal… NAR Research conducted a survey of all 9,700 appraiser members and 50,000 randomly-selected non-appraiser members to determine the level of impact of appraisals on the current market and member business in terms of cost, turn-around times, and other challenges and to measure member experiences with bias and discrimination in the appraisal process. Highlights of the NAR Appraisal Survey The...

Racial Bias in Real Estate: Is it the Appraisers’ Fault? In the past year, the appraisal industry has been under attack from various academics who claim “racial bias” on the…
AMCs Take a Sizable Cut of the Appraisal Fee It still proves my point: Appraisal Management Companies take a sizable Cut of the appraisal fee... It was March 28th,…
Are AMCs Value-Adding? The Federal Housing Finance Agency has released a working paper "Are Appraisal Management Companies Value-Adding? – Stylized Facts from AMC…

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Biased Appraisers? I Don’t Think So

Dave Towne — Wed, 18 May 2022 12:30:48 +0000

To judge an entire profession by anecdotal evidence is equally both stupid and harmful… The entire emphasis was on “anecdotal evidence” which is not documented or supported. Story after story was told about how appraisers had produced a “biased” report. No documentation and no evidence to support their claims was presented. Folks, after discussing this topic with and learning more about the appraiser who wrote this following essay, I have decided to distribute the essay below as a way to further support what we appraisers do in our work, and to expose the fallacies that have been presented to date...

HUD Dismisses Claims Alleging Racism ...white America (government) keeps trying to 'fix' Black People who are not broken in the first place! We’ve all heard…
How to Destroy the Appraisal Profession Anytime the government gets involved in an issue, it tends to have more adverse effects than positive ones. It makes…
Sales Comparison Approach is Racist "...the modern appraisal industry perpetuates racial inequality through its continued use of the “sales comparison approach”... the sales comparison approach…

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NAR Report Paints a Different Picture

AppraisersBlogs — Mon, 07 Mar 2022 13:30:47 +0000

The study also shows the appraisal was the LOWEST scored item on the list of discriminatory practices… On February 23, 2022, NAR published the “2022 Snapshot of Race and Home Buying in America” report. The study examines homeownership trends and challenges by race and location to explain current racial disparities in the housing market. Using data from the 2021 Profile of Home Buyers and Sellers, the report looks at the characteristics of who purchases homes, why they purchase, what they purchase and the financial background for buyers based on race. The study noted that for those who said they witnessed...

The Real Cause of the Home Value Gap Is the Income Gap Blaming appraisers for the income gap will never solve the real underlying problem... Blaming appraisers for the income gap is…
The One-Mile Rule: Prudent Policy or Modern Day Redlining? ...whether through redlined maps or implicit "one-mile rule," the result can be undervalued properties in historically marginalized neighborhoods. Throughout the…
The Town With No Bank: How Rural America Lost Its… For decades, we’ve been told that the problem is demand. That people don’t want to live in rural America anymore.…

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NAR and Representation of Appraisers

Guest Author — Mon, 21 Feb 2022 13:30:19 +0000

As Real Estate Appraisers, we are encountering an assault on our profession from the GSE’s with the hybrid appraisal reports, the rollout of the new desktop product and with appraisal waivers. These junk reports and the waivers continue to undermine the public trust in our industry and leave the appraisers exposed to great risk and the consumers left holding the bag if their mortgage goes south. This impacts not just us, but the Real Estate profession as a whole, because if the public loses trust in the industry, we will all lose, not just the appraisers. As appraisers, we need...

It’s Time to Take Out the Junk: AMC Practices Exposed Appraisers have spent years carrying the weight of broken AMC practices, and this article pulls every one of those practices…
The Great Debate on Appraisal Fees She included several different fee split examples indicating AMCs retained as much as 70 percent of the total appraisal fee…
The Town With No Bank: How Rural America Lost Its… For decades, we’ve been told that the problem is demand. That people don’t want to live in rural America anymore.…

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Racial Bias Narrative to Remove Appraisers

Guest Author — Mon, 21 Jun 2021 12:30:27 +0000

…the racial bias narrative will be what is utilized to remove appraisers from the lending equation… Removing us will finally put the FOX completely in charge of the HEN HOUSE…this entire narrative could very well end up costing us all, our way to make a living… Unfortunately, Professional Appraisers have no organized voice and I don’t see that we ever will. There is no one to defend us. And that has been used against us for years. After all that Appraisers have been through over the last 15 years, the racial bias narrative and the allegations of racial discrimination in...

Uncovering Flaws in FHA Appraisal & Loan Review Process The story of this single mother's harrowing experience with a defective home purchase and HUD's negligent oversight exposes deep flaws…
USPAP’s Typical Buyer Standard in the Fair Housing Era The Irreconcilable Conflict Between USPAP's Typical Buyer Standard and the Current Fair Housing Compliance Regime. Retain this document as a…
Security Bars Removal Law Debunks Alleged Racial… Complainant stated appraiser told them they should remove security bars from windows. Complainant stated this is evidence of "racist discrimination"...…

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Train Us and Trust Us

Hamp Thomas — Fri, 12 Mar 2021 13:30:38 +0000

The most weighted technique in most automated valuation programs comes down to one over-simplified formula, based on a guesstimation from an outside source that has no interest in the real estate system… Dear FHFA: Please accept the following comments in regard to Question A1.4. The response also includes comments on several additional questions. Thank you for taking the time to review these thoughts. Technology has made so many improvements in the last decade and we now have the chance to truly improve our home valuation system. With that being said, the last piece of the quality puzzle starts at the...

The New & Improved Fannie Mae “FRAUDULATOR 2.0” Originally known as Fannie Mae’s Collateral Underwriter (CU), and subsequently Collateral Underwriter 2.0 (CU-2)i this always dubious product of Fannie…
Promoting False "Racist Appraiser" Narrative Some Lenders promoting false "racist appraiser" narrative to optimize profits via AVMs Like most businesses lenders want to optimize their…
The Town With No Bank: How Rural America Lost Its… For decades, we’ve been told that the problem is demand. That people don’t want to live in rural America anymore.…

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Biden Calls Out Racial Bias Among Appraisers

Dave Towne — Wed, 11 Nov 2020 13:30:28 +0000

To counteract low appraisals in minority neighborhoods, Biden says he’ll push for training to address racial bias among appraisers… Appraisers, you might want to “take a gander” at this article in the link below, because it indicates possible/probable changes coming. I especially like the ‘extra training for appraisers’ to avoid discrimination/racial bias. Not. In other words, appraisers are at fault for lower values in certain neighborhoods which are not as highly valued as others, and so we must be indoctrinated to be more sensitive. Buckle up folks, as it’s going to be an interesting ride. Excerpt from Biden Admin and...

The Real Cause of the Home Value Gap Is the Income Gap Blaming appraisers for the income gap will never solve the real underlying problem... Blaming appraisers for the income gap is…
The Town With No Bank: How Rural America Lost Its… For decades, we’ve been told that the problem is demand. That people don’t want to live in rural America anymore.…
Sales Comparison Approach is Racist "...the modern appraisal industry perpetuates racial inequality through its continued use of the “sales comparison approach”... the sales comparison approach…

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Another ‘Pile on Appraisers’ Diatribe?

Dave Towne — Mon, 10 Aug 2020 12:30:02 +0000

The National Association of Realtors held their “Virtual Appraisal Summit” on Aug. 5, 2020, focusing on ‘fair housing and the appraisal industry.’ We were fortunate to have Craig Morley, President of the National Association of Appraisers, represent us appraisers, but his presentation was only scheduled for 15 minutes. I’m hoping when he sees this message, he will provide more info about his presentation and the outcome of the “Summit.” Craig’s presentation had the title: Abilities and Limitations of Appraising Real Estate Under Today’s Rules Craig Morley, Managing Partner, Accurity Valuation/Morley & McConkie, LLC I’m just hoping that this Summit was...

Is Race Baked into Big Data? Chicago appraiser and friend (even though she calls me “fancy pants”) writes a stellar explanation of what an appraiser actual…
Appraisers Don't Use Race Appraisers don’t use race... Race is NEVER considered during a valuation Last week in a congressional hearing on the future…
USPAP’s Typical Buyer Standard in the Fair Housing Era The Irreconcilable Conflict Between USPAP's Typical Buyer Standard and the Current Fair Housing Compliance Regime. Retain this document as a…

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GAO to Investigate Appraisal Loopholes

VaCAP Board — Fri, 21 Feb 2020 13:30:32 +0000

…Arizona is seeking damages and penalties against CoesterVMS… GAO has agreed to complete the study… Maxine Waters and Congressman William Lacy Clay requested a formal study/investigation into Title XI (FIRREA) and the recent dilution of its intent by the Federal Agencies. VaCAP has learned GAO has agreed to complete the study. The Network of State Coalitions has sent the following to their state members: This is the result of so many voices – the Foundation, ASA, coalitions, NAR, etc. Our Network efforts have given us an inside connection that hopefully we can continue to build on. Our meeting in DC...

Coester Loses in Court! Gosh... I’m really sad to bring you this news (sarcasm). Brian Coester Loses in Court! About 2 years ago, Georgia…
The Collective Rot Over 11,000 appraisers signed that petition... The US Congress completely ignored it and, as a result, The Great Real Estate Depression…
FIRREA Under Attack! ...the federal agencies charged with implementing Title XI of FIRREA have taken steps to limit the number of transactions for…

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FIRREA Under Attack!

VaCAP Board — Thu, 13 Feb 2020 13:30:15 +0000

…the federal agencies charged with implementing Title XI of FIRREA have taken steps to limit the number of transactions for which an appraisal is required… Congresswoman Maxine Waters and Congressman William Lacy Clay request a formal study/investigation into Title XI (FIRREA) and the recent dilution of its intent by the Federal Agencies. The letter to Gene Dodaro, Comptroller General, Government Accountability Office, addresses threshold increases, regulatory exemptions, appraisal waivers, the North Dakota appraiser certification waiver and evaluations in lieu of an appraisal. It is clear the Chairwoman of the House Financial Services Committee and Subcommittee Chairman on Housing, Community Development and Insurance...

The Town With No Bank: How Rural America Lost Its… For decades, we’ve been told that the problem is demand. That people don’t want to live in rural America anymore.…
Uncovering Flaws in FHA Appraisal & Loan Review Process The story of this single mother's harrowing experience with a defective home purchase and HUD's negligent oversight exposes deep flaws…
Federal Agency in Charge of Appraisers Having a federal agency in charge of appraisers will be a NIGHTMARE. Leave it to the states as it is…

The post FIRREA Under Attack! appeared on Appraisers Blogs.

National Association of Realtors - Appraisers Blogs

Appraiser Independence: What Does it Mean & Who Does it Apply to

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NAR Calls Out Unregulated Middlemen: A Wake-Up Call for FHFA

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The Great Debate on Appraisal Fees

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Insights from CFPB’s Public Comment Period

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The Lack of Transparency in Appraiser Compensation

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Seller Filed a Racial Bias Complaint Against Me

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Agent Management Company, a Familiar Ring

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NAR Concerns & Survey on Property Data Collectors

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‘Clean-Slate’ Laws, Bad Policy Could Dispatch More Felons to Borrowers’ Homes

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Look in the Mirror

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NAR Appraisal Survey

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Biased Appraisers? I Don’t Think So

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NAR Report Paints a Different Picture

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NAR and Representation of Appraisers

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Racial Bias Narrative to Remove Appraisers

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Train Us and Trust Us

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Biden Calls Out Racial Bias Among Appraisers

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Another ‘Pile on Appraisers’ Diatribe?

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GAO to Investigate Appraisal Loopholes

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FIRREA Under Attack!

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