This is so funny. FNMA is now sending out a 3.6 readiness survey.

These are not the type of questions one asks of a well managed well implemented program. (image) Gave that image snip a fitting title too.

Talk about being tone deaf and not reading the room.

If they need more data they should put an add on form and simply keep the 1004. Nobody outside of lending in their right mind would want to use a 3.6 form or anything like it. Mandates! Don’t make me laugh.

You nailed it

I just found out today after speaking with Mike Ford, and I honestly wish I had known sooner. This is a tremendous loss for AGA and for the appraisal industry as a whole. Jan was a fighter, and she stood up for appraisers when a lot of people would not.

She will be greatly missed.

Filling out a form is not a profession. There isn’t enough education required or work difficulties to be a profession. Appraisal is a job in my opinion. Most people don’t get an advanced degree or MAI SRA designation and basically have one foot out the door because they sense the fragility of the field. It’s a weird group (I’m in it so I know). No advanced degree, crotchety, stubborn, introverted.etc… it was actually more of a profession before licensing and the internet. You pretty much had to have an SRA or MAI to set up shop and get work. You trained new appraisers and had to sign off on their work..they all worked for a designation if they were serious about advancing. You needed staff to process appraisals and an office.

I was always amazed the fee paid for filling out a form and didn’t think it could last that way for long. It’s been a great run but looks like AI and general tech is drastically reducing volume and transforming to data collection which is definitely not a “profession”.

Anyways..that’s why we have had no powerful voice or representation in my opinion.

We have worked together Kenneth You’re aware of my situation. Reach out to me offline and we can talk

It is the general public that is alarmed and seeking answers. Thankfully enough influential members of the appraisal trade groups have ownership or substantial interest stakes in amc’s and their subsidiary companies, or even develop and sell the software to amc’s, they help keep a lid on things, revva has them all on speed dial.

Amc’s run the appraisal industry.
https://appraisersblogs.com/appraisal-institute-harassment-tests-n-dance-with-amcs/

FNMA is accountable to no one.
https://appraisersblogs.com/fannie-mae-2-state-of-maryland-drop-dead/

Conflicts of interest abound. The owners here sat on state boards, have financial interests in amc’s, and have integrated their technology into the gse workflow. They’re not the only ones either. Tony the clip board eliminator. You will use a tablet and you will like it. GLB is dead and buried. 3d interior home scans by unlicensed pdc’s for everyone.
https://appraisersblogs.com/fannie-n-freddies-offshore-gambit-imperils-privacy-of-millions/

FHFA had a chance to reign in the waste fraud and abuse, they failed to do so and instead forced the 3.6 forms finalization.
https://appraisersblogs.com/fannie-mae-fraud-and-abuse-exposed/

Appraisers have deeply rooted conformational bias about the alleged integrity of this industry. That’s the side benefit of the recurrent ethics class, can really get individuals motivated to understand ethics. Unfortunately this does not translate very well to practical application in mortgage lending realms and is rather used as a tool of control by the amc industry against appraisers. Sure is lucky no such standards exist for appraisal management companies. Sometimes you just get lucky that way. In the appraisal industry it’s not what you know, it’s who you know.
https://appraisersblogs.com/mismo-blueprint-2-eliminate-appraisers

NAR showed up and looked into the issue. Nothing came of it.
https://appraisersblogs.com/nar-calls-out-unregulated-middlemen-a-wake-up-call-4-fhfa/

H1B1 programs are not even necessary. In gse lending, the lenders come to them. I don’t know, volunteer to go on peoples podcasts from outside of this industry. There is no where to turn within this entire industry for effective assistance. Only the general public demanding a return to more trustworthy protective process can turn this around. I’ve been liking Harrison Smith lately.

I would be careful about declaring every mortgage broker legally complicit in fraud, especially when many may not know how the fee is divided. However, once brokers and lenders are made aware of these concerns, they should start asking questions. Continuing to present one combined “appraisal fee” without understanding or explaining where the money goes may expose a serious transparency problem.

There is a small but increasingly active group of appraisers who have had enough. Complaining online may identify the problem, but complaints alone will not change the system. We now need documented facts, credible witnesses, public records, internal communications, and appraisers willing to tell their stories.

That is what we accomplished with La Rica. She gave me her story, answered specific questions, and provided records that helped explain her compensation and workload concerns. I helped organize that information into an article that could be understood by appraisers and the general public. The article is now receiving strong feedback, and her lawsuit is receiving national exposure. That demonstrates what can happen when one appraiser is willing to step forward with facts.

I want other appraisers to know that I am willing to help do the same thing at no charge. If you have a documented story involving an AMC, staff-appraiser compensation, unpaid work, hidden fee divisions, ROV pressure, unexplained performance rankings, removal from an approved panel, retaliation, blacklisting, questionable assignment practices, or another serious industry concern, contact me.

Tell me:

* What happened and when;
* Which company or organizations were involved;
* What you were told;
* What records, emails, pay statements, engagement letters, invoices, screenshots, or other documentation exist;
* Whether you complained internally and what response you received;
* Whether other appraisers experienced the same practice; and
* What part of the story can be independently verified.

Do not publicly post confidential borrower information, privileged legal communications, Social Security numbers, account numbers, or other protected material. Preserve the original records and redact sensitive information before sharing anything publicly.

I am not a lawyer and cannot give legal advice or represent anyone. What I can do is listen, help organize the chronology and evidence, research the public issues, develop the right questions, and help turn a documented experience into a clear article or report. When appropriate, I can attempt to bring that story to AppraisersBlogs, Working RE, or another national industry forum. I cannot promise publication, but I can promise to take credible information seriously.

Logan, if you have a specific story, set of facts, or direction you believe should be investigated, send it to me. Tell me what to look for and where the evidence may be found. The same invitation is open to La Rica, Baggins, and every other appraiser who is tired of watching these practices continue without scrutiny.

La Rica stepped forward, and the industry responded. Let’s keep the ball rolling. One documented story can be dismissed as an isolated complaint. Multiple documented stories showing the same conduct can reveal an industry pattern that lenders, regulators, courts, and the public can no longer ignore.

I’m am well acquainted with LaRica. We both agree that great big light needs to be shone on this. That was the intention of this article. I wanted tbis to be a way to bring the issues to the lay person and illustrate the absurdity of the AMC model. And while I appreciate Appraisers Blogs for the exposure I would like for this to go further. We need to get this in front of every mortgage broker to let them know that while they are unaware, they are none the less complicit in potential fraud against their borrowers.

There is a small, but active group of us who have had enough and instead of getting online and complaining it’s time to do something

so we should not pretend we know the exact reason. / Having the wisdom to discern underlying reasoning and unstated truths behind human behavior without being told ‘the truth by the company’ is a common human skill. We already know all we need to know.

But a change this broad usually means the people at the top are preparing to take the organization in a different direction./ Trumps signature move; You’re fired!™. Top people are gone, many never to be replaced. Incompetent management went bye bye. There is not necessarily purpose or intelligent design waiting to be implemented. That comes later, maybe. Probably not.

That matters to appraisers because Fannie Mae does not merely participate in the mortgage market; it establishes requirements that quickly become industry standards. / I was only resting my eyes. I promise I am awake.

Decisions made inside Fannie Mae eventually affect / Where did my red stapler go!?

We have seen this before. / “The Grid. A digital frontier. I tried to picture clusters of information as they moved through the computer. What did they look like? Ships? Motorcycles? Were the circuits like freeways? I kept dreaming of a world I thought I’d never see. And then, one day… I got in.”

How will AI and AVMs be controlled and tested? / Two totally different topic matters. Dear State of Maryland.

Will AMCs gain even more control while appraisers assume the liability? / Inquiring minds want to know.

You are right: when Fannie Mae starts moving this many pieces at the top, the effects eventually reach everyone below. / Full circle, always agreeable, staying in the conversation. Going the distance. Just out of curiosity, can you please describe your model design, operational peramiters, and training data? Thanks.

‘The eliminated jobs included executives from units for multifamily loans and low-income housing tax credit, as well as finance, regulatory and communications officials, the people said.’

https://themortgagepoint.com/2026/08/21/fannie-mae-dismisses-10-of-its-senior-executives/

https://www.scotsmanguide.com/news/fannie-mae-dismisses-senior-staff-in-another-leadership-purge/

Increased mortgage origination at all costs is how that might be shaping out.

And if that is the case, this will not end well.

Maybe every major lender in the country called fhfa at once complaining about 3.6. Dare to dream.

They can never defend appraisers ever again. They’ve already crossed the line and slapped the racist label on all of us.

There is the inherent contradiction in AI writing LLM’s again. The utility believes it can assimilate available online data to create fair and balanced perspectives and solutions. Just one problem; It can not tell truth from lies or properly identify or filter out propaganda, pr spin, outright deception.

AI robots do not provide sufficient arguments to move the needle and can not be relied on to carry reliable conversations regardless of the volume of text they produce or the time they produce it in. But they can at times be good at assimilating online data in record time. If people want to use AI to the best of it’s ability without dealing with so many of it’s problems, they simply have to direct the damned things to stop having opinions or seeking to influence human behavior or which side humans should support. There is no substitute for legitimate human intellect and legitimate human working effort.

In this regard, AI is the most powerful tool of propaganda ever developed. It influences peoples opinions and they don’t even know that’s happening. The most powerful form of mind control is repetition. Always suggesting we should be tempered and fair. Corruption has run so rampant in this country for so long, it’s become the status quo in many industries. We don’t need to be fair with these people, they belong in state and federal prisons. The cycle as old as time, central planning never works. The plunder of the american housing systems continues unabated.

Looking forward to more. Want to know about the top appraisal firms whom work with amc’s and use the most outsourcing, their proportional assignment volume differences vs every day appraisers, the masses on panel not getting nearly as much. We all know this is very substantial. There was a record floating on one of these site pages years ago how a small husband and wife appraisal firm was raking millions of dollars in amc appraisal fees every year, just the two of them. Cherry pickers. Signature sharers. Inspection runners. Remote typing services. Using unlicensed stand ins. Some of these amc’s even offer appraisers their typing services. They write the appraisal report for the appraisers, and send the majority work to the appraisers whom use their typing services. That’s happening too.

One does not have to be very imaginative to understand why the TAF rewrote the allowances for this exact type of behavior into the latest appraisal uspap standards. Whatever the amc’s, lenders, and most highest donating most influential people want added or altered in the appraisal standards, that’s what they get. This is the problem with changing ethical standards, as Jeremy Bagott constantly highlights this being alterations of guidance that is against most states administrative procedural rules. The argument that none of the revised versions of uspap are even valid. They only had authority to rewrite the book once, that is in the first federal registry notice of the uspap publication. Attached. The specific term’ (will provide amendments to the code) ‘should this be deemed appropriate’.

Apparently it’s been deemed appropriate to not just amend, but also remove entire portions, constantly and substantially change the spirit of the approach and provide ever expanding practice allowances for 36 years now and I’m guessing but around 18 version rewrites. The alleged ethical guidance experts can’t quite seem to get it right, but they sure are proficient at selling more ethics books. This pay to play industry. Amc’s run the appraisal trade groups.

Hi. thanks for commenting. The fun thing about me is that I worked in an AMC. I made it 8 whole months and I realized that it was a racket. Those appraisers that you’re talking about “making money“ they’re making half of what they should be. The fun thing about me is I have receipts and this article is just the beginning.

When approximately a dozen senior executives are removed at once from areas that reportedly include finance, regulatory compliance, multifamily lending, communications, and affordable-housing investments, that is not ordinary housekeeping. Fannie Mae and FHFA have not publicly explained the dismissals, so we should not pretend we know the exact reason. But a change this broad usually means the people at the top are preparing to take the organization in a different direction.

That matters to appraisers because Fannie Mae does not merely participate in the mortgage market; it establishes requirements that quickly become industry standards. Decisions made inside Fannie Mae eventually affect appraisal forms, data collection, revision demands, automated valuation models, artificial intelligence, underwriting, appraisal waivers, AMCs, and whether independent appraisers continue to have a meaningful role.

We have seen this before. HVCC was imposed from the top down, and appraisers were forced to live with the unintended consequences. The people who actually performed the appraisals were never given a meaningful seat at the table. We should not wait until another major policy change is completed and handed to us as a finished product before asking questions.

If this shakeup is connected to modernization, technology, privatization, valuation policy, or a fundamental change in Fannie Mae’s direction, the appraisal profession deserves transparency. Who is making these decisions? What role will human appraisers have? How will AI and AVMs be controlled and tested? Who will be responsible when automated systems get the value wrong? Will AMCs gain even more control while appraisers assume the liability?

You are right: when Fannie Mae starts moving this many pieces at the top, the effects eventually reach everyone below. Appraisers need to pay attention now—not after the new system has already been built around us.

What this means is pretty simple. When a GSE dumps a dozen senior people at once, it usually signals a major policy shift, internal disagreement over where the organization is heading, or outside pressure finally boiling over. FNMA has lawsuits, modernization battles, political noise, & nonstop fights over valuation policy all hitting at the same time, so a shakeup this size is not nothing. It’s worth paying attention to, because when the top of the mortgage system starts moving pieces around like this, the rest of the industry eventually feels it.

Here’s the link for anyone who wants to see what’s going on:
https://ng.investing.com/news/stock-market-news/12-executives-let-go-from-fannie-mae-this-week–wsj-93CH-2670962

Ken, you’re putting way too much faith in politicians who have never lifted a finger to deal with AMCs. Warren has spent years on consumer protection & during the Biden era she pushed the appraisal bias narrative hard, but she has never tried to rein in AMC authority or deal with how the intermediary system hurts both appraisers & consumers. Sanders talks about big financial institutions, but he has never gone near the AMC model either. The banking committees hold hearings on mortgage practices & valuation bias, but somehow they never reach the part where AMCs overcharge borrowers, hide the fee split, operate as lender affiliates, & control the entire workflow.

And then there is Maxine Waters, who said one appraiser’s email “shines a spotlight on the racist stereotypes & harmful lines of thinking prevalent in an industry which systematically devalues the homes of Black people & other people of color.” She claims years of data & settled lawsuits prove it, even though not a single bias lawsuit has ever found an appraiser guilty in court. Yet she has never addressed the AMC system that actually sets the fees, controls the assignments, & dictates the conditions under which appraisers work. It is wild to think the same politicians who pushed the bias narrative are going to turn around & help appraisers or consumers fight AMCs. That’s not happening.

You’re dealing with a bias claim that never should have existed, yet you’re hoping the people who called appraisers racist are going to fix the AMC problem. Ken, you’re dreaming. The only people raising the AMC issue are appraisers & now the lawyers in these lawsuits. No major lawmaker is coming to save us.

The only time anything will change is when enough consumers finally understand they are being overcharged by AMCs & demand reform. Appraisers alone will never be able to force it.

Refresher on who you think is going to help:
https://appraisersblogs.com/maxine-waters-wants-appraisers-investigated/

Andrew Cuomo did not invent appraisal management companies, but his response to the 2008 mortgage collapse became the turning point. Cuomo’s investigation of Washington Mutual and eAppraiseIT led to the 2008 agreement with Fannie Mae, Freddie Mac, and federal housing regulators that produced the Home Valuation Code of Conduct. HVCC took effect in 2009.

The objective—protecting appraisers from pressure by loan-production personnel—was legitimate. The solution was overly broad, poorly informed, and written without understanding how independent appraisers actually operated. HVCC did not expressly require lenders to use AMCs, but it created a system in which outsourcing appraisal management became the easiest way for lenders to claim compliance. The results were predictable. The GAO later reported industry estimates that AMC use increased from somewhere between 15 and 50 percent of mortgage appraisals before HVCC to approximately 60 to 80 percent afterward.

That was the moment the independent appraiser lost control of the profession.

I remember when the appraiser handled the assignment from beginning to end. We accepted the order, scheduled the inspection, spoke directly with the appropriate parties, performed the research, completed the report, delivered it, and collected our own fee. Sometimes I received a check at the door from the homeowner or agent. Other times, the lender paid me within 30 days. I established my own fee based on the assignment, my experience, and the amount of work required. We did not need an AMC taking part of the fee while adding deadlines, conditions, revision requests, and another layer of interference.

Appraisers needed protection from coercion. We did not need our businesses handed over to unlicensed middlemen.

Dodd-Frank later terminated HVCC as a separate code but preserved many of its independence requirements and formally built AMCs into the federal regulatory structure. It did not return control to independent appraisers. It institutionalized the intermediary. Even more troubling, current federal law recognizes “federally regulated AMCs” that are owned and controlled by insured depository institutions. The original HVCC proposal restricted lenders from using an AMC in which they held more than a 20 percent interest, but today a federally regulated financial institution can own and control an AMC subsidiary.

That is where the shadow interest remains. The lender may claim that the AMC provides independence, but the lender or its affiliate can still influence the system from behind the scenes. The AMC controls who receives the assignment, what fee is offered, how quickly it must be completed, what revisions are demanded, and whether that appraiser receives another order. Calling that independence does not make it independent. It is the same financial power operating through a different doorway.

The recent lawsuits are important. They are finally exposing fee splitting, consumer disclosures, staff-appraiser compensation, employment classification, and the financial relationships between lenders and AMCs. I support bringing these practices into the sunlight. But we also need to be honest: piecemeal lawsuits alone will not repair the national appraisal system. One company may settle, another may change a disclosure, and another may alter an employment policy, but the basic power structure will remain.

The real fight belongs in Congress and Washington. Lawmakers such as Elizabeth Warren, Bernie Sanders, and members of the House and Senate banking committees should be holding public hearings on AMC ownership, fee transparency, customary and reasonable compensation, assignment control, staff-appraiser conflicts, consumer charges, and retaliation against independent appraisers. The industry needs enforceable federal reform—not another committee, study, task force, or public-relations campaign.

Appraisers know what is wrong. We have been living with it since 2009. What we do not have is meaningful national representation, a serious lobbying operation, or enough influence in Washington to compete with the banks, mortgage lenders, AMCs, and other well-funded interests that helped shape this system.

AMCs cannot perform appraisals without appraisers. Appraisers performed appraisals successfully long before the modern AMC system took control. We do not need another 15 years of describing the problem to ourselves. We need to organize, obtain real legal and legislative representation, and demand that Congress address the structure that created the problem in the first place. Until that happens, the industry will continue fighting one lawsuit and one AMC at a time while the people controlling the system remain safely in the back room.

Steven says we got here because appraisers and banks could not ethically work together, but that is not how any of this started!

We got here because eAppraiseIt, an AMC, was caught inflating values for Washington Mutual and even scrubbed its panel to remove appraisers who refused to hit the numbers. That investigation by Cuomo, the then New York AG, led straight to HVCC, which created the modern AMC system.

So the idea that AMCs exist because of appraisers is a little backward. The entire structure was built because an AMC could not behave.

Looks like your article attracted someone who does not know the modern AMC origin story, but he showed up fast to defend it.