AMC Fair Housing Mythodology

Digital Masking of People a Fair Housing Requirement of Mythodology

AMCs are on notice to cease demanding and insisting that appraisers do digital staging.

You’ve seen the AMC’s orders.

Appraiser is to obscure, blur or remove individuals from photos.”


Fair housing laws say so, that’s why. Do they?

I had my first settlement conference with an AMC recently. Appraisers have been participating in settlement conferences with Appraisal Board members and Department attorneys for years. Because there is no Board for AMCs, the opportunity falls to me.

At issue was the ubiquitous “client requirement” involving digital masking of people from images. While lenders and AMCs wave the Fair Housing penalty flag in order to assure compliance; there is NO such law. Never has been.

Mostly, this issue involves images of people inside their own homes. But it dovetails into exterior views and pictures that include personal artifacts.

When did interior images become a requirement? They’ve always been helpful in order to support comments on interior condition. Flaking paint, cracked walls, broken windows, water in the basement, etc.

Back in the 1980s when I, like so many of you, shot rolls of film, nobody asked us to cut people out of an image. For one thing, it was film. There was no way to doctor the emulsion. If someone was in the shot…they were in the shot for good. When digital photography emerged as a reasonable alternative to film, that’s when the possibility of editing came about. That was about twenty years ago. Back then, some lenders only wanted a bathroom and kitchen shot.

Why? I don’t know.

Around 2000 is when digital imagery really exploded in appraisal. As the saying goes, “pixels are cheap”. It was then that lenders began requesting images of most interior rooms.

Why? I don’t know.

Some lenders want everything photographed. AMCs pass on this faux “requirement” without giving it another thought. Then they write instructions that people should never appear in photographs or else. Let’s unpack that.

First, I agree that people shouldn’t be in appraisal images if possible. I still have images from hundreds of appraisals that I completed over the years. I save them for illustration purposes. I have no idea what the addresses or dates are…but I still have the images. I was hard pressed to find many images that depicted people. There were a few accidental shots and some congested urban street views, but little else. For the most part, people aren’t interested in being in the picture. After all, this isn’t a publicity still. These are documentary style images intended for informational purposes. Still, no matter what time you get to a property somebody may be going to bed, getting up, arriving home from work, going to work, heading to or from a nap (kids). Then there are the elderly or the bed-ridden who cannot, for any number of reasons, leave the room you need to shoot. It’s just not happening.

What about street scenes? People are everywhere at all times of the day. We’re not shooting a movie. We can’t clear the streets just because some underwriter five states away wants a clean image with nothing to influence them.

Nobody needed ten interior shots of a house in the 1980s or early 1990s. Why do lenders need them now? They don’t. They just want them.

Note: Race and the racial composition of the neighborhood are not appraisal factors.

Look familiar? It’s baked into every Fannie form appraisers use. What this means is that the only people capable of making race a factor in a loan file is the lender; not the appraiser.

Appraisers should make every effort to avoid recording an image of a person if, for no other reason than they’re probably blocking something you should see. Lenders need to re-examine the reason for all of these pointless and invasive interior shots. They add nothing meaningful to the file. Nobody is laying out mortgages for Beanie Baby collections and bad drapes. So why are appraisers wasting megapixels on decorating images?

AMCs are on notice to cease demanding and insisting that appraisers do digital staging. That is clearly in violation of Illinois law.

By Brian Weaver, Coordinator Editor of IllinoisAppraiser, Appraisal Management Company Coordinator for the Illinois Department of Financial and Professional Regulation (IDFPR)
Source Illinois Appraiser Newsletters – Volume 9, Issue 1 – June 2016

Latest posts by IDFPR Board (see all)
Image credit flickr - Mattia Merlo


Provided as a service to licensed and registered Illinois appraisal professionals as well as Illinois course providers and users of appraisals. Illinois Appraiser Newsletters promote a greater understanding of USPAP, the Act, and the Administrative Rules of the State of Illinois. promote a greater understanding of USPAP, the Act, and the Administrative Rules of the State of Illinois.

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27 Responses

  1. Avatar TOM D says:

    remember when you thought the digital camera was a time saving modern piece of equipment? well, not lately. just another trip on this cruise of the damned. they just change the oars sometimes to make us think it getting better.

    haven’t the crashes come after they started asking for more photos than the 1 polaroid front shot of the home i used to take. ohh, who remembers those days? the newer appraisers have no idea what the garden of eden appraising was like. now satan is in charge.

    • Retired Appraiser Retired Appraiser says:

      Just a few short years ago it was more lucrative than most small law practices and a Hell of a lot more fun.  Gone is the money (at least from the appraiser’s pocket) and gone is the fun.

      Flaming Hoop Jumpers Unite!

    • Avatar SoCal appraiser says:

      It was so much easier in the 1980’s, doing hand-written Fannie Mae 1004 reports for a major lender. I could usually get all my subject and comp photos for a typical home or condo on a 12 shot roll of film. The quality of appraisers was also better in the pre-licensing days.

  2. Avatar Koma says:

    Brian, Thanks for the article. Good to know I’m not the only one thinking this. Had a client wanted a small cross on a side table to be blurred in a photo. I asked what happens when Christmas comes around?? Also, heard a story a couple years ago when it was a cat the lender wanted blurred.. lol For me It’s always been no people, try no pets and for some crazy reason I blur out license plates on Comp photos. Just a courtesy I guess with LP.

    • Baggins Baggins says:

      If the cross offends, people are free to get back on the boats, and go back to wherever their ancestors came from. I like to just casually ignore and string along those requests. When it comes down to missing closing over a cross in a picture, whomever causes that is likely to get fired. By delaying, you put the requestor in a pot of water with the temperature steadily increasing as time passes. Copy the other interested parties, and they’ll gang up on the requestor instead.

  3. Avatar kash says:

    Had one client ask me to remove the American flag from photo the other day. I told them to pound sand.

    • Baggins Baggins says:

      Don’t forget to tag your signature in a big waving American flag, just to let them know. 

      That’s the only one which is never removed, and always photographed. I never miss a chance to highlight a flag in a report.

    • Mike Ford Mike Ford says:

      Good for you! Some demands are so egregious that even treating them seriously is a disservice to all. Thank you for standing up for OUR flag.

  4. Avatar Ralph says:

    I had a request from a large bank about 5 yrs ago through their AMC to blur out photos of an entire family, as their living rm wall was all large family photos. The family was a nice black family. I flat out refused and said you want to insult an entire family in their own home? What will they think when they read the report and wonder why their photos are blurred out? I told them “you require interior photos, therefore they will not be ALTERED in any way” That was the end of that, the AMC was no help, they just wanted to keep the client happy, but I stood firm. This is one of the reasons I no longer do AMC work at all!

  5. Avatar Bill Johnson says:

    To expand your headline one could say what is required per USPAP guidelines (photos), versus what has become standard practice within the often times 15 page engagement letters appraisers receive today. The next piece of that puzzle (extra photos), is at what cost are these photos to the appraiser? It’s hard to keep up, but in my area the following photos are often required. (Conv. loan) Street pictures in both directions, a picture of the physical address, a photo of the property across the street, side photos, pictures of common areas (PUD or condo), pictures of each utility (confirm there on), smoke detectors (state law, each Br, each floor level), CO pictures (one per floor), dual strapped water heater, bedrooms, and of course the not required original comp photos. If on average the taking of, documenting of, inclusion into the report, possible conditioning of, 5+ year records storage of, etc., takes 30 minutes per report (1.5 assignments per day), how much time per year are we not getting paid for. With 300 working days a year times 1.5 assignments a day times the 45 minutes we appraisers spend above and beyond what is required, the following happens. We spend 225 hours a year (5.6 weeks @ 40 hours a week) being asked to take extra photos that we all know we are not getting paid for. When states like Virginia have adopted appraisal law where customary and reasonable fees are to be tied to scope of work requirements (that of a VA assignment), an effort is underway to address what is required ($), versus what is being asked of use (extra $$). Lastly, I was once conditioned to remove what the lender thought was a family member standing in a bedroom picture (again not required). I told them the bearded adult dressed up as a pirate holding and swinging the sword was only a cardboard cutout (movie theater prop), and was not real.

  6. Avatar Koma says:

    You know besides what is required USPAP guidelines they will ask for the moon. Guess what only you can bring them back down to Earth!

  7. Avatar GAPeach says:

    Another stupid AMC stip:

    There are a pair of feet in the bedroom photo. Please crop out feet from photo…

    Do they dwell on the same planet as the rest of us? Justifying their crappy jobs!

    • Mike Ford Mike Ford says:

      “No. I do not tamper or alter photographs on request nor am I required to do so. Every reasonable effort is made to avoid inclusion of people and body parts but its not always practical to do so.”

  8. Avatar Michael Zuelke says:

    I’ve been appraising for 33 years…Longer then anyone I know has been doing anything almost.. I was around when this started. Bank of America was caught redlining….drawing red lines around areas they did not want to make loans in. So, the higher ups started requiring appraisals with no people pictures so that a lender could use to see what type of people they did not want to loan to… Of course BofA was discriminating against people of color… continues…. Not sure who was the higher ups.. But it was around 1991 ish….. Working for Long beach mortgage then, even commercial reports had to literally black out with marker.. condition, neighborhood description, etc.. that could give lenders any type of info they could use to basically red line.

  9. Avatar Elissa says:

    I was once asked to remove the dish drainer from the kitchen counter – I would not – every home has a dish drainer next to the sink!

  10. Avatar Liz says:

    We are working more getting paid less. We must make a stand or the fees will continue to go down. I recently found out that the client was paying over $600 for the appraisal and fee split was $290. So now the AMC are getting more than the #@!&% appraiser, really. Something is wrong with this picture, and they wonder why there are no appraisers.

    • Baggins Baggins says:

      Since day 1, my qualification criteria has been a fair shake. You always ask the consumer what they are being charged, regardless of any illusionary amc agreement was in place.  “keeping them honest.”.

      Speak for yourself about getting paid less and working more. I’ve been working less and getting paid more. It’s all about positioning and if appraisers cannot best some corny telecom desk worker who positions like a telemarketer to drive wages down, well……  That says more about the appraiser than the amc worker. Stand tall, walk the line, and know when to hold em, and know when to fold em.

    • Retired Appraiser Retired Appraiser says:

      You are 100% correct Liz. Appraisers FEEL like they are in control for the moment because of low interest rates. Once the rates go up…demand drops…and so will the fees.

      It amazes me that appraisers are jumping for joy over getting 2009 fees while doing twice the work per assignment. I suppose that ignorance truly is bliss.

  11. Bubba Jay / Retired Appraiser II Bubba Jay / Retired Appraiser II says:

    blurring would have been a piece of cake compared to the nonsense i had to endure years ago with an AMC. back then, this AMC didnt want ANY pics of people anywhere. every house i went to, i could not take a pic of a person ANYWHERE, and this included PICTURES. i cant count the number of homeowners that i had to force into totally stripping their walls of every picture, and this included the stripping down of refrigerators. blurring? oh heck no, they didnt allow the picture to be altered in any way. if i missed a picture or any signs of a person in the picture anywhere, then i had to go back to the house to retake the picture.

    i dont miss that nonsense AT ALL, and i have no idea how i managed to keep my sanity all those years.

    are they still in business? i believe so.

    the insanity continues . . .

  12. Baggins Baggins says:

    Disagree. More pictures keeps everyone honest. Fraud is out of control from the top down. Nothing wrong with a more thorough illustration of the home with more pictures. More pictures are necessary because omission of such a simple action like more digital pictures is an immediate possible indicator of some concealed issues. 

    Pictures are cheap, quick, and easy to include in reports. I stack 15 pics per page photos in my report, after about a half dozen of the 6 per page, totaling around 100 pics each report. But yeah, it’s silly to be asked to crop anyone or anything out of photos. It’s important to remember the investors are probably as ignorant as the amc workers in many regards. Just because they’re into real estate, does not elevate their intelligence by proxy, as many industry workers might presume. That goes all the way up and down the line. More photos is more honesty in reporting.

    Want to be an appraiser? No problem. It’s as easy as memorizing about 20,000 pages of regulatory text and guidance. If you don’t have a license, you should not advise an appraiser about anything. More reasons why every single amc worker should be individually licensed with criterea perhaps even more stringent than that for appraiser qualification. What we have now is the delivery boys advising the chefs how to cook a pizza, and how much to charge for it.

    • Avatar TOM D says:

      “100 pics every report”!!!!.  there’s the problem. seeing that, then they start whipping us 30 pic’s appraisers harder. there’s always someone on this cruise of the damned who has to row harder. just too funny. throw the baggins scoundrel overboard. oh wait, he chained to him oar like the rest of us. chop off one arm, that should slow him. ahhhh!!!!!!

      • Baggins - I will out pirate you! Baggins - I will out pirate you! says:

        On the upside, I rarely get stipped and to date have never been disapproved over those reporting issues. Seeing is believing. Have you ever field reviewed a skippy report and said; Those are not the correct comps. 100 pictures takes like 10 extra minutes. Photo the meters, the rooms, the 4 corners, the crawl, the cfans, the utility, some material samplings, drive, garage, shed, other appealing photos, and that’s much better than eventually being a privateer held against the mast. If you can’t pop in a total photo documentation of the home, you deserve extra lashes. If you allow the reporting to become generic to the point where questions are routinely deserved, you may have crimped your fellow mates. Blimey! Blow the man down!

  13. Avatar Ken says:

    I look at it a different way. What happens if something goes wrong? I missed the 5th bedroom photo because the owner was yapping and I lost my concentration. Now we are talking serious time to call the owner, drive out to the property and retake the photo.

    Everyone looks at these extra requirements as a best case scenario. Maybe we spend .5 hours more per report for the photos, and that is just best case senerio

    • Avatar TOM D says:

      seriously, if you saw the room why are you driving back out. either the owner, or one of their kids has a phone that takes pictures. it happens once in a while and those phone pictures are pretty good. make sure you explain how to take that picture.

      • Baggins Baggins says:

        Yeah, if ye be called a blaggard, show them th’ aft and fore, but never show the bilgewater in th’ hull. If ye be a seadog with sealegs, ye be a buckaneer of the high seas, and never walk the plank. If they shout from the crowsnest, hold them in irons for a flogging, and call for an able body seaman to stop the mutiny!

  14. Avatar Johnny Q says:

    How about labelling the photos as a must? Depicted are a commode, a shower stall or tub and a vanity with a wash basin and faucets. Or cabinetry, counters kitchen appliances and maybe some pots and pans. Quite evident one is looking at a bathroom or kitchen but God forbid you miss labelling the photo as such. The poor readers down the line won’t be able to figure out what they’re looking at if not labelled.


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AMC Fair Housing Mythodology

by IDFPR Board time to read: 3 min