If the Management Model Is So righteous, Spread It Around
Once upon a time there was a profession that stood between the public and chaos. For forty five years I watched that profession take every punch the mortgage world could invent. Every market dip, every delayed closing, every regulatory shift, every headline looking for a villain landed on the appraiser. We carried it because we understood the role. We were the guardrail.
But when the word racist became fashionable, that was the breaking point. Appraisers were already the most over regulated people in the entire mortgage process. It was absurd to pretend that lawyers, originators, brokers, realtors, AMC’s and bankers were spotless while appraisers alone were the problem. That conclusion was not logical. It was convenient. And it became the narrative.
The truth is simpler. The endless regulations were never about improvement. They were intimidation. They were pressure. They were a way to keep appraisers boxed in, while everyone else operated freely. Unlicensed, unvetted, uninsured data collectors were suddenly allowed to wander through homes and send in whatever they felt like. Homeowners were allowed to submit their own data as if they were trained professionals. And the appraiser was expected to take that data, treat it as fact, and buy the appraisal hook line and sinker. Meanwhile the appraiser carried all the liability.
And here is the part that never gets said out loud. Why are appraisers the only ones being managed? Why is there an entire shadow industry built to supervise, monitor, and skim off the work of one profession while lawyers, originators, bankers and everyone else walk free? If management companies are such a brilliant idea, why not apply them to the legal world? Why not assign babysitters to originators? Why not force bankers to hand over most of their fee to a management company that checks their ethics and competence? If the management model is so righteous, spread it around. But it never is. It is only imposed on the appraiser.
So after watching this circus run the same route for decades, you stop pretending it is anything other than what it is. The blame gets tossed at the appraiser, the management model tightens its grip, and everyone else strolls past the mess like they had nothing to do with it. And the part nobody ever wants to say out loud is simple. If this level of supervision is such a gift, then the legal world, the banking world, the political world should be lining up for their turn. If appraisers can be micromanaged, vilified and financially gutted for the greater good, surely the rest of the industry will welcome the same treatment with open arms. But they never do. The oversight only ever lands on one doorstep, and that is exactly why the story keeps repeating.
When I started appraising 25 years ago, the going rate was $350 for a residential appraisal. I just received an unsolicited awarded appraisal assignment 2 counties away for a fee of $236! I don’t do residential lender work, except for Field Reviews (which are now going away (see Mortgagee Letter 2026-10) but I know of no other industry that has taken such a severe cut in pay–most have actually *increased* rates 50% or more due to the rampant inflation in the US. It’s truly a recipe for disaster. Long term this won’t matter, as the end goal for UAD 3.6 is to automate valuation ie Zillow ZEstimates once they collect sufficient data from field appraisers, but for those still working in the interim, it will be a nightmare!
Independent truckers face a similar extinction. The last of them are being killed off this month with $7 to $10 diesel cost. Self driving trucks are just over the horizon as well…does that remind you of A I Valuation or what?
I couldn’t agree more with this well-written article and the responses that followed. The problem is that nothing ever seems to change.
Why is that? Is it really impossible for this industry to develop an organization that effectively advocates for appraisers?
Why is it so difficult to unite appraisers? We are an incredibly fragmented profession, and that fragmentation makes it difficult to have any meaningful influence.
Maybe now is the time. With the disastrous rollout of UAD 3.6, the increasing costs of software and technology, and the additional time and complexity being placed on appraisers, perhaps we finally have an issue significant enough to bring the profession together.
At some point, we need an organization with a strong, unified membership—a big enough club to demand meaningful changes and have a seat at the table. Until we can come together and speak with one voice, I’m afraid we will continue having the same conversations while very little actually changes.
Quite right. The culture of the industry is formed from the top down though. Too many conflicts of interests with the appraisal trade groups acceptance of rewriting the ethics book, aka; the industries codified guidelines, every other year at the request of the special interests and stakeholder needs and wants. The entire thing has devolved into a regulatory quagmire.
Personally that’s why I found Mr Jeremy Bagotts persistent highlighting of the violations of the administrative procedural acts as being compelling, a possible long term solution. Appears to be too late now, the special interests spent considerable time and investment on the technologies they steadily patented and implemented over time with the specific purpose of central control, removing independent checks and balances which was the 1099 small business appraiser firm tie in.
Private work is now on the menu for continued corporate modeling expansion. In the end if this keeps going the direction it’s headed, the attrition of private work independents will also accelerate and they’ll be disadvantaged too, as the corporate franchise models will do to them, exactly the same thing they did to independents servicing GSE lending work.
The process has already began, as multitudes of new tech companies and franchise appraisal firms come into place, many of whom are staffed by entire departments of former amc workers and amc staff appraisers. They somehow are able to operate exactly as an amc, perform activity which clearly falls under amc licensing requirements, and are not actually required to hold amc licenses themselves. Because they brand themselves as a franchise appraisal firm or supportive tech company whom services appraisers and amc’s alike, rather than simply identifying as appraisal management companies. They’ve added new appraisal services to their websites and offerings, legal, estate, private, government. I’d bet they get considerably more web traffic too.
One can not have effective regulatory oversight when those in charge of the oversight have ownership or profit stake in the companies being overseen, and they routinely re write the industry guidelines to benefit their own companies. That’s what’s really going on. Pay to play.
Guess what is up next. Demins to $650k. I wrote something similar to an obituary on the other forum. Who was it that said, last one out don’t forget to turn off the lights? I’ve been borrowing that one.
https://appraisersforum.com/forums/threads/fannies-own-statement-about-waiver-value-acceptance.243114/page-48#post-3633377
If the Coen Brothers and David Lynch had invented appraising, it couldn’t have been any weirder than it is now. My cert expires in about two months and all I can think of is that Roy Clark song … Thank God and Greyhound It’s Gone!
I have my own opinions about staff apparaisers. They aren’t good. I did a lender direct report not long ago where ANSI ceiling heights were not met for 1/3 of the home. The staff appraiser told me to find sales that looked alike and “assume” they had similar ceiling heights and not adjust for GLA. What about the low ceiling heights that eliminated 2 bedrooms, a bath and a laundry room? After I told them I would not proceed and presented a 2 page reason why, the same property was assigned to me again through an AMC the next day. The just shoved it off to an AMC. I told them the story and they assigned it to a friend of mine (appraiser) that reported the same issumes. They do not care what they fund. Just keep the machine rolling, screw the public.
Yeah. All that is too much work. That’s why lenders get automatic avm pass throughs from the value acceptance program, use hybrids and property data collectors instead. Can’t disqualify something that nobody who’s qualified has ever actually seen in person. Appraisal modernization!
You’ve got it all wrong Georgia. According to most appraisal news publications, most lenders and amc’s, most tech companies providing products to appraisers, the local appraisal state groups, the appraisal trade groups, the future of appraisal business modeling is no longer independent using tried and true manual methods. The future of the appraisal business is the franchise model or being an employee at a lender or amc appraisal department, automating everything possible. Only corporations and the products they sell you, can protect citizens from the predatory nature of other corporations.
Outstanding article! Bravo.
No one will ever assimilate or publish a list of every past and present appraisal trade group representative, persons involved with appraisal news, appraisal software, appraisal insurance, appraisal education providers, whom have direct financial ties to the appraisal management industry. All the conflicts of interest in this pay to play industry. Would that really be considered negative exposure, if the majority at the managerial level is in on the charade?
Much of the appraisal industry is subservient to the appraisal management industry already, even if the appraisers practicing outside of direct engagement with amc’s do not quite understand the situation at hand. Appraisers are compartmentalized and this keeps them from being able to understand, much less accept, the truth of the larger picture. How much the needle has spun around thus far. Over and over again.
For those that are not yet subjected to or disadvantaged by the amc’s entangled conflict of interest network pressures, they will understand soon enough. Amc’s are not stopping at mortgage lending. The constant expansion of practice allowances written into the appraisers uniform standards of professional appraisal practice book on a bi annual basis. The ‘uniform standards’ constantly expanded and altered upon request from stakeholders, primarily directed by lenders and amc’s. These controlling interests whom are the actual managers of the appraisal industry will make sure of their continued ability to expanded scope and practice over time. The automation, franchise modeling, corporate expansion, the continued reduction of small businesses presence, the erosion of tangible independence is coming for everyone.
Because most people have the attention span of a goldfish and view reading about the appraisal industry as an entertainment type experience, only worth a limited amount of their time, rather then as something of such important gravity that is currently shaping the future of this country, hardly anyone is willing to take the time. Why bother trying to save any of this if that is the case? The attrition continues unabated without hardly any resistance. Welcome to real estate appraisal.
The experienced segment of the appraisal profession has long recognized the structural pressures reshaping the field. Newer entrants generally lack this perspective, and many would not have selected this occupation had they understood the broader institutional dynamics. This generational divide is significant because regulatory changes increasingly reflect the priorities of large financial stakeholders rather than the interests of independent practitioners.
Over time, regulatory adjustments have consistently expanded the authority of lenders, appraisal management companies, and affiliated entities. These changes have narrowed the operational independence of individual appraisers. The pattern suggests deliberate influence by well resourced stakeholders who have sought to reduce the role of independent valuation professionals within the lending process. Since this objective cannot be stated directly, it is pursued through indirect mechanisms such as regulatory revision, political advocacy, and public narratives that diminish the profession’s standing.
The restructuring of the mortgage appraisal segment marked a pivotal turning point. When mortgage appraisers lost the ability to solicit their own client base and were instead required to operate through mandatory intermediaries, the profession experienced a fundamental shift away from free enterprise. This model resembles a socialist form of restructuring in which centralized oversight replaces individual market autonomy. The introduction of appraisal management companies as compulsory gatekeepers effectively removed the appraiser’s ability to compete independently, and it signaled the beginning of a broader transformation that has since expanded across the profession.
The recent characterization of a nationwide appraisal bias crisis further accelerated this trajectory. Racism exists in the appraisal profession as it does in every profession, but the claim that the profession as a whole is systemically or universally racist is not supported by evidence. The political environment allowed isolated incidents and legitimate concerns to be amplified into a sweeping narrative. This narrative provided a convenient justification for reforms that reduce reliance on independent human judgment. Government agencies and political actors adopted the narrative because it aligned with institutional goals that favor automation, centralized oversight, and streamlined lending operations.
Within the profession, collective cohesion is limited. Veteran appraisers, who understand the long term trajectory, are retiring. Newer practitioners often compete by lowering fees rather than organizing around shared interests. This absence of unity leaves the profession vulnerable to external forces that are more coordinated and financially influential.
Technological developments, particularly artificial intelligence and automated valuation systems, further reinforce this trend. These tools offer stakeholders scalable alternatives to human appraisers and support the longstanding effort to reduce the profession’s influence. Without structural organization or political leverage, the appraisal profession faces a continued decline in relevance and authority.
In summary, the appraisal industry is undergoing a transformation driven by powerful external interests, limited internal cohesion, and rapid technological change. The early loss of free enterprise within the mortgage appraisal segment initiated a centralized, socialist‑style restructuring that continues to diminish the independence of the profession. The amplification of racism into a universal indictment of appraisers accelerated this process by providing political justification for further centralization. The cumulative effect is a steady movement toward marginalization of independent appraisers.
My take is that it doesn’t “resemble” socialism. It IS socialism.
As will all of socialism, what they accuse us of is actually what their attitudes are and what they’re doing. I absolutely reject their accusations of any racism, much less, systemic racism. “Racism” has become a meaningless word anyway. I’d like to see even one appraisal report in the US where racism against anyone can be proven. It’s bullsh*t and we all know it.
Liked. You fit in most of the important points with great brief summarization. Totally forgot to mention consumer protection though. The entire purpose of the appraisal licensing program was at it’s heart, rooted in the need for better consumer protection from predatory lending practices.
As someone who spent more than 15 years building an independent appraisal practice before the AMC Disaster, this article resonates with me. One of the concerns I had was not simply oversight or compliance requirements, but the growing imbalance between accountability and compensation. Appraisers are expected to carry significant professional liability, meet strict regulatory standards, respond to increasing review requirements, and maintain independence, yet often have little visibility into how appraisal fees are allocated or how compensation structures are determined.
I believe transparency would benefit everyone involved. Borrowers deserve to understand where their appraisal dollars go. Appraisers deserve to understand how their compensation is calculated. Lenders deserve confidence that appraisal quality is supported by a sustainable business model. When the professional performing the valuation carries the greatest responsibility but has the least visibility into the economics of the transaction, it raises legitimate questions about fairness and accountability.
Regardless of anyone’s opinion about AMCs, I think the industry would be stronger if Transparency, Consistency, and Professional respect were applied equally across all participants in the mortgage process.
With the state of CA and my county of practice (San Diego) losing +/- 5% of the appraiser population per year (been steady for 5 years) combined with the new reports taking a third longer, the powers that be have no idea of the decimation these AMC’s and new 3.6 system have and will cause. With a reduction of bodies (+/- 25%) followed by increased time to complete 3.6 (+/- 33%) the effect means the state of CA has reduced the capacity to complete traditional appraisals by 58% from 5 years ago.
For those keeping track at home the county of San Diego has a population of 3.3 million and there are 604 total active (not necessarily practicing) number of appraisers. Of those 604, 371 are AR, 185 AG, 33 AL, and only 15 AT.
Seek the truth.
Holy cow, say hello to the coming 12 week turnaround time!
Move over Lake Mead, the appraisal industry is determined to out perform you in a race to the bottom.
Wow, those numbers are honestly insane. I knew the pool was shrinking, but I didn’t realize it had dropped to that level. What’s even crazier is how nobody in charge seems bothered by it. And it makes you wonder if that’s exactly why 3.6 is built the way it is. The whole thing feels less like a reporting upgrade and more like a giant data‑collection machine. When you look at it that way, the lack of concern about appraisers leaving starts to make sense. If the endgame is replacing the profession with automated systems fed by all this structured data, then of course they’re not worried about the workforce collapsing. They’re acting like we’re temporary.
Well Written and thank you for the post. If any lawyers, originators, brokers, realtors, AMC’s and bankers read this post, I’m sure they cringed.
Brilliant! If implemented, they would probably be as competent as FHFA. No guardrails for big money!
It’s wild to look back at those questions & remember how only a few appraisers actually fought the management model when HVCC hit. They’re the ones who stood up, called it out, refused AMC work, & didn’t cave. Meanwhile most of the industry just went along with it, let it roll in without resistance, & even criticized the people who pushed back. That’s exactly how the shadow industry got built. It didn’t grow because it was righteous. It grew because almost nobody bothered to stop it.
What about those appraisers who for a few hundred or a thousand dollars would coach you to build a business model around the AMC racket? With a little coaching, you to can churn and burn 4 to 8 appraisals a day. Don’t get me started on the, appraiser owned AMC bullcrap.
Seek the truth.
Yeah, unfortunately there were plenty of appraisers who made a nice living off the backs of everyone else. Some were more than happy to push the AMC hustle, sell the churn model, & take whatever low fee was thrown at them. That crowd helped drive fees down for the rest of us because they kept saying yes to work that paid less than a basic hourly wage. A lot of what we’re dealing with today didn’t just come from AMCs, it came from the people in our own profession who were willing to play along.
There are ‘appraisers’ on the executive boards of every AMC and every single one of them is a Benedict Arnold/Judas. They have sold out their entire profession and every appraiser in the country for their own financial gain.
They know who they are Logan. They don’t mind the criticism either.
We can’t regulate morality. We can’t fix stupid either.
But we can implement sound checks and balances systems within a largely decentralized process to limit the attraction affect for those whom would exploit others. Sadly this is exactly what the separation from loan production rule accomplished; It attracted those whom have no problem exploiting others. Third party management! This is way better than one individually accountable licensed appraiser interacting directly with one individually accountable licensed loan officer.
Central planning never works.
I have my own opinions about staff apparaisers. They aren’t good. I did a lender direct report not long ago where ANSI ceiling heights were not met for 1/3 of the home. The staff appraiser told me to find sales that looked alike and “assume” they had similar ceiling heights and not adjust for GLA. What about the low ceiling heights that eliminated 2 bedrooms, a bath and a laundry room? After I told them I would not proceed and presented a 2 page reason why, the same property was assigned to me again through an AMC the next day. The just shoved it off to an AMC. I told them the story and they assigned it to a friend of mine (appraiser) that reported the same issumes. They do not care what they fund. Just keep the machine rolling, screw the public.
I’m with you on this. The article nails it, and your comment is dead on. The only reason this whole management setup ever took root is because it landed in the one corner of the industry that didn’t have the numbers or the backbone to shut it down. Try pulling this on lawyers, originators, or bankers and watch how fast they slam the door. Nobody in those fields is handing over their fee or letting a third party babysit their work. They’d shut that down before the ink was dry.
You definitely understand! Great job on this post. Lets spread it around. What good for the goose is good for the gander, right?