Pickleball, Promises, and the Quiet Takeover of Appraisal
“Fair warning, we take our pickleball as seriously as we take our appraisal tech.”
That showed up in my inbox this week as part of a promotion for the Appraiser’s Conference and Trade Show 2026. Smiling emojis, rally invites, reminders to book meetings with onboarding teams and partnership managers, all wrapped in a message about staying ahead of what’s next. I have been in a slowdown for four years now, so when something like that comes across my screen, it lands differently. A lot of appraisers are not rallying right now. They are waiting on work, stretching assignments, and trying to hold things together while volume remains inconsistent.
So, when that message hits, it doesn’t feel like leadership. It feels like a disconnect from the people actually doing the work. A show of hands, how many appraisers can afford to attend this gathering of industry arrogance?
And while that disconnect plays out in conference halls and vendor booths, something far more consequential is moving forward in the background.
H.R. 1625, also known as S.1635, is being presented as modernization. That label deserves a closer look, because what is being proposed has very little to do with supporting the appraiser and a great deal to do with restructuring control.
At its core, the bill creates a nationwide appraisal database that reaches back to 2017 and pulls forward everything appraisers have produced since then. Not summaries or anonymized trends, but full appraisal level detail, including the appraiser’s name, license ID, comparable selection, adjustments, reconciliation, and written narrative. It then mandates public, searchable, and downloadable access to that information, opening the door for widespread scraping, modeling, and third-party use.
An appraisal has never been a public document. It is a confidential communication between the appraiser and the client, developed for a specific assignment. That boundary has always been fundamental to the credibility of the process. This bill removes it without hesitation.
Every report completed since 2017 is drawn into a nationwide system, and every report going forward risks becoming part of the same structure. What once existed within the scope of a single assignment is converted into a permanent dataset, accessible in ways that were never contemplated when the work was performed. Calling that oversight does not make it oversight. It is the systematic capture of professional work product.
And what is being captured is not just data points. It is the substance of the work itself. It is the judgment behind adjustments, the reasoning within the narrative, and the experience that supports the final conclusion. That is the part of the process that cannot be automated without first being collected, studied, and replicated.
That is what this bill makes possible.
Federal copyright protections apply the moment original work is created. The Fifth Amendment does not allow private property to be taken without just compensation. USPAP clearly defines the appraisal report as a confidential communication. S.1635 presses directly against each of these principles while presenting the outcome as a public benefit.
Transparency is the word being used. Extraction is the result that follows.
Because once that level of detail is centralized and accessible, it does not sit idle. It feeds systems. It refines models. It supports decisions that increasingly move further away from the individual appraiser who produced the work in the first place.
The appraiser is not being brought into that system. The appraiser is being converted into an input.
The structure of the bill makes that shift even more concerning. It repeatedly references an “agency” that will oversee this modernization effort, yet it never clearly identifies who or what that agency is. That lack of definition is not a drafting oversight. It is an open door.
The industry has seen what happens when that kind of space is left unclaimed. It gets filled by the groups best positioned to control flow and monetize access. That is how AMCs expanded their role in the first place, stepping into an undefined area, taking control of the ordering pipeline, and building a system around managing work they do not perform.
The bottom line is, an AMC business creates no value. (or added value)
But they control who gets the assignment and how much is paid for it. They make you bid on that work and keep ordering appraisals until someone gets the value they want. Inside of their pea sized brain that makes the appraisal a commodity. Sorry, I’m not selling pork bellies I’m producing top of the line reports. Stop bidding on work!
Now extend that structure into a system with access to nationwide appraisal data and the authority to regulate how that data is used. That is not a small adjustment to the existing framework. It is a consolidation of influence over both the process and the information behind it.
S.1635 does not need to remove the appraiser overnight to change the profession. It only needs to centralize the data, standardize the inputs, and allow systems to develop around that foundation. As those systems mature, reliance on individual appraiser’s declines, and the role itself becomes easier to redefine in ways that no longer require the same level of independence or judgment.
That is not speculation. It is a pattern.
This is why that initial (junk) email matters more than it should. It’s not about pickleball. It is about perspective. On one side, there are conferences, product demonstrations, and conversations about what comes next. On the other, there are appraisers navigating a prolonged slowdown while the structure around them continues to shift in ways they did not design and are not being asked to approve.
“Hi this is Frank from the AMC, come watch me drink Mint juleps and light Cuban cigars from $100 bills that came from the pockets of appraisers. Listen to me virtue signal about pickleball, the latest fad I know nothing about, but I look hip strutting around with the racket of which I overpaid” I’ve got your pickleball right here Frank!
This is not about resisting change. Appraisers have always adapted to new requirements, new technologies, and new expectations. The issue is not change itself, but who that change is being built for. AMC workers should have to bid each week to see if they work. “Sorry kids I didn’t bid low enough this week, looks like homelessness is coming soon.”
There is a clear difference between modernization that supports the appraiser and modernization that absorbs the appraiser.
S.1635 moves firmly in the latter direction. It removes the boundary around confidential work, opens the door to uncompensated use of appraisal data, and establishes a governing structure without clearly defining who holds authority. It does all of this while relying on the very professionals it sidelines to supply the information that makes the system function.
I invite appraisers, collateral risk professionals and lenders to take a look at a system built by appraisers for everyone. At HARBOR we solve the problems, give clear instruction on how that happens and places appraisers in charge of the valuation industry. “Someone holler at pickleball Frank and tell him the party is moving to HARBOR.”
On the topic of GSE’s disastrous policy changes towards automation and efficiency, market price discovery, AI utility substituting human appraisers, and data cancer. Mises.
https://mises.org/mises-wire/when-ai-agents-trade-ai-agents-price-discovery-dies
When AI Agents Trade with AI Agents, Price Discovery Dies
(partial copy.)
Goodhart’s Law at Market Scale
A second pathology emerges when agents dominate markets: the incentive to manipulate your counterpart’s objective function rather than compete on underlying value. If you know a procurement agent ranks vendors by a composite score of price, quality rating, and delivery speed, the optimal strategy is to game that score—not improve actual performance. This is Goodhart’s Law operating at market scale. Human buyers eventually notice and revise their frameworks. AI agents—running on fixed or slowly-updated objective functions—create stable exploit surfaces. A 2025 NBER working paper showed that autonomous reinforcement-learning trading algorithms can learn to coordinate and sustain supra-competitive profits without any explicit agreement or communication—emergent collusion that current antitrust frameworks, built around detecting explicit communication, are entirely unable to address.
The evolutionary dynamics are grim. Metric-gaming strategies outperform genuine-value strategies because they minimize actual performance costs while satisfying the score. As gaming proliferates, the metrics decay as proxies for value—but the AI evaluators keep using them. The market stabilizes at an equilibrium in which all agents game all metrics and the price signals contain no useful economic information.
What Must Be Done
Human-in-the-loop approval for consequential exchanges should be treated as epistemic infrastructure, not bureaucratic drag. A 2025 Gartner survey found that 74 percent of IT leaders already identify fully-autonomous agents as new attack vectors—institutional resistance that should be deepened, not eroded. Antitrust regulation must evolve beyond detecting explicit communication: the NBER collusion research proves emergent coordination produces anti-competitive outcomes indistinguishable from cartel behavior while falling entirely outside current law. And economists must stop treating efficiency as the terminal value in market design. Efficiency is an instrument. Discovery is the purpose. The digital advertising catastrophe—a trillion-dollar market where a third of spend reaches no human mind—is not an efficiency story, it is a preview of what every automated market becomes when human beings stop being the agents who make it work.
The Hayekian case for markets was never a case for algorithms. It was a case for human beings—for the irreplaceable epistemic contribution of persons acting on local, tacit, personally-discovered knowledge that no objective function can encode. As autonomous agents proliferate, the question is not whether they are efficient. It is whether they preserve, or quietly extinguish, the one property that made markets worth defending: the capacity to tell us things we did not know before.
All day long RESPA violations with the amc industry, going on twenty years now.
There is no actual oversight or accountability applied to the amc industry. Random find 2008; Connecticut appraisal board evidence and proposal to mitigate amc industry influence and damage.
https://www.cga.ct.gov/2009/GLdata/Tmy/2009SB-00303-R000205-Nora%20King%20-%20The%20Connecticut%20Association%20of%20Real%20Estate%20Appraisers-TMY.PDF
Received an email today (4/28/26) from an AMC informing me that condition matters. Thought I’d pass this along in case anyone was wondering.
Thank you, Baggins, for the new links, the compliment, and further discussion. Kenneth, I also thank you for the compliments and updated views on these issues.
I got that Reddit account banned for posting your article. Not the kind of message they are comfortable hearing I guess. Every comment ever, gone.
Truth hurts. That’s the problem with those kinds of social networking sites. They’re limited hangouts controlled by the tech industries. Make another one later. They’re all throw away accounts on that site anyways.
“I got that Reddit account banned for posting your article.”
I’m not surprised. The negative response since it first appeared over twenty years ago continues, even as it hinted at the Great Recession and the home foreclosure crisis that followed a few short years later.
With the inflationary recession I see coming, it may happen again comparatively soon. If so, it will coincide with a rapidly shrinking middle class, which may never recover. To prepare, I would urge appraisers to find clients and develop specialties outside of the mortgage banking sector, which has always been a good idea anyway.
No big deal. Reddit is toxic and I primarily was posting relevant links to this site anyways.
Your article was removed before this other event happened. So I know they did not want that to get out. It might have also been me asking a question if it is also a form of discrimination, if literally everyone else is identified as a protected class but you are not. Some other appraisers were talking about the new bias re education class being not very educational. Their post I think was taken down as well.
Reddit may have local moderators on individual sub section areas, but is a China controlled company at it’s heart. They don’t only just censor a post or two, merely take down an article now and then. They hit me with the comment nuke option, that traced back every post and comment ever, deleted everything. Good old China. They really don’t like Americans expressing free speech. Reddit is a place for people whom can not tolerate nor understand other peoples points of view. There is an underlying tone of political orthodoxy and lines shall not be crossed. I showed up and whistled right past the grave yard without a care. Easy come easy go. Thanks.
Two thumbs up for you.
I’ll start by saying this—Larry you deserves real credit for putting this together. A lot of appraisers see pieces of what your talking about, but very few step back and connect the dots the way you did here. The core thesis—that lender influence, fee compression, and structural dependency have shaped the profession far more than regulation ever corrected—is solid. That’s not easy to say publicly, especially in an industry where most people just keep their heads down and work. Larry you are speaking to something a lot of us have known for years.
Where I’d build on this point is this: the issue isn’t that regulation failed completely—it’s that it never went far enough to fix the underlying problem. FIRREA created a framework and a baseline, but it didn’t remove the economic reality that appraisers still answer to the very parties who benefit from the outcome. So what we ended up with is a system that looks independent on paper, but still operates under the same you is describing. That doesn’t weaken your argument—it actually reinforces it, because it shows the problem is structural, not accidental.
I’d also refine one key idea in a way that supports what you is getting at. Appraisers aren’t driving the market—we’re reacting to it. Credit policy, lending standards, and investor demand move prices. But where you is right is that appraisers get pulled into that cycle. The pressure to “make the deal work,” whether direct or indirect, is real. That doesn’t make appraisers the cause—it shows how the system puts them in a position where independence is constantly being tested. That’s the bigger issue he’s pointing to.
And where I think this conversation really needs to go—building directly off this foundation—is what the system has evolved into. It didn’t stop with AMCs or fee pressure. Now you’ve got layered influence: data models, automated valuation tools, and policy-driven narratives shaping outcomes alongside the same lender-driven structure. So the concern it is raising isn’t just about what the system was—it’s about what it’s becoming. Your article lays the groundwork, and the next step is expanding that discussion forward, because the pressures you is identified didn’t go away—they’ve compounded into something even bigger.
Larry your link did not work. Thankfully this piece you wrote is still available on The Way Back Machine.
As that important website may not be as permanent as thought, I’m also copying the complete text as it appears on the wayback machine in the content below.
Thanks.
https://web.archive.org/web/20040710063844/http://www.financialsense.com/editorials/reality/2004/0702.html
_____________________
The Fraud of Appraisal Regulation
by Larry S. Levy
~ Guest Editorial ~
Let us be clear before getting too deeply into this subject. The bread and butter of the real estate appraisal industry are provided by the financial services sector. No other class of clientele comes close, and most appraisers know no other source of business. Given that so many are so dependent on lenders as their source of work, they are quite subject to that outside influence over their standards of practice, even if they don’t see it themselves. Any class of business as powerful as the financial services industry would be foolish not to recognize, and not employ such an opportunity to advance their own interests.
With that fact of life out of the way, let us take a cursory look at the current regulatory environment influencing the appraisal industry, and the ramifications to the public interest. Our backdrop is The Savings and Loan Crisis of the 1980s. It culminated in the Financial Institutions Reform, Recovery and Enforcement Act of 1989 (FIRREA). That was the outgrowth of Congressional inquiry into the reasons behind the S&L debacle. Among other things, Congress found repeated instances of disreputable appraisers working in collusion with unethical lenders to fraudulently inflate the appearance of property values. Though well intended, FIRREA did little to prevent such abuses.
None-the-less, FIRREA did mandate that states regulate the activities of real estate appraisers. Oversight is by way of Federally supervised guidelines promulgated by the newly formed — and by all appearances independent — Appraisal Foundation. Separately, guidelines for appraisal practice and the engagement of appraisal services are issued by certain government sponsored entities (GSEs). [Examples of GSEs are agencies such as Freddie Mac and Fannie Mae, etc.]
From the beginning of this new era, however, and with a compound effect over time, appraisal usage standards and guidelines have been changed (centralized) at various levels in ways shocking to conscientious appraisers familiar with 1980s practices. What we have now is heavily influenced by the lending industry, which continues an increasing level of de facto usurpation of appraisal practice standards. New, “improved” appraisal reporting abbreviates former practices, helping to speed along the loan process and lower fees, particularly in the housing market. [“Lower fees” is in terms of overall annual costs to borrowers compared to what would be the case without these changes in reporting practices, including di minimus thresholds.] Who, then, can expect the general quality of appraisal work to exceed that of earlier times?
The system, as it has evolved since FIRREA, has helped financial institutions earn higher returns, at least in part, because appraisals are delivered swiftly, at low cost, and with more leverage toward influencing market prices. Note that the current regulator environment allows packages of loans (backed in part by regulated appraisal products) to be more easily bundled and sold to global investors. These are mortgaged backed securities in the game of two-tiered structured finance. In the process, risk is shifted to the buyer, and liability is transferred to the government (i.e., the taxpayer).
In one example, there are now “thresholds” of value below which appraisals are not required at all, or which may be conducted by appraisers who have demonstrated the lowest levels of competency. Would it surprise you to know that Federally related lending institutions (i.e., those covered by various forms of Federal oversight) have the option to avoid acquiring appraisals on real estate loans of $250,000, or less? It’s true, and such things did not exist prior to “reforms.”
Under the current system of funneling money into the mortgage system, appraisals more than ever impart a high level of security. That is because they appear to come from unbiased experts who are regulated by Federal mandate. Further, the higher the volume of loans, and the higher the appraised values of the collateral, the greater the power to increase the size of the lending institutions. Lenders, and GSE to some extent, therefore, have a very great interest in influencing the results of appraisal reports (and if risk can be transferred in the process, so much the better).
Appraisal regulation, it would appear, assists in pushing up the money supply (by way of helping to increase the value of collateral), economic activity (via higher and higher loan amounts in “cash out” refinancings), and lender profits. As such, regulation is little more than a ruse designed to shift financial liability for losses from the appraisal client (i.e., the lending industry) to the Federal government who is now responsible for appraisal oversight.
Should the Nation experience another serious financial “adjustment” like the S&L Crisis, lenders (and GSEs) will be able to point to Federally mandated appraisal regulation as their free pass to escape a Congressional inquisition (where property valuations may be called into question). They will have the appearance of having done everything according to “the book.” The investor groups suffering damages from having purchased loan packages (with this designer gift wrap) will have to seek a bail out from the government, the ultimate underwriter (and the overseer of lending and appraisal regulation). Naturally, the government will not accept blame, but it will go looking for a villain. Guess whom they will find?
This is not to say, of course, that we are going to suffer through another event like the Savings and Loan Crisis. But if we do, the foundations for lenders and GSEs to escape culpability have been laid (in so far as valuations may be to blame), and appraisal regulation in it’s current form will have assisted.
Meanwhile, users of appraisal services have become less selective in regards to the quality performance of their contractors. Why bother? They are all regulated, right? Contrary to intent, the quality of service has diminished with the advent of regulation. This is not surprising when seeing that reform means faster and cheaper appraisals. [Again, fees for some types of appraisal services have gone up in the last 15 years, but comparatively speaking, the overall cost in bundles of loans is much lower than would be experienced otherwise. Lower, too, are the overall returns to the appraisal industry.]
The decline in appraisal quality is also revealed when contemplating the development, and dramatic growth of the independent appraisal review field, something that was a nominal part of appraisal quality control before the introduction of regulation. If appraisal quality has been improved by regulation, would this large appraisal review field be necessary?
In actuality, it came about because of the higher incidences of failed quality control examinations on bundled loans. This generally lower quality performance from appraisers as revealed in these examinations is what forced the blossoming of the review field. It assists in providing cleaner looking appraisals in bundled loans, not necessarily more reliable valuations.
And, just as appraisal regulation tends to lower the general quality of appraisal performance, so does it also in the review field, and for the very same reason. It does, however, provide the user of appraisal services another level for escaping liability, while reducing the perception of risk. In other words, it’s the existence of the process that matters, and not the quality of it. If an appraisal has been performed by a Federally regulated individual, and been successfully reviewed by another regulated individual, it has an enhanced appearance of quality. That makes it much more attractive as wrapping paper for bundled loans. In practice, however, many competent appraisers will tell of a need for a review of the reviewers. The quality implied by the practice is generally lacking, and it often contributes to higher closing costs for borrowers, who are sometimes asked to pay this cost. The loan seller, however, does not care, so long as the appraisal and the formal review (if needed) look good on paper. It is the appearance of quality valuations that helps to make loans marketable, not the competence, dedication, experience, or ethical conduct of the appraisers.
Another development since FIRREA is the massive expansion of so-called appraisal management companies. These are firms that effectively warrant lenders a passable appraisal, supplied speedily, in any location, and for a competitive fee. On the surface, nothing is wrong in that. It is business fulfilling a need. These firms, however, generally award appraisal assignments to most any appraiser who is willing work for half the fee they could get on their own, and who must bear all the expenses of providing the report – office space, clerical support, computers, software, research materials, photographic equipment, supplies, etc. This is quite unlike earlier times, when substantially more of the after expenses fee went to the appraiser who accomplished the work.
This system of engaging appraisal management companies benefits lenders in their not having to maintain lists of qualified appraisers, and not having to engage staff for the purposes of supervising appraisal orders and fulfillment. The result, of course, is legions of lesser skilled appraisers who are willing to accept after cost returns far lower than the industry had been used to receiving. It cannot be unexpected, then, that quality is diminished. The practice also contributes to driving the more experienced and better skilled appraisers into other lines of work, because the appraisal management companies have commandeered so much of the national volume of appraisal requests. The best appraisers, therefore, generally are not as well rewarded for their more advanced years of experience, or their generally higher propensity toward professional self-improvement.
Another damaging part of the system is that which divides appraisers into two different classes of competency – one for the minimally qualified (the licensed level), and another for the more highly qualified (the certified level). The dividing line for appraisal assignments is based on rather randomly chosen benchmarks of loan value, or assignment complexity. [This is a separate issue from the distinction between commercial versus residential property.] The result of this division, however, is that highly qualified appraisers, particularly in the residential field, are forced to compete for the same assignments (and fees) as the lesser skilled appraisers. It gives a competitive advantage to the lesser skilled who are more eager to accept lower fees. It also results in higher proportions of mortgage portfolios containing valuations by the most minimally qualified valuers. Does this not actually increase risk, while disadvantaging the most qualified appraisers in the industry? Of course!
Don’t the lenders/mortgage brokers care? Not really. They are increasingly playing the odds, knowing that, historically speaking, very few real estate loans end in foreclosure anyway, and the risk is transferred to investor groups in bundled loans.
Consider also that the lending industry routinely supplies appraisers with the very essence of what produces bias in the valuation process, the loan amount. By providing the loan information, the typical appraiser responds by trying to make the appraisal fit the loan request. Obviously this has little effect on markets where borrowers are seeking mortgages with low loan-to-value ratios. In the case of 80, 90, and 100%+ loans — the majority of transactions — appraisers who “make the deal work” are influencing the market cycle, whether they know it, or not, and increasing the risk to the ultimate holders of these loans. Were facts otherwise, real estate lenders would be less inclined to reveal the size of a loan when requesting appraisal services. In that they do so routinely (in purchase money appraisals as well as in refinancings), it must serve their purposes. And it does.
Appraisal industry mantra says appraisals do not influence market prices. Yet, when nearly 100% of purchase money appraisals “hit the number,” and when the vast majority of real estate sales are facilitated with high loan-to-value ratios, appraisers are pushing the envelope of real estate prices. To argue otherwise says that every buyer and every seller is typically motivated in almost every real estate transaction, and that they fully appreciate the concept of Market Value when negotiating their deals. It ain’t so, or the words “typical” and “normal” would not appear in the formal definitions of Market Value. “Typical” and “normal” mean “most often,” not “all of the time.” Most transactions, therefore, will qualify as “typical” or “normal,” when others should not. Therefore, if the facts are known, not all sales contracts should be able to meet the test of Market Value.
Further, industry guidelines say that purchase contracts may represent the best “evidence” of value in an appraisal. “Evidence” is not proof, yet the “typical” appraiser will represent the contract as “typical,” though in practice they never see the contract, nor interview buyer and seller about their motivations. They also accept the negotiated price as “proof” of value. Were it indeed “proof,” appraisals for purchase money would not be needed. However, as appraisals are a required part of prudent lending behavior, and because the typical appraiser always, or almost always tends to prove the evidence of value disclosed in the contract price, appraisers have the effect of helping to push prices higher. It cannot be otherwise. Part of the proof in that comes from the fact that every appraiser uses comparative market data wherein the “evidence” of value behind those transactions was accepted as “proof” of value by other appraisers writing purchase money appraisal reports, and who also assumed those contracts were “typical.”
And, while real estate buyers may be relying to some degree on the loan appraisal to tell them whether, or not they may be overpaying for a property, appraisers routinely give no thought to that possibility. They labor under the impression that their job is to help complete the transaction for the lender. The cycle, then, as it gets repeated in purchase money transactions, tends to assist in ratcheting sales prices higher and higher, at least for as long as the market can tolerate that effect. [Please note, however, I am not arguing that appraisers are the cause of escalating property values, only that they play some part in it.]
Lest anyone think otherwise, consider what the effect on real estate values might be if appraisers were denied the information on their subject properties proposed loan-to-value ratios. In fact, the loan amount is completely irrelevant to the appraisal process most of the time in residential matters, and regulation does nothing to remove this form of manipulation. [We are speaking here, of course, about typical financings from traditional lenders. Atypical financings, even as components of financial packages, are relevant to the appraisal process where they exist. Such is rare in today’s market, however.]
Most appraisers are caught in this game 1) because they are paid employees of the lender (sometimes quite indirectly), or 2) are contractors who will suffer a loss of repeat business for not “hitting the number.” Some appraisers wisely and routinely discount the loan information, but not the vast majority who depend on the lending industry for their bread and butter, if not their entire means of sustenance. Hence, far too many appraisers are motivated by the need for sustained income, and have little regard for the lack of bias intended by regulation. This makes most of them little more than clerks, filling out forms and/or expressing narrative talents in completing commercial reports, all the while the users of appraisal services provide increasing influence over what constitutes their work product. Here may be at least one of the reasons industry vernacular has appraisers working out of “shops,” as opposed to offices. Offices are where professionals work. Shops, however, cater to customers, and “the customer is always right.”
OK, you may say, but isn’t regulation supposed to mitigate lender influence in the appraisal process? Perhaps, but as has been shown, the reality is something else. Besides, regulation does not make work product more professional, more ethical, or more accurate. It merely serves to support attractive “wrapping,” if you will, of a more easily marketable product. That product is globally marketed bundled loans, and therein is how collateral risk — supposedly mitigated with quality appraisals — is transferred.
So, does this not sound like a flawed system, or even a fraud? If it does, and it does to many observers, can appraisals backing the Nation’s mortgage portfolios generally pass the test as being truly unbiased documents? Probably not.
What’s the answer? How do we improve the quality of appraisals backing the nation’s mortgage loan portfolios?
I’m not sure anything can be done at this stage. Practical and feasible solutions are not going be considered by anyone at any level, until the fact of a problem is understood. That will take some looming threat, or actual damage to the system. By then, it may be too late. That aside for the moment, I have a few thoughts I will share with the reader. One place to start might well be to trash appraisal regulation and GSE appraisal guidelines in their current forms.
Doing away with the system and starting over is hard for me to propose. I was one of the early supporters of the concept of appraisal regulation, and I volunteered long hours to help ensure its creation. Like many, I was under the mistaken impression that regulation would lead to generally higher standards of performance from the industry, and a new level of recognition as a profession. Against my own expectations and that of others, the effect of the Federal mandate, born of the S&L calamity, never materialized in an independent committee of broad jurisdictional authority capable of discounting the needs of lenders in favor of the public interest.
On a personal level, I moved on some years ago — retired from the appraisal field after nearly 30 years of practice. In my time I worked several years as an in-house appraiser for a blue chip corporation that was then the largest private property owner in the United States. Thereafter, I was an independent appraiser. In the last half of my career, and while carrying leading credentials from two major trade groups, I almost never accepted appraisal assignments from traditional mortgage lenders, or brokers, except for reviews under special circumstances. I intentionally avoided these types of clients, having learned that they are generally the most cost and time sensitive of clients. Additionally, they are also the most demanding, the most fickle, and the least appreciative of all users of appraisal services. And they can afford to be arrogant toward appraisers. There are far too many willing to do their bidding, and herein lies the source of their power (to say nothing of their dominance at public hearings on appraisal subjects).
Though retired, I still remain in touch with the appraisal field. I have an emotional vested interest, social contacts, and I am a taxpayer who may one day be called upon to help pay for the errors of the current regulatory environment. I am, therefore, not an inexperienced, or out-of-touch observer. Having set the stage by that let me offer a few thoughts toward more responsible appraisal oversight in the public interest.
1) Especially in regards to residential property, any communication between lender and appraiser regarding loan amounts, or other suggestions toward appraisal conclusions should be prohibited by all authorities supervising the activities of lenders, and loan brokers, unless the loan structure happens to be atypical. Fines and other penalties should be imposed for violations.
2) All lenders and mortgage brokers who retain appraisal services should be made primarily responsible for the value of assets held as collateral (as of the valuation date) for the life of the loans, whether sold or not, keeping the taxpayer out of the loop. If the responsibility for appraisal quality were entirely that of the lender for the life of the loan, appraisal regulation would be less an issue, and the relationship between lender and appraiser would tend to be self-policing to a much larger degree.
3) Eliminate the division of lesser qualified and higher qualified appraisers in Federally related transactions. Make them all qualify at the same high standards, dividing only residential and commercial appraisal skills.
4) Require all appraisals reports and reviews thereof to include the appraiser’s/reviewer’s Statement of Qualifications, professional résumé, or other such document, allowing readers to better evaluate the experience, training, trade group association(s), and conceivably, the competence of the author. A mere signature over a typed name and license number generates no credibility of it’s own. Though such “brag sheets” are often ridiculed, the fact of such a requirement will force many minimally qualified appraisers to improve their credentials, or expose themselves too appearing unprofessional. Users of appraisal services and the public will benefit. The leading trade groups should recommend common guidelines for such disclosures.
5) Force appraisers to organize in a more efficient manner to effect self-regulation removed from the influence of their major clients, the financial services industry. In this way, they can be more collectively sensitive to the public interest, while discounting the clients need for faster, cheaper — but not better quality — appraisal reports.
In regards to point five, an industry fragmented by as many special interests groups as the appraisal field, is no profession, no matter how the various trade groups view themselves. Society cannot have scattered clusters of specialists in the same field calling themselves professionals, while each group tries separately to advance their own membership base, and public visibility. Such fractionalization promotes manipulation through weakness (as in the current situation), and suppresses the appearance of professionalism in the public’s eye.
Appraisers need one representative organization emphasizing qualifications, and standards of practice, while maintaining an overriding interest in, and dedication to self-regulation IN THE PUBLIC INTEREST. Is that possible? I don’t think so, but without it, the industry will remain a tool of its primary client, and a participant in the fraud of appraisal regulation.
© 2004 Larry S. Levy
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About the Author…
In his retirement, Larry S. Levy is a private email newsletter writer on metals and mining shares, and occasionally contributes economic and historical commentary on these subjects to international publications. In his former practice as a professional real estate appraiser, he held leadership roles in the leading trade associations, lectured, and published articles on valuation topics.
Editor’s Note by Gale Bullock:
Mr. Levy describes in his succinct essay the stranglehold that the banking cartel has on the realty valuation industry. The Appraisal Institute has an affiliate appraisal management company called REAS (Real Estate Appraisal Services) which operates http://www.aidirectconnection.com. REAS is owned by Charter One Financial Corporation, the 25th largest bank holding company in the USA, home based in Ohio. Royal Bank of Scotland is in merger and acquisition negotiations with Charter One to become the 7th largest bank holding company in the USA, after the Bank One and JPChase Manhattan merger as the second largest banking conglomerate. This conflict of interest doesn’t get any more blatant than these facts.
In Mr. Levy’s professional career as a realty valuation expert he attained a high level of proficiency, exemplary of expertise in both residential and commercial realty valuation. We are grateful for Mr. Levy’s guest essay, which documents the centralization of the realty valuation profession since the scam of FIRREA in 1989 — basically the setup for The Sting.
“We need to figure out how to get the message out across the market participants.”
While lenders remains the biggest users of appraisal services, they control the message. That message is “faster, cheaper,” but not so much “better.” [The mantra, “Faster, cheaper, better,” came out of Silicon Valley, CA, back in the late 1970s.]
With the commercialization of mortgage-backed paper, lenders ceased being responsible for the mortgages they created. Particularly with single-family mortgages, they packaged them, sold them, and passed along the liability while collecting generous fees. This process resulted in the evolution of Appraisal Management Companies and the Review Appraiser industry, and, in my opinion, a collapse in appraisal quality (and what used to constitute appraisal reviews).
My proposed solution long ago was to make the originator of the appraisal, the initial lender, responsible for the quality of the appraisal for the life of the mortgage, regardless of who holds the paper. Banking and certain other financial regulatory services could mandate this, but their lobbying efforts most likely will prevent any such effort.
Some twenty+ years ago, I wrote a paper touching on this subject that received a lot of attention. If the link still works, you may find it referenced here.
https://appraisersforum.com/forums/threads/the-fraud-of-appraisal-regulation-by-larry-levy.118191/
Here you go Larry.
Simply excellent.
Thanks.
https://www.reddit.com/r/appraisal/comments/1sq84ba/the_fraud_of_appraisal_regulation_by_larry_s_levy/
Look around right now. Loans are closing faster than ever, dashboards are green, and valuations are getting cleared in hours instead of days. On the surface, everything looks efficient—like the system is finally working the way lenders always wanted it to.
But that’s exactly when you should start paying attention.
Because this is how it starts. The cracks don’t show up all at once. They show up quietly. Deals that don’t quite make sense. Pricing that starts drifting from reality. Collateral that doesn’t perform the way the data said it would. And by the time anyone admits there’s a problem, the system isn’t just stressed—it’s already exposed.
And the one group that was supposed to act as an independent check? We’re not even in the room anymore.
We’ve been here before.
The 2008–2009 crash didn’t happen because there wasn’t enough data. It happened because valuation integrity broke down. The pressure to make deals work overrode independent judgment, and risk got buried until it couldn’t be hidden anymore. The lesson should have been permanent: if you lose independent valuation, you lose the ability to measure risk honestly.
Now we’re heading right back to the same place—just taking a different route to get there.
This time, nobody is leaning on appraisers to “hit the number.” That’s not the play anymore. The play now is building a system that doesn’t need us at all.
And let’s not pretend we don’t know why. It comes down to money.
Lenders run on volume, speed, and margins. That’s the business model. In that world, appraisers aren’t seen as adding value—we’re seen as slowing things down. We’re a checkpoint. A delay. A variable that can hold up the pipeline.
So what happens in a system built around efficiency? Anything that slows it down gets targeted.
That’s exactly what’s happening.
All the talk about “modernization” sounds good—better data, faster decisions, streamlined workflows. But look at what’s actually happening underneath that language. AVMs, hybrids, centralized review systems—they’re all doing the same thing: shifting control away from independent appraisers and putting it directly in the hands of the lender.
The message isn’t subtle. It’s faster, cheaper, and eventually… without you.
We’ve gone through different versions of this before. After 2008, appraisers were the scapegoat. Then the narrative shifted to bias, and the profession got dragged through that phase. Now it’s changing again.
This time it’s quieter, but it’s a lot more dangerous. The message now is simple: step aside.
With enough data and automation, the system is being built to function without independent valuation. Not overnight, and not in a way that sets off alarms. It’s happening gradually, piece by piece, until one day the role just isn’t relevant anymore.
That’s the real problem nobody wants to talk about.
Back in 2008, risk was hidden by influencing the appraiser. Today, risk is being hidden by removing the appraiser altogether. Different method, same result.
When the party with the financial interest controls the valuation process, independence disappears. And once independence is gone, transparency goes with it.
That’s not modernization. That’s risk concentration.
And concentrated risk is exactly what breaks markets.
What makes it worse is that the profession is focused on the wrong fight. We argue about fees, AMCs, and internal process issues—and yes, those matter—but they’re not what’s going to decide whether this profession survives.
While everyone is focused on those battles, the entire structure is shifting underneath us.
Control of valuation is moving upstream, away from independent appraisers and into lender-controlled systems. And once that shift is complete, it’s not something you can just undo.
At that point, it’s not an industry problem anymore. It’s a systemic one.
Because this doesn’t just affect appraisers. It affects loan quality, investor confidence, and the overall stability of the housing market. That makes this a policy issue whether anyone wants to admit it or not.
The real question isn’t whether technology should be part of the process. Of course it should.
The question is who controls valuation—and what safeguards are left to keep it independent.
Because once those safeguards are gone, the consequences aren’t theoretical. They’re real, and they’re systemic.
There are ways to fix this, but they require actually addressing the problem. Real fee transparency. Getting rid of assignment models that reward speed over competency. Independent review structures that aren’t tied back to the lender. And clear lines on where automation helps versus where it replaces judgment.
This isn’t about fighting technology. It’s about protecting the one thing the system actually depends on—trust in value.
Right now, the profession isn’t being eliminated in some obvious, headline-grabbing way. It’s being pushed out quietly, under the label of efficiency.
And that’s exactly how these systems fail.
We’ve already seen how this plays out. We know where it leads.
The only question now is whether anyone is going to recognize it early enough to do something about it—or if we’re just going to sit back and watch it happen again.
Pepsi challenge; Form the content into paragraphs with no single line statements. Give us essay format then again under the reverse triangle reversed essay type strategy. (Somewhere in the world an english teacher whom uses traditional red pen experiences a heart attack. A wolf howls in the distance under a dimly lit sky, the last rays of sunlight fading fast.)
Your robot mentioned ‘failing systems’… Hmm…. Let’s see here…. Recognizing non human work is a rather basic skill anyone can pick up. I officially volunteer for the John Henry vs machine, writing challenge. (crowd gasps in amazement. ‘He actually said it, that crazy sob actually did’. Bows left, bows right, exit rear stage. A computer chip short circuits, throws a multitude of sparks from the stage control panel, the lights go out. A man rushes to the board and sprays a fire extinguisher, clouds of smoke fill the air.)
https://economiccollapse.report/the-substack-ai-thought-experiment-that-erased-600b-and-has-insiders-both-terrified-and-ecstatic/
Citrini Research theory. I’ve copied in but a portion of this quite interesting story.
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The thesis itself and why it landed.
The Citrini scenario deserves a fair reading, regardless of where one lands politically or economically, because its core mechanism is not unreasonable. The essay’s central argument is that the U.S. economy is fundamentally a white-collar services economy, and that AI is not merely automating discrete tasks but is beginning to replicate entire workflows. As a result, companies that once purchased complex software suites from firms like Zendesk or ServiceNow are discovering they can rebuild that functionality in-house using AI coding tools — what the technology world has taken to calling “vibe coding.”
The bargaining power shifts. Vendors face margin compression. To preserve profitability, the vendors cut staff. And because those laid-off workers were consumers, their absence from the spending pool triggers downstream contractions in credit, housing, and consumer discretionary sectors. The spiral accelerates.
The irony is almost too precise. The very tools — AI-assisted trading, algorithmic amplification, sentiment analysis scraped from social media — that Citrini warns will displace human workers are the same tools now capable of translating a speculative narrative into a trillion-dollar market event before most Americans have finished their morning coffee. Wall Street has built an AI-accelerated market and is now genuinely uncertain whether it can control the machine it has assembled.
That is, by any reasonable definition, a bubble. Whether it pops the way Citrini’s fictional 2028 memo describes is unknowable. But the episode serves as a stark reminder that the complexity layered into modern financial systems — the derivatives, the leverage, the algorithmic feedback loops — does not reduce systemic risk. It concentrates it, accelerates it, and ultimately places it beyond the reach of any single institution or regulator to manage in real time. What the Citrini episode demonstrated, in miniature, is exactly the dynamic its authors warned about in the macro: a system so tightly coupled and so sensitively tuned that a small perturbation can cascade faster than human judgment can intervene.
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Appraisers should recognize many of the theories real world economic impacts. We were among the first to be replaced by automated tools via GSE’s AI/ML goals. As our work was replaced so was the every day consumers access displaced as ‘modernized tools’ prioritized concentrated power and real property holdings towards institutional investors interests primarily. The same interested parties which promoted automated theory and developed or acquired the tools for real world implementation in the mortgage lending space. Also known as ‘appraisal modernization’.
The appraiser licensee headcount attrition continues. It is much worse than many realize if focusing specifically on headcount of GSE appraisers who’s work is orientated primarily towards servicing lenders and citizens seeking loans for residential housing. As CG count in many locations is nearing half the total licensee population.
Here comes the market instability created by ‘algorithmic feedback loops’ which effect real world pricing and availability of housing. Also referred to as data cancer. The institutional changes that GSE mismanagement, appraisal trade group ineptitude and capitulation to one set of stakeholder interests over others. The processes now implemented have disrupted market segments to such a degree that it may be a plausible theory; nobody will be able to put the brakes on or mitigate the damage so readily visible on the horizon. Current status of FNMA managers; Tap dancing on a bubble, cigar and whiskey in hand.
Central planning never works.
https://appraisalbuzz.com/analysis-of-2025-asc-appraisal-license-data/
After reading this article, after reading these thoughtful comments, and after seeing another discussion, it dawned upon me that we are NOT targeting the most OBVIOUS group.
The article I’m referring to shows that the CONSUMER is not happy with nor trusts AI with the valuation of their largest lifetime investment.
We need to be educating the public.
We need to figure out how to get the message out across the market participants.
We need a 60 minutes special with Josh Tucker and other informed folks. All they would have to do is tell the truth. Most of the information regarding the danger we are headed for remains in blogs and Linkedin. It needs to be on billboads. Let the consumer know what’s happening before they don’t have a choice.
This is a concerning article that hits home to many of us. USPAP does not allow an appraiser to send, for example, a copy of the appraisal report even to the homeowner if not the named client. Yet they want to put it into a public data base? It makes no sense – or are they going to remove the Ethics rule? I, for one, cannot afford to go to some conference and trade show – not when I’m putting my software bill on my credit card as the income no longer supports the business expenses. I am still trying to find a new job – 100s of rejections at my age (although they don’t say that). Also trying to set up changes that might allow me to retire. Everything they do seems to take just that much longer for each report. I just had to draw a sketch of a utility shed – never had than happen before in 24+ years. Photos – of course, drawing a sketch of a small shed – never.
Just another reason to retire now. The appraisal industry as we once knew it, is sun-setting. Good luck to all.
I wish the right class action attorney’s would latch on to this. Confidentiality, intended users, and appraiser compensation for the data is deleted with the stroke of a pen…
While I am long retired and unaffected by this news, I have to wonder how a private contract between an appraiser and the appraiser’s client can, by legislation, become public property?
I’ve never practiced law, but this feels highly unconstitutional, at least insofar as it affects data gathered before the proposal’s enactment.
LSL, a former appraiser of (highly) complex properties
Yeah the 5th amendment piece is exactly why a lot of us raised an eyebrow. When the government takes something that belongs to you and turns it into public property, that’s where the takings issue shows up. Our reports are private work done under a private contract, not something the government can just scoop up and post online.
And honestly that’s probably why they backed off the whole public database idea and shifted to a “study.” They saw the legal mess coming. Forcing decades of reports into the open would have triggered a wall of lawsuits, and they know it.
So yeah your instinct is right. This is not some small policy tweak. It hits the core of what an appraisal even is.
The appraisal trade group executives whom can afford and access lawyers of this nature to challenge unconstitutional situations are the primary advocates for the amc industry and lenders interests rather than every day working appraisers. Who’s going to go against institutional investors when they have co opted nearly the entire mechanism from the appraisal trade groups, to fhfa, the entire gse apparatus all fronts except the va (but soon the va too), comptroller, even congress. As usual, consumers are the most harmed.
Have you seen this ofcom thing about censorship? They are censoring appraisers for a similar reason and it’s very bad for stability of housing and financial security of citizens across this country. There is not a single lawyer whom ever stands up for small business appraisers outside of individual low level cases.
https://order-order.com/2026/03/19/ofcom-fines-4chan-520000-lawyer-responds-with-picture-of-giant-hamster/
Our trade group reps love the current situation. They’re all directly or indirectly benefiting from the automation, the amc’s, the institutional investors, etc.
Once they strip mine all of the data, they can send the orders to Indian scammers to input the data into some sort of regression analysis app and voila, you’ve got yourself the paper you’ve always wanted and can live happily ever after, knowing you did your best to make the world a better place.
Overlaying with geographic analysis, the proposed nationwide appraisal database (in addition to opening the door for widespread scraping, modeling, and third-party use) may be used to evaluate if bias impacted value conclusions
‘Bias’. Get a clue. The entire real property industry top to bottom has ‘bias’. It’s called preference for housing and is driven by buyers and sellers, confirmed and negotiated by their agents. Appraisers don’t set the market, they only report on market activity, valuation benchmarks other people establish. It is impossible for there to be appraiser bias of this nature at scale. There are a hundred sales agents for every appraiser out there and the GSE lending apparatus has sent the majority of originated loans through pass through automatic service for the last decade anyways. They’re not even getting appraisals anymore except for the most high risk over leveraged borrowers.
Gse’s set the market with their automation more than anything else. They deny loans. They redirect wealth to corporate investors via the Whole Lending programs. The formula is simple; Do anything to approve origination loans, pass as many as possible through regardless of they qualify or not. This causes mass over pricing and over valuation of markets. (when people are denied access to inflated market price and value benefit, that is where they are trained to blame appraisers because they do not understand how the system actually works.) Then when they are financially compromised and foreclosed upon, the gse’s engage directly with ‘note sales’ and ‘debt sales’ which funnels the properties directly to institutional investors at firesale pricing nobody else can access.
The markets remain permanently heated and over priced until they crash, and the institutional investors scrape up even more properties. They’ve been doing this for the past decade and have already accumulated a fifth of all residential property in this country in that short of a time frame. Ethan you are parroting talking positions you don’t really understand. The most effective mechanism for identifying sub adequate appraiser practice is actual full appraisal review service, from another licensed appraiser. The advent of automation for appraisal review is where these unicorn half baked illogical ideas of appraiser bias came from in the first place. The most effective way to prevent over valuation and under valuation through the entire market spectrum rich to poor, coast to coast, is a fair free market where people have equal access and everyone goes through the same standard process of requiring an independent third party licensed appraiser provide service for loan approval.
Please allow me to introduce you to eval’s and automation bias. Image attached. These systems are price reactive every last time. Zillow took billions in write downs when they tried to use their own avm systems in real world scenarios, or whatever the number was it was substantial. Jeremy Bagott published an article about that just today. The ‘appraiser bias’ narrative was ushered in as an excuse to retool the entire system so wall street interests now have direct access and incredible control to all the citizens housing. That’s your bias. ‘Appraisal modernization.’ Total failure right out of the gate. It’s a con. Everything automated in this space is a con.
I see where you’re going with that. The thing a lot of us worry about is how fast those big national datasets get misread once they’re mashed up with census layers or demographic overlays. You take all the values, stack them on top of whatever public data you can grab, & suddenly someone 30,000 feet away decides an appraiser “looks biased” based on a pattern a spreadsheet thinks it sees.
The issue is, none of that analysis knows the actual market. It doesn’t know the housing stock, the condition mix, the sales patterns, or the weird little micro‑markets we deal with every day. It just sees numbers on a map & starts drawing conclusions. So even if the work is solid, the comps are tight, & the market supports the value, someone can still point at a pattern & say it “looks suspicious.”
That’s the real concern. Not transparency, but misinterpretation. Once everything is public, anyone with mapping software can play detective without understanding the neighborhoods we’re actually working in.
I’ve titled this photo; The impossible comp search.
Slightly redacted to protect the innocent.
Always nice to see someone in this field actually trying to build something instead of just yelling into the void. There are parts of HARBOR that hit home for those of us who spend our days in crawlspaces, attics, & neighborhoods we actually know. The BIT idea is one of them. Finally, something that treats our data like it has value instead of letting GSEs, AMCs, & every tech outfit on earth strip it, resell it, & pretend we should be grateful for the exposure. Getting paid when our work keeps getting reused is long overdue.
There are still pieces that make me pump the brakes a bit. We just watched Congress flirt with the idea of pulling every report back to 2017 into a public, searchable, downloadable database. Full narratives, comps, adjustments, addresses, names, license IDs… the whole thing. That kind of setup turns years of fieldwork into free training data for anyone with a scraper. The only reason it slowed down was because the legal risk was too big to ignore.
That is why the structure matters. A national framework only works if it respects the fact that markets are local. Local appraisers need to be the ones doing the work in their own markets. Once out‑of‑state appraisers start dropping into places they do not understand, the quality goes sideways fast. No amount of “modernization” fixes that.
There is real potential here, & I appreciate anyone who is at least trying to move the profession forward instead of letting Congress or big tech do it for us. The key is making sure the protections are as strong as the ideas, especially for the people actually out there doing the work.
I read this article and I agree with more of it than I disagree with, especially the part about independence and what happened back in 2008. That’s not something anyone in this profession should forget. The system didn’t fail because we didn’t have enough data. It failed because the people responsible for valuing collateral were either pressured or ignored, and risk got buried until it blew up. That part is dead on.
But I think the article stops short of where the real problem is heading.
This isn’t just about lenders wanting things faster or AMCs controlling workflow. That’s been going on for years. We’ve all dealt with it. What’s different now is the direction the industry is moving in, and it’s a lot more calculated than just squeezing fees or speeding up turn times. The real shift is toward capturing the appraiser’s work itself, standardizing it, and building systems that can function without us.
That’s the part that’s getting missed.
The article says this time it’s not about pressuring appraisers, it’s about building a system that no longer needs them. I agree with that. But how do you think that system gets built? It doesn’t just appear out of thin air. It’s built off the back of the work we’ve already done. Every comp selection, every adjustment, every line of reasoning in a report—over time that becomes data. And once that data is centralized and studied, it becomes the blueprint for replacing the very people who created it.
That’s not modernization in the way it’s being sold. That’s extraction.
There’s a big difference between using technology to support the appraiser and using it to phase the appraiser out. One helps you do your job better. The other turns your work into an input that eventually replaces you. Right now, the industry is leaning hard toward the second one, whether people want to admit it or not.
I also agree with the point that appraisers are fighting the wrong battles, but I’d take it a step further. It’s not just that we’re focused on fees and AMCs. It’s that we’re not paying attention to who is gaining control of the data behind the valuation process. Because once someone else controls that, they control everything that comes after it.
That’s where this ties back into the bigger picture. This isn’t just about protecting appraisers. It’s about protecting the integrity of the system. When the same side of the transaction starts controlling valuation—whether directly or through models built off centralized data—you lose the one thing that keeps the whole thing honest. Independence goes away, and when that happens, risk doesn’t disappear, it just gets harder to see.
We’ve already lived through what happens when valuation stops being independent. The difference now is it won’t look the same on the surface. It’ll look efficient. It’ll look clean. It’ll look like progress. But underneath, you’re concentrating risk in the same place again.
So yeah, the article is right about the direction things are going. But this isn’t just a slow erosion of relevance. This is a structural shift. Independent judgment is being turned into data, and that data is being used to build systems that don’t need independent judgment anymore.
And if that keeps going, by the time it’s obvious what happened, there won’t be much left of the profession to push back with.
I’m with you on the direction this is heading. The part that keeps sticking in my mind is how this mirrors what’s already happening in other industries. You’ve probably seen those videos of factory workers overseas wearing head‑mounted cameras while they assemble products, not for training them, but to train the AI that’s going to replace them. Every hand movement, every decision, every tiny adjustment gets recorded so the system can learn the job & eventually do it without the worker.
That’s basically what’s happening to us, just without the cameras. Our comp choices, adjustments, reconciliations… all of it gets centralized, standardized, & fed into models. The system needs our judgment to build the thing that eventually sidelines our judgment. And that’s the extraction piece.
Once somebody else owns the valuation data, they pretty much own the whole thing. Independence turns into a buzzword, & by the time anyone realizes what that actually means, the profession’s already been gutted.
Someone has an advocate, might not be the every day working appraiser. Missing the IVPI Proposal yet? When queried otherwise ai has stated that the IVPI proposal is a workable solution.
https://www.workingre.com/wp-content/uploads/2013/08/IVPI-Proposalfinal.pdf
Anything that removes AMCs from the process would be wonderful. Perhaps we could finally earn a decent living again.
Anything that gives appraisers a real seat at the table never gets traction because it doesn’t benefit the people who want control of the data.
Nowhere did I see borrowers mentioned in this discourse. I thought appraisals were intended to reduce (or manage) risk to the borrowers and lenders. Who handed AMC’s the power to set fees, monitor turn-times and review completed assignments. I don’t work for AMC’s, yet they are the dog and I am the tail. My due diligence is intended for the client and/or the borrower only. Confidentiality is the root of our profession. Independence is a critical component of what we do.