Certified Appraisers vs. Unlicensed Data Collectors

Pushback to Fannie Mae: Certified Appraisers vs. Unlicensed Data Collectors. Here’s a great take on the difference between Certified Appraisers vs. Unlicensed Data Collectors by Leigh Brown, President of the NC Association of REALTORS. Fannie Mae has been working hard to get rid of appraisers for years. Their latest twist is to re-categorize many appraisers as “Unlicensed Data Collectors.”

Fannie Mae will end up creating more instability for the trillions in the bond market – investors will have to process millions of valuations with the physical attributes of the home collected by unlicensed, uninsured, and unprepared individuals getting paid $10-$25 per inspection.


AI meets with Fannie Mae regulators to address Fannie Mae initiatives that disenfranchise new trainees

The following letter to FHFA provides an overview of Fannie Mae’s initiatives that will inevitably threaten collateral integrity in the multi-trillion bond market. Fannie Mae seems to be working hard to disincentivize new appraisers from entering the profession. Kudos to Craig Steinley’s leadership.

This is to follow up on a meeting Appraisal Institute representatives held in Washington, D.C. with members of the Federal Housing Finance Agency Divisions of Housing Mission and Goals and Fair Lending March 8 to discuss the new Value Acceptance program released by Fannie Mae…

Of particular concern is the encouraged development of an alternative workforce of property data collectors that may negatively impact aspiring appraisers’ ability to enter the appraisal profession…

Experience earned outside of the supervisory appraiser process would require a change to the Real Property Appraiser Qualifications Criteria and an overhaul of the logging of experience and oversight process. In the meantime, we believe the current policies around property data collectors are at cross-purposes relative to bringing new and diverse appraisers into the profession. Value Acceptance + property data collection is expected to exceed current waiver rates today based on information from our conference call. Historically, this is work that could be completed by appraiser trainees. This would be compounded should hybrid appraisals be allowed, which would potentially cut out appraiser trainees for property data collectors altogether.


Jonathan Miller
Jonathan Miller

Jonathan Miller

Jonathan Miller is President and CEO of Miller Samuel Inc., a real estate appraisal and consulting firm he co-founded in 1986. He is a state-certified real estate appraiser in New York and Connecticut, performing court testimony as an expert witness in various local, state and federal courts.

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7 Responses

  1. Avatar Xpert says:

    Great video. We need more advocates like Leigh Brown!

  2. Avatar IMJSAYN says:

    Numerous states require anyone “analyzing” real property condition to be licensed in accordance with state regulations and laws. The acts of a property data collectors by definition require analysis of condition and quality of a home. These are the actions of the performance of an “appraisal assignment” and in some states can ONLY be performed by a Licensed/Certified appraiser. Anyone watching this video needs to check their state laws and find out if that is a requirement.

  3. Baggins Baggins says:

    Watched the video, interesting. Read the letter.

    The amc’s whom helped develop and are pushing the hybridization, cloud based new forms, and ‘appraisal modernization’, are the same whom push the unlicensed property collector approach. Amc companies, including the vast majority of their owners and employees, are not bound by any code of ethics either. There is no individual licensing requirement for the amc companies, except for a rather meaningless requirement the entire amc corporation must hire at least one single solitary licensed appraiser. Pick a side; pro individual licensing requirements, or departure from individual licensing requirements. To agree with much of what the amc industry promotes, is to be against individual licensing. The vast majority of the amc industries efforts and expenditures has revolved around substituting licensed professionals for unlicensed third party servicers, alongside clever work arounds to bypass regulatory intent which is structured around individual licensing and accountability. Automation efforts alongside modernization efforts, as far as the amc industry is concerned, is synonymous with abolishing the need for licensed professional person participation in general. Greater income potential is on the horizon for the amc corporations, as they move to increase the momentum to ‘modernize’ other processes such as inspection, automatic valuation utility engagements, forms restructuring, engagement process restructuring in general, etc.

    Overall, better than expected and thank you to Leigh Brown and Craig Steinley for putting these pieces together.

  4. David Samnick on Facebook David Samnick on Facebook says:

    Keep pushing back!!!

    • Baggins Baggins says:

      Related. USDA celebrates the one year anniversary of the pave task force. Third party unlicensed inspectors for agricultural properties! Something about the supposed ‘resistance’?

      Are the multitudes of policy decision makers even aware that the ‘appraisal management industry’ in many situations currently fulfills more vendor assignments to persons whom do not hold appraisers licenses, than those that do hold appraisers licenses? Third party profiteering with a conscious intent to remove individual licensing and general accountability, bypassing regulatory intent imposed on licensed individuals is more like it. Equity!

  5. Avatar Troy K says:

    While I certainly like seeing this video, and bravo to anyone out there speaking up, I would have really liked to hear her speak to the more significant problem, which is the lack of reliability of inexperience, unlicensed and untrained data collectors versus the “creepiness” factor of having someone unlicensed in your home. That is what really needs to be hammered home here.

  6. Leigh Brown did a great job in clarifying the condition that we have today. Regarding AVM’s, I have not run across one that can specify if the subject property sits adjacent to a sewer treatment plant!! Oh, and, hey, how about the interior condition of the houses? And, hey, how about the liability the appraiser accepts when he uses data from a non certified third party without seeing it for him/herself? This is a large step backward in streamlining and improving the system., my two cents. John Welter, Certified General.


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Certified Appraisers vs. Unlicensed Data Collectors

by Jonathan Miller time to read: 1 min