Consumer Financial Protection Bureau - Appraisers Blogs

Appraiser Independence: What Does it Mean & Who Does it Apply to

Guest Author — Mon, 31 Aug 2026 12:30:57 +0000

Why It Matters Appraiser independence is mandated by state and federal laws – not a professional courtesy. Every agent, broker, loan officer, lender and AMC involved in a transaction with a lender-ordered appraisal is legally prohibited from influencing the appraiser’s value conclusion and from interfering in the appraisal process. Violations can cost you your license, trigger federal civil penalties, NAR sanctions, civil liability, and in extreme cases, criminal prosecution.1 “I didn’t know” is not a defense. The Legal Foundation Three federal frameworks govern this area. Title XI of FIRREA (1989) requires all appraisals for federally related transactions to be performed...

Violating Appraisal Independence Through Harassment,… It shall be unlawful... to engage in any act or practice that violates appraisal independence... Appraisers, I have written the…
No I Won't Work With This Appraiser How much power do agents have over the appraisal process? The lender gets a call. Agent tells them that appraiser…
Expert Wants to “Eliminate” Appraisers Mortgage Industry Expert Wants to “Eliminate” Appraisers – A Response The National Mortgage News website just published an interview with…

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The AMCs: Coming Soon to a Lawsuit Near You

AppraisersBlogs — Tue, 20 Jan 2026 13:30:22 +0000

The AMCs built an entire system on silence, and now the quiet parts are being said out loud. For years, the mortgage industry has insisted that appraisal management companies are the guardians of independence, the compliance buffer that keeps lenders and appraisers at a safe distance. Yet 2025 has delivered a storyline that feels more like satire than industry narrative. Borrowers are suing, judges are listening, and the AMC business model is beginning to look less like a safeguard and more like a very expensive middleman with a very opaque invoice. The first shock came from California, where the Timmins...

Lack of Fee Transparency: Exposing the AMC Exploitation By keeping the borrower in the dark about the true cost of the appraisal, the AMCs are able to charge…
The Appraisal Fee Lawsuit AMCs Can't Outrun The class action lawsuit filed against CrossCountry Mortgage and Class Valuation arrives at a moment when many in the appraisal…
AMCs Deceptive Fee Skimming Exposed in Lawsuit Rocket Mortgage and the AMCs actively conceal this fee skimming from borrowers, never disclosing the proportion of the "appraisal fee"…

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Fannie Mae’s Conservatorship: A Babysitter’s Blunder

Guest Author — Mon, 28 Apr 2025 12:30:06 +0000

Calling the FHFA a babysitter for Fannie Mae doesn’t fully capture the dysfunction. What the general public doesn’t understand is that Fannie Mae has been under conservatorship since the 2008 market crash — a status far from ideal, just one step from bankruptcy. By definition, a conservatorship is a legal arrangement where a court appoints a conservator to manage the affairs of an entity unable to do so itself, due to financial distress or other incapacity. It’s a polite term for babysitting an organization that can’t handle its own affairs. A Babysitter Who Sparks Chaos Calling the Federal Housing Finance...

Data Cancer Infecting the Real Estate Market They have created the phenomenon known as “data cancer” which reduces an appraisal to a rubber stamp that contaminates the…
Fannie Mae Fraud and Abuse Exposed History of waste, fraud & abuse at this rogue organization... Fannie Mae reported this week it had fired more than…
A Cry from the Appraisal Trenches: The Fall of GSE Oversight That could bring our best and brightest back to GSE lending, leveling the playing field with fairer work distribution. Picture…

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A Cry from the Appraisal Trenches: The Fall of GSE Oversight

Guest Author — Fri, 25 Apr 2025 12:30:13 +0000

That could bring our best and brightest back to GSE lending, leveling the playing field with fairer work distribution. Picture this: a system built to protect homeowners, backed by taxpayer dollars, now teetering on the edge of betrayal. The regulatory framework governing Government-Sponsored Enterprises (GSEs) was once a fortress of consumer protection, transparency, and fairness. As an appraiser, I’ve watched this fortress crumble. The rules imposed on GSEs and their partners—our trade-off for their congressional charter—have been chipped away through years of cunning maneuvers by trade groups and stakeholder interests. What’s left is a hollow shell, far removed from the...

Data Cancer Infecting the Real Estate Market They have created the phenomenon known as “data cancer” which reduces an appraisal to a rubber stamp that contaminates the…
The Great Debate on Appraisal Fees She included several different fee split examples indicating AMCs retained as much as 70 percent of the total appraisal fee…
It’s Time to Take Out the Junk: AMC Practices Exposed Appraisers have spent years carrying the weight of broken AMC practices, and this article pulls every one of those practices…

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AMCs Deceptive Fee Skimming Exposed in Lawsuit

AppraisersBlogs — Tue, 25 Feb 2025 13:30:23 +0000

Rocket Mortgage and the AMCs actively conceal this fee skimming from borrowers, never disclosing the proportion of the “appraisal fee” that is pocketed by the AMC rather than being paid to the appraiser. The class action lawsuit, Timmins v. Clear Capital, et al., filed on November 1 in the Superior Court of California, County of Stanislaus, sheds light on the deceptive and unfair business practices allegedly perpetrated by ClearCapital.com, Inc., Core Valuation Management, Inc., and Rocket Mortgage, LLC in relation to the appraisal fees charged to borrowers in home mortgage transactions. The complaint asserts that these defendants engaged in a...

The Appraisal Fee Lawsuit AMCs Can't Outrun The class action lawsuit filed against CrossCountry Mortgage and Class Valuation arrives at a moment when many in the appraisal…
The AMCs: Coming Soon to a Lawsuit Near You The AMCs built an entire system on silence, and now the quiet parts are being said out loud. For years,…
Appraisal Regulation Compliance Council Exposes… The Appraisal Regulation Compliance Council published a detailed breakdown to the CFPB, which showed the median average AMC fee being…

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The Shadowy AMC Fees Draining Billions from Homebuyers

AppraisersBlogs — Thu, 09 Jan 2025 13:30:46 +0000

The hidden costs of appraisal management companies (AMCs) in the real estate industry have faced growing scrutiny, as highlighted by a recent Business Insider article titled “The Hidden Middleman who cost homebuyers $12 billion dollars and counting.” The article examines the opaque practices of AMCs, which frequently charge exorbitant fees that can exceed the amount paid to the appraiser. As highlighted by former Appraisal Institute CEO Cindy Chance, this issue has faced significant resistance from entrenched interests, mirroring the challenges faced in other industries such as the pharmacy benefit manager (PBM) sector, which ultimately led to an FTC investigation. The...

Lack of Fee Transparency: Exposing the AMC Exploitation By keeping the borrower in the dark about the true cost of the appraisal, the AMCs are able to charge…
Appraisal Regulation Compliance Council Exposes… The Appraisal Regulation Compliance Council published a detailed breakdown to the CFPB, which showed the median average AMC fee being…
AMCs Billing Scheme, Hidden Profits & Deceptive Practices Appraisers who do not agree to their hidden billing methods are excluded from the majority of the GSE lending marketplace…

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Appraisal Industry Outlook Under Trump Administration

AppraisersBlogs — Mon, 06 Jan 2025 13:30:04 +0000

In a recent article, John D. Russell, JD explored the potential impact of the new Trump administration on the appraisal industry. With Republicans set to control the legislative process, Russell analyzed various documents and comments to distill expectations for how appraisal-related issues may be handled going forward. He noted that the Trump administration’s efforts will likely reflect much of the Project 2025 platform, and that its approach to the GSEs and FHFA in the first term could mirror that of the previous administration. Late first-term efforts on housing finance reform may also provide insight into second term priorities. Regarding the...

GSE Exec Boasts Scheme to Slash Appraiser Numbers At a recent appraisal event, a GSE executive, after a few drinks, privately told his nearby colleagues that we suck…
FHFA's Appraisal Waivers Expansion The Federal Housing Finance Agency's (FHFA) recent push to expand the use of appraisal waivers represents a concerning and potentially…
ARCC Discussion Exposes GSEs Agenda to Reduce… Mark Calabria's discussion with ARCC revealed the GSEs' agenda to reduce "appraisal friction" by eliminating the role of professional appraisers…

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The Great Debate on Appraisal Fees

Isaac Peck — Mon, 28 Oct 2024 12:30:09 +0000

She included several different fee split examples indicating AMCs retained as much as 70 percent of the total appraisal fee paid by the borrower, which prompted her to stop working with AMCs because of the lack of transparency. The appraisal industry is abuzz with a discussion about appraisal fees. The Consumer Financial Protection Bureau (CFPB) recently issued a Request for Information Regarding Fees Imposed in Residential Mortgage Transactions [Docket No. CFPB-2024-0021] in which it solicited feedback from the public and industry stakeholders on the fees charged to consumers by mortgage providers and related settlement services. The CFPB framed it as...

Appraisal Regulation Compliance Council Exposes… The Appraisal Regulation Compliance Council published a detailed breakdown to the CFPB, which showed the median average AMC fee being…
Lack of Fee Transparency: Exposing the AMC Exploitation By keeping the borrower in the dark about the true cost of the appraisal, the AMCs are able to charge…
AMCs Billing Scheme, Hidden Profits & Deceptive Practices Appraisers who do not agree to their hidden billing methods are excluded from the majority of the GSE lending marketplace…

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Appraisal Regulation Compliance Council Exposes Disturbing AMC Violations

AppraisersBlogs — Fri, 30 Aug 2024 12:30:34 +0000

The Appraisal Regulation Compliance Council published a detailed breakdown to the CFPB, which showed the median average AMC fee being charged to borrowers amounted to a staggering 65% of the total appraisal fee, with one AMC extracting as much as 84% in pure profit. The Appraisal Regulation Compliance Council (ARCC) is a crucial non-profit organization that specializes in providing fact-based research and expertise on the complex web of appraisal regulations and compliance issues. Driven by a non-partisan mission, ARCC has spent the last two years diligently collecting, vetting, and organizing comprehensive data on lender appraisals conducted by Appraisal Management Companies...

AMCs Billing Scheme, Hidden Profits & Deceptive Practices Appraisers who do not agree to their hidden billing methods are excluded from the majority of the GSE lending marketplace…
AMCs Violating TILA and C&R Fee Clauses Fellow Appraisers, the appraisal industry has been facing a major issue with AMCs violating the Truth in Lending Act (TILA)…
Lack of Fee Transparency: Exposing the AMC Exploitation By keeping the borrower in the dark about the true cost of the appraisal, the AMCs are able to charge…

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County Assessors’ Standards | AVM Final Rule Guidance

Dallas T. Kiedrowski, MNAA — Fri, 23 Aug 2024 12:30:47 +0000

County Assessors have the advantage of being able to calibrate their models specifically for one market, allowing for a more tailored and precise approach. The OCC, FDIC, NCUA, CFPB, and FHFA (collectively, the Agencies) are adopting a final rule to implement AVM quality control standards mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). The quality control standards apply to mortgage originators and secondary market investors in determining the value of a dwelling that is the collateral for mortgage financing. Under the final rule, institutions involved in specific credit decisions or securitization activities are required to...

House Measurement by Property Data Collector Gone Wrong The lender allowed an unlicensed property data collector give bad data to the appraiser... I work for this lender and…
AVMs... Garbage In, Garbage Out Garbage data in means garbage results out every time! It's no secret that AVMs have been a thorn in the…
Is the GSE's "Appraisal Modernization" Really Just… Mass Appraisal tend to exhibit a regressive nature... In the intricate landscape of real estate mortgage financing, the notion of…

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Insights from CFPB’s Public Comment Period

AppraisersBlogs — Tue, 13 Aug 2024 12:30:20 +0000

The comment period on the Consumer Financial Protection Bureau’s (CFPB) “Request for Information Regarding Fees Imposed in Residential Mortgage Transactions” concluded on August 2, 2024, with a total of 959 comments received. Upon reviewing some of these submissions, several noteworthy perspectives emerged regarding appraisal fees and the role of Appraisal Management Companies (AMCs). The National Association of REALTORS® (NAR) highlighted the lack of transparency surrounding AMC fees, which are often bundled together with the actual appraisal fee on the Closing Disclosure (CD). This opaque structure prevents consumers from understanding the true cost of the appraisal service and hinders their ability...

Lack of Fee Transparency: Exposing the AMC Exploitation By keeping the borrower in the dark about the true cost of the appraisal, the AMCs are able to charge…
The Illogical Reality of Mortgage Appraisal Reviews Reforming the appraisal review process is essential to maintaining the integrity of the real estate market and protecting consumers and…
Gov't-Indulged Middlemen Are Wrong RX for Battered… The U.S. government impoverishes homebuyers as it does the chronically ill – by promoting the use of middlemen who prey…

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Lack of Fee Transparency: Exposing the AMC Exploitation

Desiree Mehbod — Wed, 31 Jul 2024 12:30:07 +0000

By keeping the borrower in the dark about the true cost of the appraisal, the AMCs are able to charge exorbitant prices and pocket the difference (as shown in Figures 1 through 10), exploiting the consumer’s lack of knowledge. Thank you for the opportunity to comment on the Consumer Financial Protection Bureau’s Request for Information on Fees Imposed in Residential Mortgage Transactions. The growth of Appraisal Management Companies (AMCs) in the wake of the 2008 financial crisis was driven by a well-intentioned but ultimately misguided belief that they could help “ensure the integrity and independence” of property valuations. The reasoning...

Exposing Predatory AMCs Exposing the inner workings of these predatory AMCs and their corrosive influence on the housing market. Cindy Chance's recent comments…
AMCs Billing Scheme, Hidden Profits & Deceptive Practices Appraisers who do not agree to their hidden billing methods are excluded from the majority of the GSE lending marketplace…
AMC Fee Impact on Appraisal Fee While the borrower was charged $695 for the appraisal, the appraiser was only paid $301. The AMC fee was $394. …

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Uncovering Flaws in FHA Appraisal & Loan Review Process

AppraisersBlogs — Mon, 15 Jul 2024 12:30:32 +0000

The story of this single mother’s harrowing experience with a defective home purchase and HUD’s negligent oversight exposes deep flaws in the FHA appraisal and loan review process. After sacrificing for years to rebuild her credit and earn the right to become a homeowner, this borrower found her dream home in the country – or so she thought. During the home inspection, several issues were flagged. The seller, an investor who had purchased the home in an estate sale, was unaware of the septic system’s location. The seller agreed to have the tanks pumped so the location could be determined....

The Appraisal Problem Gone are the days of hiring a professional appraiser to solve the appraisal problem. For decades lenders have taken on…
Scope Creep & the Imploding of Rules ...the imploding rules then implemented, and the scope creep that evolved because the cart was leading the horse, has severely…
AMC Reviews of Appraisals Only the lender's Underwriter should be able to request changes to the report and the lender should be the one…

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Gov’t-Indulged Middlemen Are Wrong RX for Battered Borrowers, The Infirm

Jeremy Bagott — Mon, 17 Jun 2024 12:30:21 +0000

The U.S. government impoverishes homebuyers as it does the chronically ill – by promoting the use of middlemen who prey upon them. A cadre of such middlemen was created decades ago as a firewall between Big Pharma, the insurance companies and the pharmacy chains. Called “pharmacy benefit managers,” they were to negotiate drug prices, streamline distribution and manage lists of prescription drugs covered by insurance plans. But since the government has gone whole-hog into health care under the Affordable Care Act and into drug-price controls under the Inflation Reduction Act, things have gotten crazy at the slop trough. Today, according...

CFPB Crackdown: Unfair Practices Hurting Consumers Bureau is currently investigating various fees associated with obtaining a loan, with the goal of identifying any that may be…
AMCs Billing Scheme, Hidden Profits & Deceptive Practices Appraisers who do not agree to their hidden billing methods are excluded from the majority of the GSE lending marketplace…
Exposing Predatory AMCs Exposing the inner workings of these predatory AMCs and their corrosive influence on the housing market. Cindy Chance's recent comments…

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Exposing Predatory AMCs

AppraisersBlogs — Fri, 14 Jun 2024 12:30:39 +0000

Exposing the inner workings of these predatory AMCs and their corrosive influence on the housing market. Cindy Chance’s recent comments about the concerning practices of some appraisal management companies (AMCs) have struck a chord with many in the real estate valuation industry. Chance is shedding light on the troubling ways in which certain AMCs have come to wield significant power and influence over the appraisal process, often to the detriment of both appraisers and the public. The growth of AMCs in the wake of the 2008 financial crisis was driven by the misguided belief that they could help “ensure the...

CFPB Crackdown: Unfair Practices Hurting Consumers Bureau is currently investigating various fees associated with obtaining a loan, with the goal of identifying any that may be…
AMCs Billing Scheme, Hidden Profits & Deceptive Practices Appraisers who do not agree to their hidden billing methods are excluded from the majority of the GSE lending marketplace…
Uncovering Flaws in FHA Appraisal & Loan Review Process The story of this single mother's harrowing experience with a defective home purchase and HUD's negligent oversight exposes deep flaws…

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CFPB Crackdown: Unfair Practices Hurting Consumers

Guest Author — Wed, 05 Jun 2024 12:30:07 +0000

Bureau is currently investigating various fees associated with obtaining a loan, with the goal of identifying any that may be particularly burdensome or concerning for borrowers. As we all know many AMCs are not paying Customary & Reasonable fee as required by TILA. They have consistently pushed down the pay of Appraisers while making undisclosed profit off consumers and prioritizing cheapest and fastest over quality and competency. The CFPB has been in communication with individuals behind the scenes and are concerned with what has been shown enough to include AMCs in their data collection process. Now is the time to...

AMCs Billing Scheme, Hidden Profits & Deceptive Practices Appraisers who do not agree to their hidden billing methods are excluded from the majority of the GSE lending marketplace…
AMC Fee Impact on Appraisal Fee While the borrower was charged $695 for the appraisal, the appraiser was only paid $301. The AMC fee was $394. …
It’s Time to Take Out the Junk: AMC Practices Exposed Appraisers have spent years carrying the weight of broken AMC practices, and this article pulls every one of those practices…

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Obscure Federal Official Has Hatched ‘Sick Chicken’ in Housing Sector

Jeremy Bagott — Thu, 04 Apr 2024 12:30:58 +0000

The case eventually found its way to the U.S. Supreme Court, where it came to be known to the public as the “Sick Chicken Case” It was the Great Depression’s bleakest year – 1933. At President Roosevelt’s urging, Congress passed the National Industrial Recovery Act, a New Deal bill that partially ceded lawmaking authority to private organizations and industry boards to develop codes of conduct that would then be enforced on citizens as binding law. The owners of poultry producer Schechter Poultry Corp. were indicted for violating the new private business code for the poultry industry. The chicken men lawyered...

Reindeer Standards As Unenforceable As Appraisal Code There’s a lot to like about the bylaws of the Association of World Reindeer Herders. The code defines how herders…
How U.S. Home Valuations Are Being Subverted At the crossroads of it all is a campaign to weaken or eliminate valuations... The nonprofit is now exploring ways…
Confusing Language for USPAP Ethics Rule Addition A proposed update of professional guidelines for property appraisals contains confusing language about what constitutes discrimination, and would even suggest…

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Reality of Today’s Appraisal Environment

Dave Towne — Fri, 27 Oct 2023 12:30:27 +0000

Proving discriminatory activity is hard, which is probably one reason HUD is dragging their collective feet in resolving the filed complaints. The real scourge of what’s been happening to appraisers for the past 5 years (yes, it started prior to the last election) has been revealed by Mr. Isaac Peck, in this article. You really need to read it, perhaps again, if you saw it come through your email on Wednesday October 25. Isaac has allowed me to “re-broadcast” his article. Yes, it’s a ‘sales promotion’ but it contains critical information appraisers need to know about. The first paragraph, contained...

Appraisers Pressured to Inflate Values Based on Race The real estate appraisal industry has long been subject to pressure from various sources, such as lenders, borrowers, and agents.…
HUD's Private Inquisitors Will Chill Protected… HUD awarded $54 million to 182 nonprofits to serve as posses in a a Spanish Inquisition-style drive. The deep pockets…
Racial Bias in Real Estate: Is it the Appraisers’ Fault? In the past year, the appraisal industry has been under attack from various academics who claim “racial bias” on the…

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Dazzled by Wizardry, Federal Mortgage Regulators Ignore Zillow Debacle

Jeremy Bagott — Mon, 12 Jun 2023 12:30:18 +0000

This rulemaking is one more sign that federal bureaucrats are all in on a whacky plan to use technical wizardry to tease out the value of individual properties across the country… Secretary of Defense Robert McNamara was a committed technocrat. Under his direction, a team of policy advisors descended into the Pentagon’s cavernous basement in 1967. They fed punch cards into the basement’s IBM mainframe computers with everything that could be quantified about the Vietnam War. Numbers of ships, tanks, transport helicopters, gunships, fixed-wing aircraft, artillery, troop strength, machine guns, ammo. They queried the computers, “What year will we win...

AVMs... Garbage In, Garbage Out Garbage data in means garbage results out every time! It's no secret that AVMs have been a thorn in the…
AVMs... The Not So Accurate Magic Bullet That article mentioned three on-line services which claim to provide accurate property values. In alphabetical order, those services were REDFIN,…
How Deep Fakes Have Burrowed Into Home Finance Fannie and Freddie have been toiling at the coalface of “synthetic appraisals” – “black box valuations.” In the 1960s, technocrats…

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Sale Price vs Appraised Value Disconnect

Dave Towne — Mon, 10 Apr 2023 12:30:15 +0000

How can it be said that valuing a property lower than its eventual sale price based on current market evidence is tantamount to BIAS? The article titled “FHFA Data Fueling Looks into Appraisal Bias” was in the Inside Mortgage Finance Publications e-newsletter on 4/06/23. The Federal Housing Finance Agency is a is a critical provider of the data necessary for oversight, enforcement and research, FHFA Director Sandra Thompson noted during a discussion in late March. According to aggregate statistics from the Uniform Appraisal Dataset released by the FHFA, roughly 57% of appraisals were above the contract price in 2021. Just...

A Low Appraisal is Now a Bad Appraisal A low appraisal is now a bad appraisal. Well, that's according to the headline. The article does not stress ‘bad.’…
Is the GSE's "Appraisal Modernization" Really Just… Mass Appraisal tend to exhibit a regressive nature... In the intricate landscape of real estate mortgage financing, the notion of…
The New & Improved Fannie Mae “FRAUDULATOR 2.0” Originally known as Fannie Mae’s Collateral Underwriter (CU), and subsequently Collateral Underwriter 2.0 (CU-2)i this always dubious product of Fannie…

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Consumer Financial Protection Bureau - Appraisers Blogs

Appraiser Independence: What Does it Mean & Who Does it Apply to

Related Posts:

The AMCs: Coming Soon to a Lawsuit Near You

Related Posts:

Fannie Mae’s Conservatorship: A Babysitter’s Blunder

Related Posts:

A Cry from the Appraisal Trenches: The Fall of GSE Oversight

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AMCs Deceptive Fee Skimming Exposed in Lawsuit

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The Shadowy AMC Fees Draining Billions from Homebuyers

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Appraisal Industry Outlook Under Trump Administration

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The Great Debate on Appraisal Fees

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Appraisal Regulation Compliance Council Exposes Disturbing AMC Violations

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County Assessors’ Standards | AVM Final Rule Guidance

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Insights from CFPB’s Public Comment Period

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Lack of Fee Transparency: Exposing the AMC Exploitation

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Uncovering Flaws in FHA Appraisal & Loan Review Process

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Gov’t-Indulged Middlemen Are Wrong RX for Battered Borrowers, The Infirm

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Exposing Predatory AMCs

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CFPB Crackdown: Unfair Practices Hurting Consumers

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Obscure Federal Official Has Hatched ‘Sick Chicken’ in Housing Sector

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Reality of Today’s Appraisal Environment

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Dazzled by Wizardry, Federal Mortgage Regulators Ignore Zillow Debacle

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Sale Price vs Appraised Value Disconnect

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