Dodd Frank - Appraisers Blogs

Systemic Failures in FHA Appraisal and Loan Review

Desiree Mehbod — Mon, 18 May 2026 12:30:44 +0000

This case exposed the cracks in an FHA system where failures by the lender, the AMC, and the review process aligned in ways that no borrower could have anticipated. It shows how easily an appraisal error can escalate when every safeguard designed to prevent harm breaks down at the same time. When the first article about this case ran on July 15, 2024, it already raised serious concerns about how an FHA appraisal could miss something as basic as the type of water and sewer service. What has emerged since then paints a much larger picture, one that shows how...

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The New Con: Hybrids, Waivers & AMCs Threaten Public Trust

VaCAP Board — Mon, 16 Dec 2024 13:30:39 +0000

Hybrid Appraisals, Appraisal Waivers and Appraisal Management Companies are the new Con. Last month marked the 7-year anniversary of Appraiser Fest. The conference was truly like nothing that had been done before. It was organized by appraisers for appraisers. The agenda was more about bringing the profession together and protecting the public trust. Appraiser Fest was not about promoting the profit of others at the expense of appraisers; nor was it about hiding the unchecked facts of fraud and ill doings against consumers. It was about public awareness and trust. It all started with a renewed sense of energy with...

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Recap of the 4th ASC Appraisal Bias Hearing

AppraisersBlogs — Wed, 28 Feb 2024 13:30:47 +0000

On February 13th, 2024, the fourth ASC appraisal bias hearing took place. For those who were unable to attend, the video of the hearing has been included below. The hearing was a crucial event for the appraisal industry, and it is important for all appraisers to be aware of the discussions and topics addressed. The panel of witnesses included: David Bunton, President, The Appraisal Foundation E.C. Neelly IV, Executive Director, Mississippi Real Estate Appraisal Board Maureen Sweeney, Principal, Maureen Sweeney, Real Estate Appraiser Ltd. Melissa Tran, Director, Texas Appraiser Licensing and Certification Board Jillian White, Chief Executive Officer, Appraisal Insights...

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What Is My Incentive?

Michael Ford — Tue, 20 Sep 2022 12:30:38 +0000

Why would I bother taking on the added risk of an inconvenient process? Where is my incentive again? As an appraiser, I have to ask (seriously) why should I care if the profession has a shortage of skilled appraisers? Logic dictates that If there is a shortage, then I will remain busy. Even if waivers (another ruse to eliminate appraisal work) increase, I’ll be busier with fewer appraisers. Especially with so many of them “trained” under PAVE or PAREA programs. If there is an adequate supply of appraisers, then users of appraisals will continue to seek cheaper alternatives from them...

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Proposed Rule to Eliminate C&R Fee Tabled

Mark Skapinetz — Thu, 21 Jul 2022 12:30:33 +0000

Yesterday morning, I attended the Georgia state appraisal board hearing on the proposed rule to eliminate the C&R fee law they have in place. You know, the one that is similar to the one in Dodd-Frank. The Georgia appraisal board apparently is being investigated by the FTC for their law. They thought that the FTC vs the Louisiana case was a ruling in favor of the FTC when in fact it was not, and wanted to avoid any sort of notion that they were price fixing or of anti trust. The board received letters from appraisers and others in the...

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Violating Appraisal Independence Through Harassment, Intimidation & Coercion

Dave Towne — Wed, 15 Jun 2022 12:30:59 +0000

It shall be unlawful… to engage in any act or practice that violates appraisal independence… Appraisers, I have written the info below, which you may use if you desire to send to your clients and local real estate offices. It’s time for all appraisers to stand up to this kind of very adverse behavior, done by and promoted by many real estate brokers/agents across the US. I have been chastised multiple times by brokers, and in one instance that I know of, was excluded (by the lender who told me) from doing another assignment when I didn’t appraise a prior...

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Is Georgia Going Rogue?

VaCAP Board — Mon, 13 Jun 2022 12:30:27 +0000

VaCAP has learned the Georgia Real Estate Appraisal Board is considering rescinding rule 539-1-.23. This rule is the customary and reasonable fee requirement to appraisers from appraisal management companies. The matter will be decided at a 9:30 AM Sunday July 17, 2022 meeting. From the Georgia Real Estate Commission and Appraisal Board: RULE 539-1-.23 Appraisal Management Companies Purpose: In light of the recent decision and order In the Matter of Louisiana Real Estate Appraisers Board Before the Federal Trade Commission of the United States and to avoid even the appearance of anticompetitive conduct or the unreasonable restraint of price competition...

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Federal Agency in Charge of Appraisers

Guest Author — Mon, 23 May 2022 12:30:12 +0000

Having a federal agency in charge of appraisers will be a NIGHTMARE. Leave it to the states as it is now. ALL appraisers should be SWAMPING their state representatives with calls & emails in OPPOSITION to newly introduced H.R. Bill entitled: Fair Appraisal and Inequity Reform Act of 2022. DO IT NOW. **Remind them all that the job of a Professional Real Estate Appraiser is to PROTECT THE PUBLIC TRUST. That’s what we are in place for! With all of the ridiculous changes proposed with “PAREA”, we know exactly where this is headed. Appraisers coming out of their “PAREA” certification...

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How to Destroy the Appraisal Profession

Mark Skapinetz — Mon, 16 May 2022 12:30:42 +0000

Anytime the government gets involved in an issue, it tends to have more adverse effects than positive ones. It makes things worse when they only have their plan in mind and NOT the FACTS from the people they are about to hurt. This is especially true in the Real Estate Appraisal profession and the newly introduced H.R. Bill entitled: Fair Appraisal and Inequity Reform Act of 2022. It’s essential to bring some information that not one person in the government or the people they are getting information from is talking about. First let’s step into my time machine and go...

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Dear ASC: Details… Why They Matter

Mark Skapinetz — Fri, 25 Mar 2022 12:30:09 +0000

DETAILS… NO MATTER HOW SMALL OR BIG NEED TO BE PRESENTED. If not, you failed. ASC, today you failed us all. Over the past several days, the Real Estate Appraisal Industry has been the subject of scrutiny with the release of the PAVE Report that the Interagency Task Force developed on Property Appraisal And Valuation Equity set forth by the Biden Administration. On March 23, 2022, there was a public meeting to unveil the Pave Task Force report on Racial Bias in the Real Estate Appraisal Profession. You can watch the press conference below as well as read the entire...

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Bias in Automated Valuation Models

VaCAP Board — Mon, 28 Feb 2022 13:30:35 +0000

The CFPB is reviewing bias in Automated Valuation Models (AVMs). The proposed rules are a joint effort by the Consumer Financial Protection Bureau, the Office of the Controller of the Currency, the Federal Deposit Insurance Corporation, the National Credit Union Administration and the Federal Housing Finance Agency. These agencies are concerned AVMs may reflect bias in design and function. The mathematical models rely on biased data resulting in inaccurate valuations. Basically the agencies are stating historical data going back to redlining is built into these models and do not reflect current market data. Remember markets are not static and are...

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Desktop Appraisals: Has The Devil Infiltrated The Public Trust?

Mark Skapinetz — Thu, 10 Feb 2022 13:30:41 +0000

Are desktop appraisals with third-party inspectors protecting the public, or are these products about to destroy the very profession I love so much. The Uniform Standards Professional of Appraisal Practice (USPAP) are the key to maintaining public trust in real estate transactions. USPAP is pretty much the equivalent to the Bible, but it MUST be followed for appraisers. Created by the Appraisal Foundation, USPAP set forth the guidelines for how appraisers should perform their work. By following these standards, appraisers ensure that they act in a professional and unbiased manner. To expand, even more, USPAP states, “While USPAP does not...

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A New ‘Standard’ for ROV Requests

Dave Towne — Tue, 21 Dec 2021 13:30:55 +0000

Since beginning using this Standard, I have had ZERO ROV requests. Appraisers, the latest ‘buzzword’ around appraising is Standard. We’ve got to have a Standard for measuring a subject dwelling, even though the comparable GLA reported figure may have been measured far differently from the new soon-to-be mandated Standard. Appraisers have no way of controlling the apples to oranges dissimilarities. But I digress… According to the Dodd-Frank law, and the HVCC before it, clients are allowed to challenge the appraiser’s value opinion by submitting what is termed in the law “appropriate” sales to be further reviewed, with the expectation that...

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DEAR HUD… What’s Your End Game?

Mark Skapinetz — Tue, 07 Sep 2021 12:30:25 +0000

Dear HUD, recently, within the past year or so, you have been on a crusade to prove discrimination and racism in the appraisal process. Your actions haven’t gone unnoticed by many within the appraisal profession as well as outside it. It’s become clear that you are the go to organization for complaints. Ok. Please read this in its entirety and see my thoughts at the end before making a judgement. The reason I am writing you this letter is for a couple of reasons. First and foremost, I am writing this letter to ask you what your TRUE intentions are...

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Waiting for the Platform to Fall…

Guest Author — Wed, 21 Jul 2021 12:30:24 +0000

…waiting for the platform to fall… because you know they hired the fastest and cheapest guy to build it! When Dodd Frank was implemented lenders started using appraisal management companies, eliminating appraisers relationships basically overnight. Appraisers embraced the change reluctantly and started accepting assignments from appraisal management companies. Over the years appraisal management companies showed their true colors and lowered fees, required appraisers to pay upload fees and forced many appraisers to pay for unnecessary back ground checks. Some have hired staff appraisers, completely disregarding the intent of Dodd Frank in an attempt to lower operating costs. Today, most AMC’s...

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FTC Has Cost the Appraisal Profession Dearly

VaCAP Board — Mon, 19 Jul 2021 12:30:10 +0000

The FTC has cost the appraisal profession dearly in their pursuit of the State of Louisiana. This entire episode has been entirely misguided… The FTC’s time SHOULD have been spent investigating the AMC trade group known as REVAA to find TRULY non-competitive practices… The FTC is asking for public comments on the consent decree by the Louisiana Real Estate Appraisal Board. The time line to comment is short and ends on July 22, 2021. VaCAP asks each of you to take a few minutes and read the consent decree as well as the analysis provided by the FTC before commenting....

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Relationships… The Lost Art

Mark Skapinetz — Thu, 15 Jul 2021 12:30:51 +0000

Relationships. It’s a lost art of business when it comes to the appraiser profession… I have been an appraiser since 2003, when I started my career path. Since then, the appraiser profession has gone through many changes, none more impactful than creating the Home Valuation Code of Conduct or HVCC law that was put into effect after the crash. HVCC created the new normal for the profession where Appraisal Management Companies (AMCs) were installed as the firewall or third party between the appraiser and the lender. Overnight on May 1st, 2009, appraisers all over the country lost every relationship they...

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Open Letter to Mortgage Lenders

Guest Author — Wed, 27 Jan 2021 13:30:47 +0000

How much vetting have you done on the appraisal management company? How involved are you as the lender in the day to day activities of the appraisal management company?… The world has changed and most everything in our lives involves technology. The technologies available to each of us are tools. They are not a more reliable means, merely more convenient. Human thought and analysis is still required in every aspect of life. When the Final Rules of the Dodd Frank Legislation went into effect, many lenders chose to use appraisal management companies with the false idea they had no liability for...

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The Biggest Snow Job of Your Life

Guest Author — Thu, 15 Oct 2020 12:30:00 +0000

Remember the saying “Pick two: fast, cheap or good. You can only have two of them?” Well you see, amcs got impatient and stopped reading after fast and cheap… The concept is simple enough, a fire wall between the loan production staff and the appraiser to avoid any possible pressure, coercion or influence. It sounded like a good idea to many; hence the HVCC legislation passed and was enacted. This was a period of trial and error for so many and before anyone found their way, along came Mr. Dodd and Mr. Frank to give their official stamp of approval...

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Biden Claims on Racial Bias in Appraisals

VaCAP Board — Fri, 06 Mar 2020 13:30:59 +0000

Over the past week or so, Presidential Candidate Joe Biden publicly called for more regulation and oversight over appraisers to combat racial bias. He specifically cited the Brookings Institute Study ”The Devaluation of Assets in Black Neighborhoods, The Case of Residential Property”. If you are unfamiliar with this study, in a nutshell, the findings accuse appraisers of undervaluing properties in black neighborhoods. The study is an easy read and can be found here. We will warn you, much of the data used in the study carries very little weight as Census Bureau (self-reported data) and information from Zillow were used....

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