E&O - Appraisers Blogs

Surviving UAD 3.6: Secondary Market Risk Protocols

Desiree Mehbod — Mon, 19 Oct 2026 12:30:31 +0000

If economic necessity forces you to accept UAD 3.6 assignments, you cannot afford to sign blindly while exposed to massive secondary market liability risks. The reality on the ground for independent real estate appraisers is unforgiving. While the industry debates the long term dangers of data harvesting, many independent business owners face an immediate, binary choice: sign the new UAD 3.6 reports and accept Certification 25, or stop feeding your family. Not every appraiser has a robust book of private estate, divorce, and non lending work. Transitioning away from AMCs takes time, marketing skills, and capital that many simply do...

The MLS Interior Photo Blackout & UAD 3.6 The rollout of UAD 3.6 creates a massive data clash, leaving us completely unable to verify comparable sales just as…
UAD 3.6 Erases My Legal Defenses: Insurance Industry Agrees The insurance industry just verified the erasure of my legal defenses under UAD 3.6. The corporate apologists and tech insiders…
UAD 3.6 and the Danger of Corporate Pragmatism The rollout of the new UAD 3.6 framework has triggered a major wave of compliance literature, and a perfect example…

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UAD 3.6 and the Danger of Corporate Pragmatism

Desiree Mehbod — Wed, 14 Oct 2026 12:30:30 +0000

The rollout of the new UAD 3.6 framework has triggered a major wave of compliance literature, and a perfect example is a recent article by Woody Fincham at Valuation Nation, titled “Certification 25: What’s the Real Risk to the Appraiser?”. In his piece, Woody sets aside the rhetoric and lists my AppraisersBlogs article regarding our legal defenses under this dataset as a citation reference at the end of his post. While he acknowledges the existence of this perspective, his broader argument claims that the legal risks of signing Certification 25 are low, the threat of regulatory discipline is minimal, and...

Our Metrics, Their Millions: Exposing the Backdoor Data Rush If you still think the corporate panic over structural data is just a theoretical debate about software licensing, a tech…
UAD 3.6 Erases My Legal Defenses: Insurance Industry Agrees The insurance industry just verified the erasure of my legal defenses under UAD 3.6. The corporate apologists and tech insiders…
Inspectors Blocked the Door, Appraisers Handed Over the Keys A fellow appraiser dropped a direct message in my inbox with a link to home inspector Preston Kincaid's Facebook video,…

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Inspectors Blocked the Door, Appraisers Handed Over the Keys

Desiree Mehbod — Mon, 12 Oct 2026 12:30:11 +0000

A fellow appraiser dropped a direct message in my inbox with a link to home inspector Preston Kincaid’s Facebook video, and watching him warn the public sent a chill through me because his words mirrored the exact warnings I have been shouting about our own appraisal profession. To understand the shock, you first need to know what Spectora is and how home inspectors work. Spectora is the dominant cloud software platform used by roughly 7,000 independent home inspectors across the country to draft, format, and deliver digital property inspection reports. By law and standard contract, home inspectors operate under strict...

UAD 3.6 Erases My Legal Defenses: Insurance Industry Agrees The insurance industry just verified the erasure of my legal defenses under UAD 3.6. The corporate apologists and tech insiders…
Cert 25 Dilemma: TAF Abdicates Its Role as Ethics Arbiter We finally have a direct written response from The Appraisal Foundation regarding the Cert 25 confidentiality crisis and it is…
Certification 25 and the Quiet Breach of Appraiser… Certification 25 made me realize that my refusal to participate in UAD 3.6 was justified long before I even knew…

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UAD 3.6 Erases My Legal Defenses: Insurance Industry Agrees

Desiree Mehbod — Thu, 08 Oct 2026 12:30:15 +0000

The insurance industry just verified the erasure of my legal defenses under UAD 3.6. The corporate apologists and tech insiders have spent weeks trying to downplay the Certification 25 confidentiality crisis. They’ve lined up to tell independent appraisers that the new language is just a passive weather report, a routine disclosure, or an innocent acknowledgement of a reality that has existed for many years. But the ultimate reality check just arrived from the very people who calculate risk for a living, and it completely blows the corporate defense strategy out of the water. Isaac Peck, Publisher of Working RE Magazine...

Who Controls Access in UAD 3.6 Access has become the most expensive word in the appraisal industry, a reminder that every new “solution” seems to cost…
Certification 25 and the Quiet Breach of Appraiser… Certification 25 made me realize that my refusal to participate in UAD 3.6 was justified long before I even knew…
Cert 25 Dilemma: TAF Abdicates Its Role as Ethics Arbiter We finally have a direct written response from The Appraisal Foundation regarding the Cert 25 confidentiality crisis and it is…

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FOIA, AI, & the Appraiser’s Defense: A Blueprint for Fighting Back

AppraisersBlogs — Fri, 13 Jun 2025 12:30:12 +0000

Targeted under the guise of equity, I faced baseless accusations with no due process — until I used FOIA, uncovered the truth, and turned the tables. But I had a secret weapon: I used artificial intelligence. For decades, appraisers have worked in silence, held hostage by regulations, scrutiny, and — recently — false narratives of systemic racism. When the Biden administration launched the PAVE Initiative, it claimed to champion equity in housing. But behind the curtain, it became a political tool. The result? Appraisers like me were targeted based on ZIP codes, stripped of due process, and labeled racist —...

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…
The Town With No Bank: How Rural America Lost Its… For decades, we’ve been told that the problem is demand. That people don’t want to live in rural America anymore.…
How Bureaucratic Overreach Turned Real Estate… This is what bureaucratic overreach looks like: a maze of rules with no exit, a hearing held while you're hospitalized,…

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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....

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…
The Appraisal Problem Gone are the days of hiring a professional appraiser to solve the appraisal problem. For decades lenders have taken on…
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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Shane Lanham Countersuing Black Homeowners for Defamation

AppraisersBlogs — Thu, 08 Feb 2024 13:30:29 +0000

Shane Lanham, a Maryland appraiser, has found himself in a difficult situation as he is being sued in The United States District Court of Maryland. However, he is not backing down and fully intends to fight these allegations through trial. In addition, he is countersuing the accusers for defamation and seeking $500,000 in damages. Lanham firmly believes that the accusations of racism against him are baseless and he has engaged a consultant with significant experience in handling such cases. To ensure he has the best chance of success, Mr. Lanham has engaged a consultant with extensive experience in similar cases....

Seller Filed a Racial Bias Complaint Against Me So what’s caused the sudden loss of income? Could it be because of the racial bias complaint filed against me…
False Claims of Racism Against Appraiser ...my career, business, and health at risk due to false claims made by a homeowner. As a professional real estate…
Appraiser Countersuing Black Homeowners for Defamation The Maryland appraiser has filed a countersuit against the homeowners, claiming defamation. Appraisers, there have been several lawsuits filed against…

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Fannie Mae Filed a Complaint Against Me

AppraisersBlogs — Wed, 18 Oct 2023 12:30:39 +0000

An appraiser shared the following with us which was posted on one of the appraisers’ groups. Fannie Mae filed a complaint against me with my state appraisal board. Here’s what happened. The Report In June of 2021, I completed an appraisal for a conventional purchase. The appraisal was ordered by an AMC on behalf of a lender. At that time, the real estate market was still being wildly affected by the COVID pandemic. Remote work was in full swing, and consumers were desperately seeking to get out of the cities. Prices for all types of residential properties were rising rapidly,...

Fannie's Loan Buyback Sophistry Relies on Modifying… “Many of the repurchase letters make no sense,” said the insider. If analysts don’t write enough defects on those files,…
FNMA Continued Effort to Get Rid of Appraisers Fannie Mae Continues Their Effort To Get Rid Of Appraisers: Sends “Tips” For the past year, Fannie Mae has sent…
USPAP’s Typical Buyer Standard in the Fair Housing Era The Irreconcilable Conflict Between USPAP's Typical Buyer Standard and the Current Fair Housing Compliance Regime. Retain this document as a…

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PAREA Program & Its Negative Impact on Diversity

Guest Author — Thu, 03 Aug 2023 12:30:04 +0000

The study also found that the PAREA program is not as effective in providing a more accessible pathway to licensure as the traditional apprenticeship model. Practical Applications of Real Estate Appraisal (PAREA) is a program that aims to revolutionize the real estate industry by increasing the number of appraisers. However, after listening to the Appraisal Institute speaker at yesterdays board meeting it quickly became evident that this initiative is a complete failure. You cannot start PAREA until you have received all your real estate appraisal education. 94 hours = $1,700 per McKissock Appraisal Institute speaker said that most AMC’s/banks won’t...

The PAREA Program: Costly Promises, Empty Support The PAREA program markets itself as a shiny, mentor-free express lane to becoming a real estate appraiser, but its steep…
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…
Federal Agency in Charge of Appraisers Having a federal agency in charge of appraisers will be a NIGHTMARE. Leave it to the states as it is…

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The New & Improved Fannie Mae “FRAUDULATOR 2.0”

Michael Ford — Mon, 15 May 2023 12:30:53 +0000

Originally known as Fannie Mae’s Collateral Underwriter (CU), and subsequently Collateral Underwriter 2.0 (CU-2)i this always dubious product of Fannie Mae is increasingly being referred to by some, if not many American Appraisers as The Fraudulator / Underwriter 2.0 (FU-2). To be clear it is not limited to the Collateral Underwriter (CU & CU-2) software. The new Fraudulator (FU-2) combines the CU products with their numerous improper uses. The end result of which includes OUTRIGHT FRAUD being perpetrated against banks via the repurchase letters Fannie Mae now issues on a quota based system rather than because of legitimate appraisal defects....

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…
Dear Representative, FNMA Has Gone Rogue! Dear representative, waiving/eliminating property appraisal for lending purposes is wanton recklessness. Fannie Mae’s decision to waive/eliminate property appraisal for lending…
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…

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Lender Liability for a Negligent Appraisal?

Peter Christensen — Wed, 26 Oct 2022 12:30:36 +0000

Does a mortgage lender have liability to the borrower for a negligent appraisal? As residential property prices plateau or decline in various markets and as borrowers have financial problems with fewer financing options, there are more legal claims being filed by borrowers against appraisers and lenders in relation to appraisals for loans made in recent years. Essentially, the cases are situations of “buyer-borrower remorse.” Leaving aside the appraiser’s potential liability, does a mortgage lender have liability to the borrower for a negligent appraisal? An Ohio appellate court recently said “no.” It ruled that the lender did not owe the borrower...

New Suspicious Law in CA ...any suspicion of a discriminatory appraisal by the holder of a real estate appraiser license... Folks in the Golden State,…
AMC Liability for Deficient Appraisals ...may AMCs be liable for the deficient work of contractor appraisers? Can AMCs be sued for negligence? Can they be…
FNMA Ensnares Appraisers in Farcical Probes You feel like Fannie Mae is simply trying to get rid of appraisers. A lot of appraisers feel that way...…

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Protect Yourself Against Racial Bias Claims

AppraisersBlogs — Thu, 23 Jun 2022 12:00:47 +0000

Free webinar on how to protect yourself against discrimination claims on 6/30/22, and today there will be a forum on “Racial Bias in the Home Appraisal Process”… OREP is sponsoring a free webinar on how to protect yourself and your business against discrimination claims. Leading trial attorney Craig Capilla has handled nearly 1,000 appraiser cases in his career and has been on the frontlines defending appraisers from lawsuits, state board complaints, and now, HUD Fair Housing (Discrimination) complaints. Capilla began his legal career working for Illinois’ professional regulation agency as a real estate prosecutor and since then has become one...

Stoked by HUD, Cottage Industry Shakes Down… The harassment campaign benefits a number of odd bedfellows: the housing lobby, which wants unfettered access to federal funds and…
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…
The Town With No Bank: How Rural America Lost Its… For decades, we’ve been told that the problem is demand. That people don’t want to live in rural America anymore.…

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States Want Appraisers to Play Ball

Jeremy Bagott — Fri, 10 Dec 2021 13:30:47 +0000

“[The builder] filed a grievance against me… and threatened to file a grievance every time I or others appraised below purchase price.” California and Nebraska couldn’t be more different, but both clearly want their states to be more like the fictional town of Lake Wobegon – a place where all the men are good-looking, all the children are above average and all properties appraise at or above their sale price. Parts of California Assembly Bill 948, which was signed into law in September, read like something from the satirical news site The Onion. The statute requires the state’s appraiser enforcement...

Frivolous Complaints Against Appraisers TALCB noted that roughly 70% of all complaints against appraisers are unfounded... The American Guild of Appraiser recently wrote to…
Phony Complaint Against Appraiser ...a laundry list of 'pile on' purported USPAP "violations" were fabricated deriving for the above oversights ‘confirmed’ by the out…
Phony Low-Value Complaints ALL unintended users are specifically excluded from any right of reliance on this appraisal report... Recently, Mr. Steve Kahane, Board…

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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...

Promoting False "Racist Appraiser" Narrative Some Lenders promoting false "racist appraiser" narrative to optimize profits via AVMs Like most businesses lenders want to optimize their…
The Town With No Bank: How Rural America Lost Its… For decades, we’ve been told that the problem is demand. That people don’t want to live in rural America anymore.…
How to Destroy the Appraisal Profession Anytime the government gets involved in an issue, it tends to have more adverse effects than positive ones. It makes…

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Listening to Appraisers

David Brauner — Fri, 31 Jan 2020 13:30:07 +0000

…appraisers believe that the bifurcated model and the use of unlicensed, untrained and unaccountable contractors for key elements of collateral assessment will adversely affect the health and welfare of the housing finance system, increase their own liability and damage the public trust… It is the goal of the Federal Financing Housing Agency (FHFA) to ensure the health and welfare of the housing finance system. FHFA oversees Fannie Mae and Freddie Mac and has, for the time being, paused the testing and development of bifurcated appraisals that bypass the participation of licensed appraisers (FHFA Puts Brakes on Fannie’s Bifurcated Program). I...

GSE Pilot Programs Dead The Only Good Pilot Is A Dead Pilot? Like my father always told me about having a business partner (see…
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…
Dear Representative, FNMA Has Gone Rogue! Dear representative, waiving/eliminating property appraisal for lending purposes is wanton recklessness. Fannie Mae’s decision to waive/eliminate property appraisal for lending…

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California AB 5 – Legal For Appraisers

Peter Christensen — Wed, 15 Jan 2020 13:30:44 +0000

More than 375 California appraisers registered for the AB 5 webinar – I hope you didn’t miss it. I’ll be hosting my next free webinar for appraisers on January 31, 2020 – it’s the “California Legal Update just for Appraisers!” In this free video webinar, I’ll cover: New 2020 laws relevant to California appraisers and appraisal firms (other than AB 5), including the California Consumer Privacy Act, and The very most important thing that appraisers can do in 2020 in every appraisal report of every type (whether residential, commercial, lending or non-lending) to avoid liability. The webinar will last approximately 45...

CA Appraisers 50% Decline & Fees Up 76% The Number of CA appraisers drops from 20,120 to 9,987. Renewal fees up 76% for 2020. Excerpt: It’s time to…
AB5 - Employee or Independent Contractor? Most independent appraisers are paid ‘by the job’ and are issued 1099’s for the payments made. Appraisers who are ‘staff appraisers’…
Case Helpful to Appraisers This is the only way that the opinion would ever help other appraisers, especially residential, in future cases filed by…

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Fee Transparency, Pivotal Point for Appraisers

Isaac Peck — Wed, 23 Oct 2019 12:30:10 +0000

…appraisers may finally have a chance at making the goal of fee transparency a reality… Keep your eyes open, events are happening fast. Ever since the passage of the Home Valuation Code of Conduct (HVCC) in 2010 and the monumental rise of Appraisal Management Companies (AMCs), one of the main issues appraisers have pressed for is transparency for consumers in terms of the fee split between appraisers and AMCs. Specifically, how much of the actual “Appraisal Fee” being paid by the consumer goes to the licensed real estate professional and how much is withheld by the AMC “manager.” Now, over...

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…
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…
The Town With No Bank: How Rural America Lost Its… For decades, we’ve been told that the problem is demand. That people don’t want to live in rural America anymore.…

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Appraisers, did you Shoot yourself in the Foot?

Richard Hagar, SRA — Mon, 30 Sep 2019 12:30:23 +0000

When I explain the rules many of the appraisers start complaining: “An MLS photograph depicts the house at the time it sold so it’s more accurate than my photograph would be”… There’s a lot of yelling and screaming about bifurcated appraisals. Unfortunately, appraisers may have shot themselves in the foot when it comes to this issue. Allow me to provide an analogy to help explain the issue. I’m not sure if this happens in other areas of the country but in Seattle there is a strange “left leaning” way they do things: State and Federal governments perform numerous traffic studies, to...

The Real Cause of the Home Value Gap Is the Income Gap Blaming appraisers for the income gap will never solve the real underlying problem... Blaming appraisers for the income gap is…
Dear ASC: Details... Why They Matter DETAILS... NO MATTER HOW SMALL OR BIG NEED TO BE PRESENTED. If not, you failed. ASC, today you failed us…
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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ACI Software Users

John Pratt — Tue, 20 Aug 2019 12:30:53 +0000

I just received a message from another appraiser that I believe uses ACI software. He received a request from ACI to sign a “Digital Signature Application” along with a few other forms. This appears to me to be in connection with a new form of an appraisal product which they have developed. The first paragraph of this “Digital Signature Application” read as follows 1.1 Signature Using BLACK INK, sign within the box below. Signature must remain within the confines of the box (see sample). All signature cards are destroyed after they are scanned, tested, and delivered. Passwords are not kept...

USPAP’s Typical Buyer Standard in the Fair Housing Era The Irreconcilable Conflict Between USPAP's Typical Buyer Standard and the Current Fair Housing Compliance Regime. Retain this document as a…
Who Controls Access in UAD 3.6 Access has become the most expensive word in the appraisal industry, a reminder that every new “solution” seems to cost…
Promoting False "Racist Appraiser" Narrative Some Lenders promoting false "racist appraiser" narrative to optimize profits via AVMs Like most businesses lenders want to optimize their…

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Phony Complaint Against Appraiser

Michael Ford — Mon, 08 Jul 2019 12:30:22 +0000

…a laundry list of ‘pile on’ purported USPAP “violations” were fabricated deriving for the above oversights ‘confirmed’ by the out of area review appraiser… In fighting or appealing a false complaint filed against you as an appraiser, truth, factual evidence and professional competency is no longer enough! More important than all these things, is conformity to the detailed technical rules of a state’s administrative law procedures. In short, in many if not most cases, appraisers MUST HIRE AN ATTORNEY to represent them before any administrative board. Anything less, is playing with fire and your professional career. Worse, E&O won’t cover...

Phony Low-Value Complaints ALL unintended users are specifically excluded from any right of reliance on this appraisal report... Recently, Mr. Steve Kahane, Board…
Advance Property Research is Vital ‘Subject to’ obtaining a correct legal description... Appraisers, an unusual situation occurred with an appraiser buddy, who asked for advice.…
Frivolous Complaints Against Appraisers TALCB noted that roughly 70% of all complaints against appraisers are unfounded... The American Guild of Appraiser recently wrote to…

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E&O - Appraisers Blogs

Surviving UAD 3.6: Secondary Market Risk Protocols

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UAD 3.6 and the Danger of Corporate Pragmatism

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Inspectors Blocked the Door, Appraisers Handed Over the Keys

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UAD 3.6 Erases My Legal Defenses: Insurance Industry Agrees

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FOIA, AI, & the Appraiser’s Defense: A Blueprint for Fighting Back

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Uncovering Flaws in FHA Appraisal & Loan Review Process

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Shane Lanham Countersuing Black Homeowners for Defamation

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Fannie Mae Filed a Complaint Against Me

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PAREA Program & Its Negative Impact on Diversity

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The New & Improved Fannie Mae “FRAUDULATOR 2.0”

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Lender Liability for a Negligent Appraisal?

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Protect Yourself Against Racial Bias Claims

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States Want Appraisers to Play Ball

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Open Letter to Mortgage Lenders

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Listening to Appraisers

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California AB 5 – Legal For Appraisers

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Fee Transparency, Pivotal Point for Appraisers

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Appraisers, did you Shoot yourself in the Foot?

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ACI Software Users

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Phony Complaint Against Appraiser

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