FIRREA - 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...

Expert Wants to “Eliminate” Appraisers Mortgage Industry Expert Wants to “Eliminate” Appraisers – A Response The National Mortgage News website just published an interview with…
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…

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It’s Time to Take Out the Junk: AMC Practices Exposed

Logan Dorman — Fri, 21 Aug 2026 12:30:23 +0000

Appraisers have spent years carrying the weight of broken AMC practices, and this article pulls every one of those practices into the sunlight so the profession can finally take out the junk. “Evil AMCs thrive not only through active malice, but also through the silence and inaction of those appraisers who could intervene.” — Edmund Burke… if he had been an appraiser It’s a conversation we’ve all had before: “I’ve already got all my information entered. I’m used to the system. I don’t want to learn a new process. I guess I’ll just keep paying the extra couple of dollars...

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,…
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…
First the Borrower Fee. Now the Appraiser… Two lawsuits place Class Valuation’s fee transparency and staff-appraiser compensation practices under federal scrutiny. Most appraisal disputes examine only one…

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USPAP’s Typical Buyer Standard in the Fair Housing Era

Guest Author — Fri, 29 May 2026 12:30:07 +0000

The Irreconcilable Conflict Between USPAP’s Typical Buyer Standard and the Current Fair Housing Compliance Regime. Retain this document as a reference should you face a complaint grounded in disparate impact theory alone. The three-safeguard framework from Inclusive Communities provides a robust defense for any appraiser whose methodology is USPAP-compliant, well-documented, and market-supported. Introduction I want to state plainly what the appraisal profession has been tiptoeing around since roughly 2019: an appraiser cannot simultaneously comply with: 1- USPAP’s requirement to identify and analyze the most probable (typical) buyer of a property via market data AND… 2- comply with the current iteration...

Appraisers Freed from DEI Propaganda This bold move immediately resulted in the removal of all appraisal bias propaganda from the official whitehouse.gov website. With a…
Biased Appraisers? I Don't Think So To judge an entire profession by anecdotal evidence is equally both stupid and harmful... The entire emphasis was on "anecdotal…
Disparate Treatment and Impact in USPAP USPAP has introduced the terms DISPARATE TREATMENT AND IMPACT in its 5th exposure draft. Disparate treatment and impact are bad…

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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...

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…
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…
HUD Investigation Leads to Illegal Break-In &… Over the past four years, I have been subjected to a relentless, unjust investigation by the U.S. Department of Housing…

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Lack of Evidence, Appraiser Challenges Discrimination Claims

AppraisersBlogs — Thu, 24 Oct 2024 12:30:29 +0000

The next morning I went to my trusted AI program and asked if there was any evidence of bias. “Where is the evidence?” The issue of perceived bias and discrimination in the appraisal industry has become a highly contentious and polarizing topic in recent years, sparking intense debate and controversy. At the heart of this complex issue lies a fundamental tension between the appraisal profession’s commitment to objectivity and impartiality, and the persistent allegations of systemic racism and unfair practices that have plagued the industry. As exemplified in the response from Maryland Certified General Appraiser William Turner to an article...

NFHA's False Narrative Undermines the Appraisal Industry A barrage of billboards, magazine ads, and TV/radio public service announcements is being used to amplify and spread this false…
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…
Misleading Ads Sow Mistrust These misleading ads are sowing seeds of mistrust in a time-tested profession. The National Fair Housing Alliance (NFHA) has recently…

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The One-Mile Rule: Prudent Policy or Modern Day Redlining?

Dallas T. Kiedrowski, MNAA — Thu, 18 Apr 2024 12:30:24 +0000

…whether through redlined maps or implicit “one-mile rule,” the result can be undervalued properties in historically marginalized neighborhoods. Throughout the history of mortgage banking and lending in the United States, underwriting policies have significantly influenced the appraisal process for home purchases and refinances. Appraisers must follow underwriter appraisal review guidelines meticulously to ensure their appraisal reports are accepted by the lender. Unfortunately, in the past, these policies became the basis for redlining, wherein certain communities were systematically denied access to mortgage credit. In this article, we delve into the historical context of underwriting policies and their influence on the appraisal...

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 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.…
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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Is the GSE’s “Appraisal Modernization” Really Just Mass Appraisal?

Dallas T. Kiedrowski, MNAA — Thu, 07 Mar 2024 13:30:04 +0000

Mass Appraisal tend to exhibit a regressive nature… In the intricate landscape of real estate mortgage financing, the notion of appraisal waivers recently dubbed “Value Acceptance”, by the Government Sponsored Enterprises (GSEs), has stirred considerable debate. The most recent statistics show Value Acceptance accounts for up to 40% of all mortgage approvals. It is presented as part of the GSEs “Appraisal Modernization” initiative, which aims to streamline the mortgage appraisal process. However, a closer examination reveals potential drawbacks, raising questions about its efficacy and impact on the housing market. Despite its roots in a methodology designed to support appraisers, Value...

AMC Hires a Convicted Felon as Property Data Collector The recent case of Paschal Uchendu, a convicted felon awaiting sentencing for orchestrating a $1.2 million armed robbery of a…
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.…
From Data to Value: How Mass Appraisal Delivers Fair… Behind every annual notice of assessments is a complex valuation system most property owners never realize exists. The Appraisal Foundation…

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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....

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…
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…
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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The Scam of Racial Discrimination by Appraisers

Michael Ford — Wed, 10 May 2023 12:30:40 +0000

More and more appraisers are retiring every day. Aside from that more and more are changing to lower liability careers. Eventually, the opportunists who have been promoting the scam of racial discrimination by appraisers such as career politicians, and ‘anti-discrimination’ software hucksters like Black Knight will be shown to be what they truly are. Recently, a highly respected appraiser who is also a senior designated member of a well-known national professional peer association, wrote an article about a new proposed law in New York ostensibly targeting New York appraisers. Mr. Bagott’s article had an unusual amount of hyperbole within it...

Why is Only One Side of This Story Being Told? There are always two sides to every story; however, understanding is a three-edged sword: your side, their side, and the…
HUD Dismisses Claims Alleging Racism ...white America (government) keeps trying to 'fix' Black People who are not broken in the first place! We’ve all heard…
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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The Appraisal Problem

Guest Author — Thu, 20 Oct 2022 12:30:37 +0000

Gone are the days of hiring a professional appraiser to solve the appraisal problem. For decades lenders have taken on the responsibility of shaping the appraisal process and dictating the solutions to the appraisal problem. Savvy appraisers push back in a positive fashion to try and enable the lender to receive a report that not only meets USPAP, FIRREA, Fannie Mae, or HUD/FHA/VA an UAD reporting guidelines, but also provides the client with a report that is clear, concise, accurate and not misleading. An appraisal report can be on time, have all the boxes checked, no inconsistencies, meet all the...

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…
Convicted for Committing Fraud Unknowingly? Appraisers need to have intent in order to be convicted of fraud... I have recently read several different posts and…
Schizophrenic Adjustments Appraisers, I’ve written in the past about what I believe are strange ways to report adjustments in appraisals, and suggested…

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Grants to Help Train Appraisers

Dave Towne — Tue, 13 Sep 2022 12:30:21 +0000

To establish grants directly to supervisor appraisers to help cover the training costs for each Trainee… Folks, this article appeared in American Banker on September 7, 2022. In my view, after reading it, the article appears to present a balanced perspective about what appraisers have been experiencing since the FIRREA law was mandated back in 1989. It also exposes problems with getting new people into the appraisal profession. If you have been paying attention to appraisal related activities over the years, you will recognize the names of people quoted in this American Banker article. One thing that has not been...

The Trainee Inside the Fast and Cheap Model The trainee walked into a job expecting mentorship and instead found a crash course in misconduct. There is a widening…
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.…
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…

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Racial Bias in Real Estate: Is it the Appraisers’ Fault?

Maureen Sweeney — Tue, 22 Jun 2021 12:30:14 +0000

In the past year, the appraisal industry has been under attack from various academics who claim “racial bias” on the part of real property appraisers providing appraisal services to lenders who provide home mortgages. These academics do not fully understand various types of valuation specialties, the appraisers who practice in these specialties, and the myriad of laws that must be followed. Help is needed to explain the appraisal industry, including the specialties and the types of reports. An understanding of the different components of the appraisal industry is necessary to assist various academics, journalists, the media, the public, and the public...

Independent Fee Appraisers Under Attack Appraisers, I have reached my boiling point about the negative press ‘we’ Independent Fee Appraisers have been receiving for many…
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 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…

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Reconciling the Erosion Within My Profession

Maureen Sweeney — Wed, 09 Sep 2020 12:30:02 +0000

The continued reliance of unregulated aggregators and bifurcated products continues to erode the public trust at the expense of discarding the profession specifically intended to promote the public trust. How does this protect the public?… On June 14, 2005 Steve Jobs told a class of graduates, “you can’t connect the dots looking forward; you can only connect them looking backward” Around the same time, I was appointed as the sole residential member of the appraisal licensing board of my state. Little did I realize that this 2005 governor-appointed position would eventually lead me to sharing a stage in 2018 with...

Honest Appraisers Who Risked Their Careers Meet the Honest Appraisers Whose Warnings Should Have Prevented the Great Financial Crisis The honest appraisers’ warning was ideal. It…
Racial Bias Claims Without Proof or Logic The Appraisal Institute just sent a letter to The Appraisal Foundation to address things that have been floating out in…
Is Race Baked into Big Data? Chicago appraiser and friend (even though she calls me “fancy pants”) writes a stellar explanation of what an appraiser actual…

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Professional Opinions Can Never Be Replaced

Michael Ford — Wed, 17 Jun 2020 12:30:13 +0000

Professional OPINIONS have value that can never, repeat NEVER be replaced by automation… Earlier this week, George Dell‘s article titled “Why is Residential Appraisal in Trouble?” was published on AppraisersBlogs. Respectfully, George misses or misinterprets a few items. There has been zero evidence that an AVM produces credible approximations of MARKET VALUE consistently or with even an acceptable degree of variance. None. Like George indicates, an AVM is NOT an appraisal. By definition, it is not an appraisal. FIRREA required appraisal standards; NOT banking industry and TAF proposed alternatives. TAF is very far out of line giving AVMs any imprimatur...

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…
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.…
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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Unsolicited Appraisal Request

VaCAP Board — Wed, 11 Mar 2020 12:30:08 +0000

…an unsolicited appraisal request instructing payment be collected at the door… Well who said 2020 would be a nice calm year for appraisers? VaCAP has been receiving messages from appraisers about some of the crazy dumb stuff lenders and amcs are doing. What is scary is the things we are hearing are very reminiscent of 12-15 years ago. A long time VaCAP member forwarded an appraisal request to us he received via Mercury Network. All was good with the order, turn time, fee; all good except for one little issue, payment was to be collected at the door from the...

West Virginia Appraisal Board Scheme The Doomed Quest to Reform a corrupt West Virginia Licensing Board “Board members earn money working for a law firm…

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GAO to Investigate Appraisal Loopholes

VaCAP Board — Fri, 21 Feb 2020 13:30:32 +0000

…Arizona is seeking damages and penalties against CoesterVMS… GAO has agreed to complete the study… Maxine Waters and Congressman William Lacy Clay requested a formal study/investigation into Title XI (FIRREA) and the recent dilution of its intent by the Federal Agencies. VaCAP has learned GAO has agreed to complete the study. The Network of State Coalitions has sent the following to their state members: This is the result of so many voices – the Foundation, ASA, coalitions, NAR, etc. Our Network efforts have given us an inside connection that hopefully we can continue to build on. Our meeting in DC...

FIRREA Under Attack! ...the federal agencies charged with implementing Title XI of FIRREA have taken steps to limit the number of transactions for…
Coester Loses in Court! Gosh... I’m really sad to bring you this news (sarcasm). Brian Coester Loses in Court! About 2 years ago, Georgia…
The Collective Rot Over 11,000 appraisers signed that petition... The US Congress completely ignored it and, as a result, The Great Real Estate Depression…

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FIRREA Under Attack!

VaCAP Board — Thu, 13 Feb 2020 13:30:15 +0000

…the federal agencies charged with implementing Title XI of FIRREA have taken steps to limit the number of transactions for which an appraisal is required… Congresswoman Maxine Waters and Congressman William Lacy Clay request a formal study/investigation into Title XI (FIRREA) and the recent dilution of its intent by the Federal Agencies. The letter to Gene Dodaro, Comptroller General, Government Accountability Office, addresses threshold increases, regulatory exemptions, appraisal waivers, the North Dakota appraiser certification waiver and evaluations in lieu of an appraisal. It is clear the Chairwoman of the House Financial Services Committee and Subcommittee Chairman on Housing, Community Development and Insurance...

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…
Tapping States for Backchannel Budget Scofflaw U.S. Agency Taps States For Its Backchannel Budget VENTURA, Calif. (February 4, 2022) – History is replete with cautionary…
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…

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VaCAP Expresses Concerns to Legislators

VaCAP Board — Thu, 10 Oct 2019 12:30:29 +0000

The safety and soundness of the housing market is the back bone of local economies, the national economy and yes, the international economy. We have barely recovered from the major financial crash of 2007/2008. Let’s not do it again! Last week we shared with you Maxine Waters and Sherrod Brown’s inquiry to the Appraisal Subcommittee inquiring on the parameters used to determine the North Dakota Appraiser Waiver approval. We encouraged each of you to take advantage of the attention on our profession and contact your representatives. VaCAP has sent letters to both the US House of Representatives Committee on Financial...

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…
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…
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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Appraisal Waiver Questioned by Legislators

VaCAP Board — Tue, 01 Oct 2019 12:30:01 +0000

Late Friday afternoon, VaCAP learned the Financial Services Committee Chairwomen. Maxine Waters and Senator Sherrod Brown, Ranking Member of the Senate Committee on Banking Housing and Urban Affairs, sent a letter to the Appraisal Subcommittee Chairman Arthur Lindo inquiring around the circumstances of the North Dakota Appraisal Waiver that was granted a few months back. The exact verbiage used in the letter to describe the waiver was “unprecedented with minimal justification.” This speaks volumes as to their concern. Congress has repeatedly recognized the essential role that appraisals play in both safety and soundness and consumer protection. That is why it is...

FDIC Says NO to Appraisals The FDIC voted to increase the minimum appraisal threshold to $400,000 for residential appraisals, despite the overwhelming opposition. The vote…
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…
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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AMC Incompetence in Appraisal Management

Michael Ford — Wed, 18 Sep 2019 12:30:48 +0000

I’m told USRES routinely sends orders to out of state appraisers for orders in areas they don’t work in. Is this indicative of the Home Point Financial “We care” motto? ATTN: Executive Leadership Gentlemen, see attached copy of an Alabama appraisal order placed by your AMC, USRES. Among our many other efforts on behalf of appraisers and promoting appraisal quality, we periodically communicate directly with lenders that use AMCs. We do this to make sure they are aware of any substandard practices or services that may be offered in their name. This particular issue is not an isolated instance. Though...

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…
Look in the Mirror The phrase “take a look in the mirror” is a common idiom used to encourage self-reflection and introspection. It is…
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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FIRREA - Appraisers Blogs

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

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It’s Time to Take Out the Junk: AMC Practices Exposed

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USPAP’s Typical Buyer Standard in the Fair Housing Era

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Systemic Failures in FHA Appraisal and Loan Review

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Lack of Evidence, Appraiser Challenges Discrimination Claims

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The One-Mile Rule: Prudent Policy or Modern Day Redlining?

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Is the GSE’s “Appraisal Modernization” Really Just Mass Appraisal?

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The New & Improved Fannie Mae “FRAUDULATOR 2.0”

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The Scam of Racial Discrimination by Appraisers

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The Appraisal Problem

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Grants to Help Train Appraisers

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Racial Bias in Real Estate: Is it the Appraisers’ Fault?

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Reconciling the Erosion Within My Profession

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Professional Opinions Can Never Be Replaced

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Unsolicited Appraisal Request

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GAO to Investigate Appraisal Loopholes

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FIRREA Under Attack!

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VaCAP Expresses Concerns to Legislators

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Appraisal Waiver Questioned by Legislators

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AMC Incompetence in Appraisal Management

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