FIRREA - Appraisers Blogs

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...

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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...

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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...

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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...

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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...

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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....

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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...

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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...

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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...

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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...

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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...

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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...

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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...

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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...

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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...

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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...

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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...

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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...

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Computershare Reviews & Cheap Diapers

Michael Ford — Thu, 05 Sep 2019 12:30:35 +0000

The resulting “outcome” of those cheap diapers is the same outcome as Computershare 15-minute reviews must be… This didn’t start out as an article, but you know me. Doing research prior to posting in the 100% comments board I was shocked at how pervasive this new ‘service’ already is. A simple blog post can’t begin to cover it. Every single reader needs to research their own states requirements. The AMC at the following link makes this easy. Please look your state up. My concern was with Computershare and Colorado. Feel free to look them up by clicking here. If that doesn’t...

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FDIC Says NO to Appraisals

VaCAP Board — Wed, 21 Aug 2019 12:30:22 +0000

The FDIC voted to increase the minimum appraisal threshold to $400,000 for residential appraisals, despite the overwhelming opposition. The vote was quietly supported by the Consumer Financial Protection Bureau (CFPB). Maxine Waters and The Appraisal Foundation condemn the actions of the FDIC. See The Appraisal Foundations response below. (Washington, DC) August 20, 2019 – The Appraisal Foundation President David Bunton issued the following statement after the final rule exempting residential real estate transaction of $400,000 or less from appraisal requirements was approved by the Federal Deposit Insurance Corporation. “When the proposed rule was announced in November 2018, The Appraisal Foundation...

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