Retired, should have listened to you ten years ago, if not longer. What’s on the horizon next is hud is substantially ramping up it’s ‘note sales’ directly to investors, mirroring the fnma whole lending program. The upcoming definitions regarding POTUS executive order titled; stopping wall street from competing with main street home buyers. Issued 01/20/2026.

There appears to be some definition and language games being played in an attempt to circumvent the order, so wall street can continue to have upstream access to residential properties for their primary benefit, rather than regular citizen. The thirty day requirement has passed, still no clear definitions issued, as the sixty day compliance deadline comes late this month. This is going to define how gse’s handle defaulted properties, as well as influencing housing price and price discovery, possibly for generations to come.

It’s quite remarkable HUD would even take this approach, they’re claiming this reduces losses to the fund pool, yet the fact remains this activity of selling defaults directly to corporate investors is harmful for buyers and affordability everywhere. So hud ramps a mirrored version of fnma’s handling, happening simultaneously as FNMA affirmed a now made permanent, special reo handling privileges, to a limited set of amc’s.

A friendly agent ran some AI Q&A on this which is really actually quite good, as much as it pains me to say that. I’m cleaning out our conversation and will be forwarding to blogs as this might be article worthy. If not I’ll launch a long copy AI comment post on this soon. Here is one of the investment side articles on the matter that was AI referenced. Perspective of institutional investors and lawyers on this executive order. These people are not going to stop until the ability to game real estate is wrested away from them via firmly and broadly stated definitions. They expect an increase in lawsuits and are ready to fight to maintain this new status quo of everyone being at the mercy of corporations in their residential housing interests. I’ve also copied a brief portion of this AI explanation below. The entire thing is three or four pages long.

Executive order;
https://www.whitehouse.gov/presidential-actions/2026/01/stopping-wall-street-from-competing-with-main-street-homebuyers/

Article reference;
https://www.manatt.com/insights/newsletters/client-alert/executive-order-targets-institutional-purchases-of-single-family-homes?utm_source=chatgpt.com
________________________________________

Yes. There is evidence HUD has been doing note sales recently, including very recently in 2025 and 2026. It is not widely discussed in the REO brokerage world because these sales happen through HUD’s Office of Asset Sales, not through the normal HUD REO disposition channel.

HUD is actually expanding the program / HUD finalized rules to create a permanent Single Family Loan Sale Program that combines several prior note-sale programs. / The program has existed in some form since 2002 and has increasingly been used as a default disposition strategy for delinquent FHA loans.

After the 60 day deadline, will current HUD note sales comply with Section 3?

That depends almost entirely on how Treasury and HUD define and implement three things:
1. what counts as a “large institutional investor”
2. what counts as a “single-family home”
3. whether a note sale is treated as “facilitating” an acquisition or as a Federal asset disposition that effectively transfers the home to that investor

If HUD’s guidance treats these HECM note sales as outside Section 3 because HUD is selling debt rather than title, then the program could continue, especially with exceptions or narrow carveouts. But if HUD treats note sales as a prohibited way of channeling single family homes to large institutional investors, then these sales would become much harder to defend after implementation. Section 3 is written broadly enough that HUD note sales could fall within its reach, especially because it prohibits not only direct dispositions, but also “facilitating” acquisition by a large institutional investor. / End

https://appraisersblogs.com/FHFA-working-paper-credibility-questioned

Sounds about right. Eight years later after this piece, more true than ever. Thank you.

Your comment; Published Fall 2025, WorkingRE. Great job.

AMC’s have bilked the American borrower out of 12 billion dollars. The ARCC compiled extensive data that reveals how unregulated appraisal management companies engage in unfair pricing practices, inflating consumer appraisal costs by nearly 15 billion between 2013 and 2023. This research clearly demonstrates the anti-competitive nature of the amc pricing model of hidden fees and it’s impact on borrower’s buying power.

An understandable sentiment. But only amc appraisers would get to be part of the settlement. It’s the amc appraisers whom deserve to lose their licenses the most. They facilitate the fraud by accepting unacceptable assignment conditions, knowing full well the amc’s defraud consumers. The amc appraisers understand they get prioritized access to work, that no other appraiser licensee can get, because they provide a thing of value to be the preferred appraiser, in violation of the USPAP management rule. All that’s necessary to be a successful amc appraiser is to play ball, discount enough so the amc can pocket a sufficient unearned fee billing rake, and look the other way on systemic consumer billing fraud. The consumer never saves a dime. The other three quarters of the appraisal valuation service licensees whom refuse to work with amc’s for ethical reasons have been excluded or blacklisted from working in this space, some for well over a decade. These are RICO violations, restraint of trade arguments. If amc’s are liable, so are the lenders. The amc legally defined as a representative agent of the lender. Lenders are acutely aware of how many fewer appraisers are available to them under the amc model. Those same lenders deal with an entirely different origination scenario when working with the VA. Can’t hide it.

That’s a good piece, professionally focused.

Except amc’s are not professional companies nor stake holders. They are legally defined as representative agents of lenders. Their primary function has morphed into specifically specializing in side stepping regulatory guidance and eliminating appraiser independence. They should no longer be called appraisal management companies as they appear to specialize in redirecting as much work away from appraisers, also having used their monopoly power and billions of unearned junk fee billing rake to capture many non appraisal related spaces which are integral parts of mortgage lending. Amc’s should be regulated at the federal level just like lenders. They should be required to have individual licensing for everyone involved. Even then, the amc functioning legally as an agent of the lender, should not have one of their members sitting in clear conflict of interest on state individual appraiser licensing boards.

Stake holders…. In a centrally planned system devoid of meaningful checks and balances. When do we the people and every day workers in this industry get a vote? When do consumers get their power back? The consumers right to choose whom their vendors they hire? There is no effective way for consumers to research anything in the realm of real property valuation as that pertains to mortgage lending. Lenders obscure their relationships with amc’s, use multiple amc’s simultaneously, steer customers to their profit centers, tell consumers they can not pick their own appraiser. The consumer has no choice, no vote in the matter. From a consumer protection and stable operation of gse systems standpoint, amc’s have been a total failure, enticing exponential increases in fraud, safeguarding nothing.

Value shopping never left. It only took on new innovative forms under the disguise of amc’s.

Missing the IVPI proposal yet?
https://www.workingre.com/wp-content/uploads/2013/08/IVPI-Proposalfinal.pdf

FNMA wholesale lending program serves as an effective cover to redirect defaulted properties directly into the hands of their partner institutional investors at volume levels never before seen. Thereby nullifying effective disclosure of insufficient and arguably regulatory non compliant appraisal engagement during forensic review. Foreclosure by design. Increased profits the result. Consumer protection removed from the GSE priority list years ago. Short sales have already returned, substantial increases.

Enter executive order curbing institutional investors from buying residential properties. Will it make a difference?

https://www.whitehouse.gov/fact-sheets/2026/01/fact-sheet-president-donald-j-trump-stops-wall-street-from-competing-with-main-street-homebuyers/

Source article.
https://appraisersblogs.com/fannie-mae-fraud-and-abuse-exposed/
Specifically this;
https://capitalmarkets.fanniemae.com/whole-loan-sales

Pepsi challenge; Tally up the total volume of principal default amounts over the entire term this program has been running. The figures are more than substantial. The reason why there is related news stories of institutional investors possibly currently holding 20% or more of all residential housing in the country.

Amc’s made all of this possible with their concerted efforts to steadily erode then eliminate appraisal independence. FNMA endorsed the behaviors with continuing appraisal modernization efforts.

With additional monetization of the data on the back end. The guy whom owns that company or somehow has a major stake, I do believe is an appraiser and also has sat on state appraisal boards, while simultaneously working hand in hand with top amc interests. He wrote articles in favor of uad 3.6 and modernization which proclaimed the appraisers will no longer be using clip boards and manual methods. I drew up a meme at the time to celebrate the occasion, titled it; Tony the clip board eliminator. / GLB is dead.
https://appraisersblogs.com/fannie-n-freddies-offshore-gambit-imperils-privacy-of-millions/
https://appraisersblogs.com/automatic-review-of-photos-in-appraisal-reports/

The fees stopped making sense by March of 2009 for Christ sake! Work load doubled overnight and fees were reduced by half. Entire rosters of hard earned clients evaporated for most appraisers.

There are honestly appraisers out there who are just beginning to figure this out?

When you say the fees are rising, I assume that you mean fees are finally getting back to where they were in 2009. We were charging $400 to $700 for typical residential work prior to March of 2009 and turning away three times more orders that we were accepting.

If you (or any other appraiser) are elated over $500 to $650 for a standard appraisal fee I worry about you guys. You do realize that your work load is about to double again with the new forms…right?

Show me a $1,000 fee for an 800 sf single family home appraisal and I’ll show you a guy who would consider reentering this lousy profession.

I think many of us are rowing the boat with you. One AMC went from just assigning at “almost” a respectable fee to email blasts for fee and turn time. After at least 100 of those producing ZERO orders, I made the decision that if I was going to be broke it would be on my terms and not by helping the enemy kill us the rest of the way by joining the race to the bottom. Good luck.