The Harbor Model: Where Appraisers Take the Helm
The author of this article has chosen to remain anonymous, not out of fear, but out of necessity. Since 2012, they’ve been developing a disruptive valuation model that challenges entrenched interests in the appraisal and AMC industries. Their work has drawn direct confrontations from AMC owners and industry insiders, many of whom are threatened by the implications of these proposals. Anonymity, in this case, is a shield, not from scrutiny, but from retaliation.
If you want to hear directly from them, there’s an interview available at the Harbor Oversight legislation page. But here, the ideas speak for themselves.
Before we get to the full article, it’s worth highlighting one paragraph that speaks directly to a concern appraisers have voiced for years, the unchecked use of their work to power automated valuation models:
Importantly, Harbor introduces the first valuation AI that attributes authorship to the appraisers whose work built the data layer. Appraisers are credited, tracked, and—where appropriate—compensated. This initiative aligns with the need for a federal appraisal license to protect and recognize the contributions of appraisers. The era of silent data extraction ends here.
And now, in their own words, the author lays out the stakes, and the solution.
“Generals gathered in their masses, just like witches at black masses. Evil minds that plot destruction. Sorcerer of death’s construction—oh Lawd yeah…”
The scene is set. Valuation Expo 2025 takes over Caesars Palace in Las Vegas. Risk officers, data vendors, proxy regulators, and private AVM firms swarm the halls—scheming, selling, spinning tales of modernization. HR 1625, the so-called “Appraisal Modernization Act,” is their anthem. They’ll crown the Kings of Modernization 2025 and call it progress.
They don’t realize, or worse, they don’t care, that the average appraiser couldn’t dream of affording a flight to Caesars Palace, let alone a three-day pass to sit through panels wrapped in jargon and self-congratulation. What they call a summit is, to most of us, a vacation we didn’t get this year. And here’s the bitter truth: your signature, yes, your signature, is what paid for it. That same signature, bound by regulation and framed in fear, feeds this dysfunctional family of middlemen, advisors, and alphabet groups. You didn’t just stay home; you sent them there. And for what?
Their AMC business model creates no value, no added value, except for themselves. They don’t touch the house, don’t read the report, don’t stand behind the number. They just take a cut… and call it modernization. And they’re not alone. Every few years, another wave of hangers-on shows up, consultants, tech vendors, form re-designers, slapping fresh wrappers on the same broken system. New formats, new portals, new compliance tools, all pushed without real input from appraisers, and certainly without consent. These are the pickpockets of policy, quietly emptying your pockets while claiming they’re helping you carry the load. If you’re tired of their polished words, modernization spun from focus groups and committee rooms, then take a few minutes to hear me out. This isn’t a pitch. It’s a real plan to save the appraiser and deliver true modernization.
There’s a new idea in town, and it’s designed to rescue the appraisal industry from people who couldn’t carry your HP-12C. HARBOR resolves many of the problems infecting the risk and valuation industry. Harbor brings a long-overdue answer to the issue of appraisal copyright and data misuse. For too long, appraiser-authored reports have been mined by GSEs and platforms to power AVMs, without consent or compensation. Through its Buyback Intelligence Transfer (BIT), any time a Harbor AVM cascades to a usable result, the contributing appraisers within that zone, called a Hit Box, receive a monetary credit. It’s a system that finally recognizes the value of your contribution.
The plan outlines a clear, three-step framework paired with the legislative actions needed to bring it to life. It fully anticipates the wind-down of FNMA and includes detailed strategies for transferring their data and AVM infrastructure into the Harbor system. I’ve invested considerable time modeling each phase, and I’m confident that every angle has been accounted for.
For decades, the appraiser has worked in isolation, licensed by states, undermined by third parties, and left to fight uphill against systems designed without them in mind. Harbor changes that. With a single, federally-issued license, appraisers step into a unified system, protected by national standards, backed by real oversight, and no longer subject to the patchwork of conflicting state policies and backdoor politics.
A federal license means your credentials travel with you. Your experience is recognized across state lines. Your voice is part of a national network. No more redundant renewals, no more arbitrary rules set by state boards influenced by those looking to cut you out. Harbor gives you a seat at the table, and a system that’s finally working for you, not against you.
You’re not an island anymore. You’re part of something bigger.
For the past two years, I’ve been quietly working behind the scenes, training AI agents, testing neural pathways, and building the foundation for a future where appraisers are empowered by artificial intelligence, not replaced by it. The goal was never to automate judgment but to connect the right intelligence to the right moments in the appraisal process. Harbor is the first system designed with that link in mind. Now, with plans underway to secure a compute partnership with OpenAI, Harbor will operate within a secure, enterprise-grade AI environment supporting scalable, valuation-specific models. Our Utah-based operations center will serve as a real-time deployment site for AI agents assigned to Harbor’s oversight grid. These agents don’t just process data, they interpret risk and help appraisers do what no algorithm ever could: deliver sound, independent valuation rooted in market truth.
For decades, the appraisal fee has been treated as a “hard cost,” forced to the front of the transaction and paid out-of-pocket by borrowers, regardless of whether the loan closes. This outdated structure not only placed appraisers in an awkward financial position but created confusion over who pays, when, and why. Harbor eliminates that friction entirely by structuring the appraisal fee into the loan itself, using a forward-facing payment allocation system that treats the valuation process as an essential component of underwriting, not a bolt-on service.
Under Harbor’s model, the appraisal fee is no longer a barrier to entry for borrowers or a waiting game for appraisers. The total cost is built transparently into the loan, and through early-payment allocation, Harbor recoups the appraisal fee in the first several payments made on the loan, not as a surprise or surcharge, but as part of the natural amortization flow. Appraisers are paid on time. Borrowers are not hit with out-of-pocket fees. And lenders are no longer tangled in collection or trust account mechanics.
Most importantly, this structure preserves the independence of the appraiser. The appraiser remains a licensed, third-party professional, contracted by Harbor, not employed by it, and remains fully protected under federal license standards. Financing the fee in this way does not compromise objectivity; it simply ends the outdated “hard cost” designation and finally treats appraisal as what it truly is: a foundational part of the lending process worthy of streamlined, fair, and forward-thinking compensation.
One of the most damaging forces in the current appraisal landscape is the lender-driven bidding process. In an attempt to cut costs, many lenders solicit multiple bids and accept the lowest offer, regardless of quality, expertise, or turnaround time. This “race to the bottom” has eroded fees, demoralized professionals, and pushed many qualified appraisers out of the industry altogether. It’s a short-sighted tactic that treats valuation as a commodity instead of a profession, and the industry is paying the price.
Harbor puts an end to the bidding wars. Under our model, fees are standardized, reviewed annually, and set to reflect the complexity of the assignment, not a blind auction. Every appraiser working under Harbor receives fair, posted compensation for their work. No bidding, no undercutting, no games. This creates a more stable profession, attracts new entrants to the field, and restores dignity to a role that has long been underappreciated and underpaid.
By decoupling compensation from lender preference and enforcing consistency across the board, Harbor re-centers the appraiser’s value in the process. It’s not about who works cheapest, it’s about who works best. And Harbor makes sure that’s who gets hired.
“No more war pigs have the power. The hand of God has struck the hour. Day of judgment—God is calling. On their knees, the war pigs are crawling. Oh Lawd yeah…”
To learn more about the Harbor model and how it offers a true alternative to the Appraisal Modernization Act of 2025 (H.R. 1625), visit harboroversight.org. If you’re ready to help reshape the future of valuation, contact any member of the U.S. Senate Committee on Banking, Housing, and Urban Affairs and let them know there’s a better way forward, it’s called Harbor.
- The 24-Hour Appraisal Diet: Slim on Time, Light on Credibility - September 5, 2025
- The Harbor Model: Where Appraisers Take the Helm - August 8, 2025
- FOIA, AI, & the Appraiser’s Defense: A Blueprint for Fighting Back - June 13, 2025
It’s an interesting thought experiment but gets really off course on the “system core” page. No disrespect intended, but it shows a lack of technical know-how. Also, all of these marketing pages on their site were clearly written by ChatGPT (the long — dashes are the giveaway as is the writing style).
Also, while the ASC has it’s major flaws, I’m not convinced redirecting federal funding to another group of suit wearing “meetings” people is the answer. Overall, there’s some interesting ideas in there like unified license and nuking the AMC model but also some bad ones like setting fees.
And finally, AMCs delenda est!
I’m with you, Chase. There were some good arguments, but it lacked real “know-how.” What this industry needs is an independent appraisers’ association — one the big players can’t corrupt or control. I’ve learned far more from conversations with other small business owners in this field than from the hundreds of hours of CE carefully curated in partnership with FNMA, app institute, and the large AMCs.
Totally hear you, Cam and I used to feel the same way. But we’ve had independent appraiser associations. Plenty of them. Some started strong, but over time? Corrupted, co-opted, or just plain silent when it mattered. The Appraisal Institute’s backroom deals with AMCs were bad enough, but then came the sexual harassment allegations, the testing fraud, and the leadership cover-ups. ASA and others didn’t say a word when appraisers were getting smeared with bogus discrimination claims. And instead of defending the profession, they leaned into DEI talking points and the whole unconscious bias narrative.
Even the state coalitions like VACAP did great work locally, but most faded out because appraisers stopped showing up. It’s not that the idea of an association is bad. it’s that we’ve tried it, and it hasn’t held up.
That’s why I’m more interested in something like Harbor. It’s not another club or committee, it’s a system. If it can actually protect appraisers, deliver real-time data, and cut through the politics, I’m all ears. At this point, I’m done hoping an association will save us.
And the AMCs are thrilled that we can’t just come together
Chase, you raise some valid points. That “System Core” write-up definitely reads like it’s trying to impress… F-35 jets, data vaults, and AI grids sound cool, but it’s hard to tell how much of that is real tech versus marketing flair. I’m not a tech expert, so I won’t pretend to know if it’s legit or just dressed-up jargon. But if the goal is better housing data and less delay in oversight, maybe it’s worth looking past the buzzwords.
On the ASC, totally get the hesitation. Swapping one group of suit-wearing meeting folks for another doesn’t solve much. But maybe the idea isn’t just moving money around, it’s about building something that actually listens to appraisers and acts fast. If Harbor’s setup gives appraisers more say and cuts through the red tape, that could be a step forward.
Totally agree on the AMC mess. “AMCs delenda est” might need to be a t-shirt. As for the other ideas, I think things like portable certification and fair, consistent pay are worth exploring. Not perfect solutions, but better than the status quo.
Interesting military type language integration. Hard to miss actually. This is why I normally try to avoid talking to robots or reading AI generated proposals. Trust the plan? I don’t think so. Central planning never works. Going to make some meme’s out of the AI images here. I’ll call it; My own personal AI overlord.
Hmm. Now thats interesting!
Anything that will get AMC’s out of the picture will be good for the industry as a whole.
It’s definitely a step toward getting the dignity back for appraiser’s and being recognized as a beneficial instead of friction. I also love the time of the War Pigs timely salute of Ozzy’s recent passing.
Commentary on the Systemic Failure of Dodd-Frank Enforcement in Appraiser Compensation and what will make this any different?
Despite its well-intentioned framework, the Dodd-Frank Act has been systematically hollowed out in practice. While it mandates that appraiser fees be “customary and reasonable,” the reality is a marketplace dominated by appraisal management companies (AMCs) and lenders who routinely ignore this requirement. Instead of fostering professional independence and fair compensation, the system incentivizes a race to the bottom—where “best price and fastest turn time” override compliance, ethics, and quality.
**The Numbers Tell the Story**:
Over 80% of appraisers report being offered fees below market norms by AMCs, with little room to negotiate.
– The number of disciplinary actions or meaningful fines for violating Dodd-Frank’s fee provisions remains vanishingly small. Most penalties, when issued, are **under $1 million**—a negligible cost for firms managing billions in assets.
– The average AMC markup on appraisal fees can exceed 40%, with appraisers receiving a fraction of what the borrower pays—undermining both transparency and fairness.
**Divide and Conquer**:
Worse still, AMCs have weaponized competition by pitting appraiser against appraiser. Assignments are routinely awarded not based on qualifications or geographic competence, but on who will accept the lowest fee and fastest turnaround. This practice directly contradicts Dodd-Frank’s intent to protect appraiser independence and prevent coercion. It fosters a toxic environment where professionals are forced to underbid one another just to stay afloat—eroding quality, morale, and public trust.
**Oversight in Name Only**:
Regulators appear either unwilling or unable to enforce the law. The Consumer Financial Protection Bureau (CFPB), tasked with oversight, has issued only a handful of fines—none of which have meaningfully changed industry behavior. State-level enforcement is fragmented and inconsistent, with many jurisdictions lacking the resources or will to investigate AMC abuses.
So when new proposals surface—promising to restore fairness or reinforce compliance—the question remains: “What will make this time different?” If the same players are allowed to ignore the rules with impunity, and if no one in oversight is willing to intervene, then what good is another layer of regulation?
Don’t worry. Nobody will go to jail. Except maybe the appraiser.
https://en.wikipedia.org/wiki/GameStop_short_squeeze
I argue that the fee is what the customer actually pays. It’s the only fee that they see on the HUD 1.
The HUD 1 is a CB legal document is it not?
Remember that very first appraisal and or economics class you took where they told you that excessive profits produced ruinous competition? What they didn’t tell you was than ANY profit bred ruinous extortion.
Regarding the article, yeah, we’ll see. A federal license? I can see a good side to that in that you could work anywhere. I can also see something else. I mean, having a state license is bad enough. Can you imagine a federal license?!
The whole idea of someone other than you and or I deciding what we’re worth on any particular assignment is still communism. It wasn’t designed to be fair. It was designed to beat you to a bloody pulp. Who decides what’s reasonable? Who decides what’s customary? They treat us like a sack of grain or a loaf of bread, a commodity. But, oddly, I can’t go to the feed store or grocer and tell them that I set the price of a bag of corn or a loaf of bread. I’d be arrested if I insisted on paying 50 cents for a $5 loaf of bread.
Consider this, AI is here to stay and the longer it stays, the more detached from reality valuations will become.
That’s what made the C&R rule so brilliant. Market surveys. It was the appraisers themselves that set the market for what C&R fees.
A solid solution is already out there; the IVPI proposal. No unnecessary tech. A transparent process. Fair fees and fair distribution. And it will not cost six billion dollars.
https://www.workingre.com/wp-content/uploads/2013/08/IVPI-Proposalfinal.pdf
Who else is there pursuing these goals? The use of this technology will skew the market even more so than it already is. Define conflict of interest.
https://blog.restb.ai/impact-of-condition-and-quality-on-appraisal-accuracy
Not all consumers want this invasive technology, data held by a private company. It’s bad enough the CU system provides a central repository with a fraction of this proposed data gathering. Consumer privacy in GSE lending is almost non existent.
Wind down the GSE’s, require lenders manage their own risk without taxpayer backing. The comptroller; still suspiciously absent.
Define free market principals before trying to answer such complex issues by substituting one monopolized market with another.
These proposals are entirely unnecessary and overly complex. (I’m apparently arguing with a robot again.) Just separate the appraiser billing already, require round robin. Roll back appraisal waivers. Ditch the updated forms.
The solutions do not require advanced tech. They will require those seeking reform to remain focused on general consumer protection and citizen privacy first, rather than generating opportunities to install proprietary software, create new avenues of corporate profit.
Going to pass on my own personal AI over lord. I certainly do not want this as a regular consumer either.
They put me out of business after 24 years. Fees suck
Just logged our 35th job for the YEAR! What used to be our monthly job count…..Yeah, the line about what appraiser can even afford a trip to Ceasars Palace to see all this? Correct. QE and waivers and All the other tricks that stole our livelihood has left a once thriving industry in life support 👿
This looks like an interesting and potentially worthwhile model, but more information is needed – I would like to know if there is a group that is fighting the HR 1625 – I would like to contact my “officials” – not that it may help much. I searched on line, but found nothing but the bill, itself.
Is there a group fighting this??
Who is behind the curtain of Harbor? I watched the Wizard of Oz. I discovered I don’t like the guy behind the curtain. This is PRO artificial intelligence and less medulla oblongata.
I’m done supporting BS causes.
I’ve pretty much left lender work behind. It took a lot of effort and some tough years to make the switch, but it was worth it. After more than 20 years in the rat race, I can’t see anything that would pull me back.
I get that it’s not great for the profession when more of us step away and leave that side of the work to the younger crowd—but we were that hungry group once too, grinding out 15-hour days, six days a week.
If the folks still in mortgage work want to let a system like this define how they operate, that’s their choice. Let them put their own stamp on it—maybe something good will come from it. My heyday’s behind me, and I’ve made plenty of hay in the past two decades. These days, I’m happy taking the private work that comes my way and watching how the rest plays out.
Well stated!!
Off topic, but if anyone cares the state of CA has lost 113 active appraiser licenses over the past 105 days. With a current appraiser count (active license) of 7,677 at what point will a reduction of +/- 400 appraisers a year gain the attention of the powers that be?
The new form will only lead to an increase in appraiser turnover and sooner or later they are going to have to address the shortcomings ($$$) in the industry.
Seek the truth.
That’s on topic for sure. It’s one of the most interesting stats about the appraisal industry to surface in a long time. Undoubtedly a national trend. Does ASB even keep track or have any stats on this? The comptroller is supposed to provide oversight to everything, but they never do anything either. FHFA just launched a wire fraud mortgage fraud investigation to a single fed person, and overlooked the entire amc industry. Brilliant.
What an amazing end result of appraisal management companies influence. Free lunch every time an appraiser dies. They sent enough orders through to rubber stamp appraisers to profit over 12 billion collective dollars, and drove over 75% of the rest of the appraisers out of the mortgage lending and consumer protection spaces. One could also argue that amc’s prevented another hundred thousand appraisers from coming into existence. How many trainees would 12 billion in lost fees, and the hottest mortgage climate in history have brought forth? The answer under amc management is a negative number. Less than zero. The attrition continues.