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 Harbor Model: Where Appraisers Take the Helm - August 8, 2025
- FOIA, AI, & the Appraiser’s Defense: A Blueprint for Fighting Back - June 13, 2025
- WA Appraisers Stung by Fee Hikes and Veto - June 6, 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!
Hmm. Now thats interesting!