Hi there. It’s all good Edwin. Although obviously AI, the content was excellent. Looks like a sound legal argument. But where is the actual lawyer to enforce any of it? AI is draining resources like nobodies business but does nothing for the regular person whom deals with the beaurocracy. Rules and guidance don’t mean anything if nobody respects or follows them in the first place, and there is no effective enforcement mechanism. I put forth a long piece about that in the latest article, the one with the plane flying, check that one out. Have to run. Have a good one. Thanks.

Interesting content. Obviously AI generated. The bottom line is…

Nobody in power whom could effect the needed change is going to listen. They don’t care about the law or the truth.

That’s the thing AI systems do not understand and never will; The human condition.

These decisions came down the pipeline by way of peer pressure, emotional decision making, the inherent bias of those holding the levers of power whom are racist themselves, entitled from decades of sitting in advantaged positions. They wanted to use whatever mechanism was available to browbeat and pressure appraisers into doing what they want, and they got their way. The intimidation is not illusionary. The class is now mandated and your license is tied to it. Until the class goes away, their position stands as affirmed. The legal argument is now irrelevant from an individual point of view, you take it or you lose everything. The people whom staged this have not been reformed and never will be.

From a practical perspective; I’ll just take the class online, click through to the test as fast as possible, and write down the correct answers for anything I get wrong. Then I’ll click through again lightning fast, get the passing cert, and be done with it. These days I’m able to get uspap done in less than two hours, I think I came close to a single hour last time around. Define; content mastery. It’s that way for most of the classes from the big box stores. They rake tens of millions a year in continuing education fees, and spend most of their working hours and efforts chasing down continued class approval, in each individual state. This creates a repetitive cycle where the same classes are reformed and repackaged with quite similar content, under a different class label, and sent back for re approval on an individual basis, again, and again, and again. If anyone actually gave a hoot about the quality of continued education they would immediately create a national approval standard so ce providers would not be burdened by the state by state individual approval requirements. They don’t want that. They enjoy the fees and income generated by the bureaucratic process. They have enriched themselves with the ability to repackage content and resell it indefinitely.

None of it matters. The rules are formed around the institutional interests. Consumer protection is a long forgotten side note. The appraisal license is now rendered merely a symbol of having paid to play, an access card or concert ticket. The only people still taking this seriously are those of deficient intellect whom can not see what is obviously right in front of them. Fraud and favor trading rules the day in ‘appraisal’. Now we get the pleasure of a never ending series of insider interests training seminars ‘teaching us’ how to use their wares to further their cause. Qualified CE baby. Approved and rubber stamped on command. ‘Appraisal modernization’. Appraisal independence is DOA.

The heart of the problem is the cultural issues. You can thank fake news media and the corporate power structure that backs them for that. What’s happened in the appraisal industry is a side note, but one piece on the board. Part of the larger play to disassemble the constitution, bill of rights, and sovereignty of this country, what fragmented strands are left anyways. My question to the purveyors of the required anti bias appraisal classes; ‘When do the real deportations start?’ There is nothing left to lose, this industry already fell too far. Make a better living and have far more independence with lawn mowing and landscaping. You pay to play and do what you are told or you do not survive anywhere near GSE lending and federally regulated transactions. You know; Where consumers are at whom need consumer protection from predatory lending activity. Screw those guys, they are a resource to be exploited. What do you think the illegal and legal migration issue is all about in the first place? E.X.P.L.O.I.T.A.T.I.O.N. Now you know.

The Legal Backbone — and How to Submit
Valuation-bias / Fair Housing CE has drifted onto the wrong side of the law. Here’s why, in one page — and exactly where to send your account.
Prepared by Edwin Farr, MAI, MS-RECM · Global Appraisal LLC · for the NCDOT class allies · July 2026
The six pillars (this is the whole argument)
1. NC law now bars it — HB 171. HB 171 (effective July 1, 2026) prohibits any State agency — the NC Appraisal Board included, by the statute’s own definition of “board” — from requiring DEI training. The one exception is genuine antidiscrimination-law compliance. A course that skips the actual legal standard and teaches “a disparity proves discrimination” is not compliance. It is the prohibited kind. The label doesn’t decide it — the content does.
2. The federal tide is going out — disparate impact. HUD proposed removing the disparate-impact regulation (24 C.F.R. § 100.500) in January 2026. The mandate our CE rode in on is being pulled back at the federal level.
3. The law never said “disparity = discrimination.” Disparate impact under the Fair Housing Act was never “an imbalance exists, therefore guilt.” The Supreme Court (Texas Dept. of Housing v. Inclusive Communities, 2015) built in three guardrails our class taught none of:
• a robust causality requirement — the plaintiff must prove a specific policy causes the disparity, not merely point to a statistical gap;
• a legitimate-interest defense — for us, valuing on real market evidence. A USPAP-compliant appraisal is that legitimate interest, which shields a compliant appraiser from a frivolous complaint or HUD abuse;
• a less-discriminatory-alternative step, reached only after the first two — and therefore never even in play here, because the class taught neither of the first two.
4. It collides with USPAP. The ETHICS RULE demands impartiality and objectivity and bars letting race affect value; STANDARDS RULE 1 requires credible results drawn from market evidence — the market as it is. A course that nudges values toward a social outcome trains us to violate USPAP, not comply with it. And it runs headlong into a second command — the ETHICS RULE states that an appraiser “must not advocate the cause or interest of any party or issue.” Directing an appraiser to build race or identity outcomes into the scope of work is compelling that forbidden advocacy: it turns a neutral valuation into an instrument for a social cause, which is exactly what USPAP prohibits.
5. It’s compelled speech — First Amendment. The State may teach a course, but it cannot make affirming a contested political belief the price of your license. Since West Virginia v. Barnette (1943) government cannot force a citizen to profess an opinion, and NIFLA v. Becerra (2018) held that a professional license does not forfeit that protection — the State cannot conscript licensees to carry its message. Courts are now drawing the same line for mandatory DEI training — lawful instruction is fine, but “forced acceptance or adoption” of the government’s views is not (Henderson v. Springfield, 8th Cir. en banc, 2024) — and that line applies with equal force when the coercion runs through a license instead of a paycheck. So a required Fair Housing course that teaches the disparate-impact theory while omitting its three guardrails is not neutral education — it is compelled, misleading political instruction, unconstitutional at both the state and federal level.
6. No discrimination means NO discrimination. For six decades, discrimination has been read one way — treating someone worse. That is only half the law. Discrimination is differential treatment by innate characteristics (race, sex, etc.): not worse, not better, just different. The moment race is weighed in a decision where one party gains, the choice is zero-sum — in the Supreme Court’s own words, “a benefit provided to some applicants but not to others necessarily advantages the former group at the expense of the latter” (Students for Fair Admissions v. Harvard / UNC, 2023). Pick a winner by race and everyone else is a loser by default. “Eliminating racial discrimination means eliminating all of it.” That is exactly what the law forbids — whether the thumb is on the scale for or against:
• Federal — the Equal Protection Clause (14th Amendment); Title VI of the Civil Rights Act of 1964 (42 U.S.C. § 2000d); and the Fair Housing Act, which bars racial discrimination in real-estate transactions and names the appraising of residential real property by statute (42 U.S.C. § 3605).
• North Carolina — our own Constitution: “nor shall any person be subjected to discrimination by the State because of race, color, religion, or national origin” (Art. I, § 19) — plus the State Fair Housing Act (N.C. Gen. Stat. Ch. 41A).
A curriculum that tells appraisers to weigh race for a favored outcome is not curing discrimination. It is committing it. These bodies must be held to the law they are sworn to follow.
Bottom line: This isn’t ideology. It’s that the required course is out of step with current state law, the First Amendment, the federal direction, the actual Fair Housing standard, and our own professional standards. We were in the room. Our first-hand account carries weight no op-ed can.
What to say (10 minutes, your own name, your own words)
Keep it short and factual. A strong submission is three sentences:
1. “I am an NC-credentialed appraiser and I completed the required Valuation Bias & Fair Housing CE in spring 2026.”
2. “The course taught [what you personally heard] — e.g., that a value difference between differently-composed neighborhoods is itself evidence of discrimination and grounds for a HUD complaint.”
3. “That framing conflicts with HB 171, with the Inclusive Communities causality standard, and with the USPAP ETHICS RULE and STANDARDS RULE 1. I’m asking you to remove non-real-estate-based concepts from required CE, qualifying education, and criteria, and return the standard to valuing property on market evidence.”
Sign with your name, credential, and license number. First-hand is the whole point — say what you heard.
Where to submit — the three bodies
1. NC Appraisal Board — the state regulator now bound by HB 171.
• Email: ncab@ncab.org — for a rules/CE comment, also copy Legal Counsel Sondra Panico (Legal@ncab.org) and Executive Director Donald Rodgers (Don@ncab.org).
• Mail: 5830 Six Forks Road, Raleigh, NC 27609 · 919-870-4854.
• Also: public comment is taken at Board meetings (agenda posted at ncappraisalboard.org).
2. The Appraisal Foundation (TAF) — author of USPAP and the Qualification Criteria.
• USPAP / Appraisal Standards Board: ASB@appraisalfoundation.org (or the ASB comment form at surveymonkey.com/r/ASBComments).
• Qualification Criteria / Appraiser Qualifications Board: AQB@appraisalfoundation.org — and a live exposure draft is open now. Comment on the Second Exposure Draft of the Real Property Appraiser Qualification Criteria at surveymonkey.com/r/AQBComments by July 27, 2026. This is where the required Fair Housing course lives — the most direct vehicle this month.
3. Appraisal Institute (AI) — our designation body.
• No public comment inbox. Submit through the contact form at appraisalinstitute.org/contact-us and ask that it route to Government Relations / External Affairs (Washington, DC). HQ: 200 W. Madison, Chicago, IL 60606.

https://youtube.com/shorts/HxAtSiGuV1M?si=7JUDVo9OYbKmVYiC

With 3% down and now OPTIONAL (as in never just like optional AMC fee disclosure) FHA field reviews instead of the now required 10%, what could possibly go wrong.

I also love how FHA quotes inflated field review fees of $425 when we all know AMC’s steal 50 to $75% of that.

Today, FHA issued the following MLs:

Updates to FHA Quality Control Requirements for Appraisal Field Reviews. Through this ML, FHA is making field reviews an optional component of the appraisal quality control (QC) process. FHA previously required mortgagees to obtain appraisal field reviews on at least 10 percent of their origination and underwriting QC samples. By making field reviews optional, FHA is maintaining its core appraisal compliance framework while giving mortgagees greater flexibility to tailor review methods based on case-specific risk.

Appraisal field reviews represent one of the most expensive quality control components of the lender appraisal review process, with an average cost of $425 per field review. FHA estimates that eliminating this requirement will save industry partners approximately $3.3 million annually, meaningfully improving the cost structure for FHA lending.

Seek the truth.

Quite similar exploitation of workers by trade groups and associated ‘managers.’ Along with quite similar mis management from the very top of industry managers. Except instead of appraisal, in associated industry of property preservation and field management services (reo). If you ever wondered why the reo clean up job was so dang inadequate. At the heart of it all; Appraisal management companies whom also service these industries.

I’d like to say only in real estate but that’s sadly not true.

The ‘franchise model’. Where independence dies and exploitation goes next level.

A similar model is now being levied by the same companies, using PDC services.

I’m right there with you. I haven’t done an appraisal in one year this month. I put pencil to it a few months ago. Figured at my typical fees with AMC’s which are about the same (in absolute dollars) I was making 25-30 years ago, I was doing appraisals for about $150-$175 in year 2000 dollars. And, with all the expanded costs in all aspects and the added liability with a whiny, litigious public, there is simply no point in continuing. I had a few banks that ordered appraisals from me for awhile and paid decent/good fees, but they all went with AMC’s and the fees went down. Losing battle.

Huh?

Do you ever feel like the appraisal trade groups are not fairly representing the working appraisers?

Edwin, where did you hear or what evidence do you have about a possible 12% settlement rate? If you have any article I could read or other information let me know, I would like to see that for myself. Ken

Worhit, I dont believe so. Though I havent done any research on active or recent cases yet. It seems most attorneys either dont want to get involved or if they do, they are in such high demand, its effectively supply-restricted. I have heard the rumor that only ~12% of the HUD complaints have been settled and that all of those have been cash settlements and no findings based on merit, which reminds me of the ADA shakedowns in small downtown commercial spaces in the 1990s… Perhaps a FOIA request to HUD is in order to see exactly what they are doing with these allegations.

At its core, the appraisal process requires us to analyze the market as it actually exists, not as we wish it existed. Every day appraisers make judgments based on buyer preferences, market segmentation, school districts, property characteristics, location influences, and countless other factors that affect value. The concept of the “typical buyer” is not something appraisers invented for convenience; it is a fundamental component of market value analysis. Without understanding who is actually buying a property and what drives their purchasing decisions, it becomes difficult to explain why one feature contributes to value while another does not.

What I found particularly interesting is the discussion regarding the safeguards established in Inclusive Communities. Whether one agrees with every conclusion in this paper or not, the point regarding robust causation, legitimate business justification, and less discriminatory alternatives deserves serious discussion within the profession. Those safeguards are part of the legal framework and should be understood by appraisers just as thoroughly as the theories that create potential liability.

As someone who has personally spent years under investigation related to appraisal bias allegations, I believe the profession benefits from open discussion of these issues. Bias should never be tolerated, and legitimate discrimination complaints should be investigated. At the same time, appraisers should not be placed in a position where they are expected to ignore market behavior, buyer preferences, or supported market evidence simply because the results may be uncomfortable. Our role is to analyze and report what the market is doing, not to engineer outcomes.

The long-term health of the profession depends on maintaining that distinction. The answer is not less analysis or less transparency. The answer is better-supported analysis, stronger documentation, and a clear understanding of both USPAP requirements and the legal standards that govern fair housing enforcement. Appraisers serve the public best when they remain independent, objective, and committed to reporting the market as it exists.

I doubt that most of them can even read at a fourth-grade level, much less, understand anything about how valuation works.

Blame the AMC’s? Yeah, OK, but I blame the people who started the AMC’s. Remember who was President? I do. Barney is dead, but I don’t know about Dodd. But, that was a dose of poison we’ll never get over. Even with Trump in for a year and a half, the woke pathology is only getting worse.

To the powers that be, there is no such thing as “local” or “reality” except as they define it. I recognize what’s going on, but I can’t say it here or anywhere else. It will expose itself eventually, but maybe not before I’m dead and gone. Nope, I’m no conspiracy “theorist”, simply an observer of big forces outside of the appraisal industry.

Next time call it a “mosque” and see if you get the same reaction.