Thank you for posting this important proposal about this overlooked topic matter. Sorry for not getting to this sooner. I had initially created an account here for this exact issue. Please see the multiple links where many appraisers have been writing about these issues.
As a certified real estate appraiser myself, fully agree. Myself and tens of thousands of other appraisers like myself are right now being railroaded out of our lifetime careers by the incompetent managers and corrupt influences in the mortgage lending sector. From the amc’s (appraisal management companies), to the recently passed 'avm final rule) where lenders will now bypass independent appraiser checks and balances and rubber stamp every deal, to the bought and sold appraisal trade groups, and ever predatory lending interests, the mortgage system has problems.
We talk about this quite a bit on an appraisers focused website, which unlike other industry publications is not bought and paid for by mortgage and amc interests.
Serious problems in housing and they way they’ve ‘modernized’ the lending system. This is one of the most important issues of our time, the fundamental reasons behind a never ending housing affordability crisis, spiraling inflation as multiple rounds of QE (quantitative easing is constantly buried in housing), pulling the levers of power.
I’ll que you into something most people don’t know. Social credit scoring is already present in mortgage loan handling. Google patent; US8775300B2, and that’s just the tip of the iceberg. Heat maps and cluster maps, character identification types, locational restrictions. That’s social credit scoring. Forget FICO.
The popular author Jeremy Bagott talks about this and he has an X account if anyone cares to get a weekly summary on all the problems the mortgage system is experiencing as a result of the sidelining of appraisers, and the appraisal trade groups constant violations of administrative procedural rules.
Please can someone help? When Bill Pulte took over the FHFA recently, stepped in and fired senior GSE management, we appraisers had high hopes he would roll back the avm final rule, put an end to the new UAD complex digitized new appraisal forms, stop the censorship of appraisers, reign in the corrupt amc industry, and revitalize a once vital real estate appraisal profession. Then all he did was made the bureaucrats go sit in their chairs again and nothing actually changed. No meaningful GSE corrections as long as the full service independent real estate appraiser is absent. FNMA ‘Wholesale lending’ program continues to sweep mountains of loan default under the rug un noticed. The amc industry continues to control the appraisal industry, it’s a complete racket. Freddie continues to push censorship of appraisers speech unabated without any meaningful resistance. Independent checks and balances systems have been replaced with avm automation (automated valuation models). You’ll just have to trust the lenders and investors that broke the system and plundered the hell out of everyone a hundred times over through history, will be magically trustworthy now that they have even more centralized control and even less oversight.
The fraud is undeniable and nobody does anything about it. Rather we dealt with a socialist exercise to bring forth what was called ‘valuation equity’ in place of a free market. Biden era policy which implemented a DEI focused complete restructuring of the appraisal industry, called the PAVE task force. An insider play from mega corps which allowed them an excuse to circumvent decades of regulatory structure and oversight, remove independent appraisers, automate everything with black box internal controls instead. Although the executive order on removing DEI focused content from government happened, and the PAVE website is taken down, nearly every single policy change and goal of the PAVE task force has been rushed into and adopted by the mortgage lending system. The DEI is baked into the process now.
It’s the GD wild west in mortgage lending right now. They’ve already eliminated most appraisers, installed 98% loan to value appraisal waivers across the board, allow amc companies to dominate mortgage lending and blacklist everyone whom disagrees, junk fee raking billions of dollars from consumers is now a legal billing practice from amc’s, appraisal industry heads are bought and paid for, support every proposed stake holder proposal. Unlicensed home inspectors called PDC’s or property data collectors. LIDAR scanning technology is being placed in everyones private spaces when they get a loan, and that data is being sold and shared to unscrupulous companies in clear violation of GLB Gramm-Leach-Bliley act act on consumer privacy.
An entire generation of young people are priced out of residential housing and nobody is actually doing anything about it. The presence of the full service real estate appraiser prevented untold volumes of fraud. And now that we’re gone and sidelined from GSE lending, appraiser licensee headcount falling rapidly, hundreds leaving every month, there has been an acceleration of fraud in mortgage markets. It’s one big insider give away. They’ve completely circumvented a substantial portion of previously implemented regulatory restrictions and controls. There are clear correlations that every time the appraisers position is further diminished, fraud increases, pricing skyrockets, and the system becomes less stable.
Pull the twins congressional charters immediately. Force the Treasury and Federal Reserve players to divest from purchasing MBS mortgage backed securities instruments, stop burying qe and inflationary policies in housing, stop firesale give aways to insider investment and banker interests. Save the real estate appraisal industry.
As amc’s are embroiled in class action lawsuits, have lost class action lawsuits in the past, are barely skating by a serious CFPB investigation which was just opened before the CFPB was slated for shut down, have a clear and verifiable track record of having committed many felonies from wire fraud to deceptive trade practices to restriction of trade practices, to underhanded back room deals, and raking over twelve billion of not far more in unearned junk fee billing practices from mortgage lending consumers. When is enough enough? At what point will someone stop playing along with the unethical practices?
Bill Pulte, Mr Trump, DOGE, Mrs Warren, anyone, please, will someone please help save the independent real estate appraisal industry?
