The average price of homes has steadily outpaced Americans ability to save, leaving home ownership nearly impossible for first-time buyers. New regulations set to take place in 2026 could make matters even worse.
Determining a home’s true value has become very difficult, with appraisers feeling an extreme amount of pressure to get it right and being stuck in the middle of both the bank and potential homeowner, as neither wants to be stuck with a long-term liability, which could be financially catastrophic for a first-time home buyer.
Fortunately, appraisers undergo rigorous training, are regulated at both the state and federal levels, and are held to Uniform Standards of Professional Practice (USPAP), so case closed. Right? It’s all regulated, so there is no risk for subversion of the process without a state or federal referee throwing the flag.
Here is the rub: What if one of the referees is no longer making calls according to the rules of the game, or worse, is biased towards a particular outcome and begins exercising his or her influence to generate that outcome?
Now, what if his or her fellow referees decide to do the same? This is exactly the case with the Appraisal Subcommittee (ASC), a federal regulating body with oversight of all state jurisdictions and their subsequent regulation of appraisers. Many of us may see the value we currently have in our homes reevaluated and adjusted, not on the market but in favor of one perceived political constituency over another.
Unless the current administration acts quickly, the ASC will soon require mandatory training for all appraisers entitled “Valuation Bias and Fair Housing” (VB-FH). Effective January 1, 2026, this 7-hour course will be required by every appraiser in the country, with a 4-hour refresher every renewal thereafter.
Ostensibly, this course was intended only to ensure that all appraisers adhere to their professional standards (USPAP), while also providing additional training on the Fair Housing Act, enacted in 1968, which prohibits discrimination in housing based on race, color, religion, sex, disability, familial status, and national origin.
What’s not to like? As the adage goes, “the devil is in the details.” First, we must ask ourselves, why would this significant block of training be required when appraisers already have a mandatory 15-hour USPAP course, which covers all of their professional standards, to include the Fair Housing Act, not to mention a 7-hour USPAP refresher every renewal thereafter?
At the very least, the “Valuation Bias and Fair Housing” (VB-FH) training would seem duplicative. The next question that would immediately come to mind is whether there must be a robust justification for this additional emphasis, so what is it? Prior to the Trump administration, the justification offered by the ASC was that the Property Appraisal and Valuation Equity (PAVE) report suggests there is pervasive bias in appraisals.
If the PAVE report is directly linked to the “Valuation Bias and Fair Housing” training that will soon be required and its genesis was this pervasive bias, then there should be interest in the case studies. But there are no definitive long-term case studies.
Keep in mind, if there were case studies so pervasive and prevalent in nature that it would rise to wholesale training of the industry, wouldn’t the public have heard about this by now? Why is the Department of Justice, and its Civil Rights Division, tasked with enforcement of the Fair Housing Act, not prosecuting these cases where they exist?
And why are state jurisdictions reporting so few complaints about appraisal bias from homeowners? These are questions that many regulators asked in very sophisticated ways but are subsequently subjected to circular reasoning with the ASC and their proxy, the Appraisal Foundation, referring them back to the 2022 Biden-Harris Administration’s Interagency Task Force on Property Appraisal and Valuation Equity (PAVE) report born out of former President Biden’s Executive Order 13985 on “Advancing Racial Equity and Support for Underserved Communities Through the Federal Government.”
In other words, “Trust us. We know best.” In the absence of any recent case studies, there is often a pointing back to some of the practices of the industry prior to 1968, which led to the rise of the Fair Housing Act, as if there has been no improvement at all since then. You see the same from proponents of affirmative action who keep talking about present-day conditions as if we are still in the 60’s era. The people conflating the two periods are being intellectually dishonest by not acknowledging the contrast of the two or that any improvement has occurred. That is what is happening here.
The plot thickens. When very early in his tenure, President Trump issued Executive Order 14151, entitled “Ending Radical and Wasteful Government DEI Programs and Preferencing,” the 13 federal agencies that made up the interagency task force responsible for the PAVE report immediately scrubbed their websites of any mention of the PAVE report.
This action indicates that each of the agencies considers this report to fall within the realm of Diversity, Equity, and Inclusion (DEI) and therefore subject to this order, and by extension anything born out of this report would also be subject to the same order. What is most incredible is that the ASC, themselves, scrubbed any mention of the PAVE report from their own website, when they were up until recently incessantly referring to this report as the source and reason for the training, so they too would have considered it DEI until now.
Why is the ASC determined to ram this training through in clear violation of President Trump’s EO 14151, hoping that no one will notice? If there is no justification for the “Valuation Bias and Fair Housing” training because robust mechanisms already exist to address valuation bias, and any insistence at this point would be an illegal subversion of a lawful order, then why take the risk? There are many possibilities: hubris, greed, radicalization, etc. Take your pick, but the result will be indoctrination of every appraiser in the country, which will trickle down and have an impact on us all—a potential devaluation of many of our homes in favor of a constituency perceived to be in alignment with the Left.
Lately, we have read much about how federal agencies regularly act independently and circumvent lawful orders by use of proxies, or non-governmental organizations (NGOs). The Appraisal Subcommittee (ASC) is no different. They have tasked an NGO, the Appraisal Foundation, to “set the standards and qualifications that guide appraisers” and funnel them funds to that end.
As a result, all states are subject to the training requirements set by the Appraisal Foundation and its Appraiser Qualifications Board (AQB). When the Appraisal Foundation insiders were approached about the disconnect of eliminating all references to the PAVE report from agencies that sponsored it due to the President’s mandate requiring the elimination of DEI programs and preferencing, their response was that they were willing to forfeit the federal funding they were receiving. However, they are forgetting that their influence throughout the industry, which generates an enormous amount of money, is directly linked to their special relationship with the ASC and its delegation to them to “set the standards and qualifications that guide appraisers.”
The Appraisal Foundation’s authority is derived from the ASC as their proxy, not one extended to them directly from Congress. Given the Appraisal Foundation’s defiance, which shows outright contempt for the current administration, it may be time for the ASC to reconsider its relationship with the Appraisal Foundation.
Darkness flees the light. All it would take would be someone to spotlight this corruption and subversion, and I suspect the mandatory training would be immediately dropped. We have enough to worry about in this economy as it pertains to the affordability of home prices and the security of our investments.
We shouldn’t have to look over our shoulders because of corrupt government entities subverting the will of the people and their elected officials. We seem to be losing a lot of these types of battles right now with rogue elements within our own government, but this one could be an easy win for us all; however, we are against the clock. January 1, 2026, is just around the corner, and like Milton Friedman once said, “nothing is so permanent as a temporary government program.”
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Author: John Williams
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