There is no small difference between appraising to fannie's guidelines for secondary market and appraising an in-house loan for a local bank using a fannie mae form. As subtle as it may be, and let's for argument's sake, say that you fill out the new fannie form for secondary market and use the old fannie form for in house lenders. And otherwise you fill them out identically. What's the difference? First, you are unlikely to get any feedback whatsoever with the in house appraisal. If the comps are distant, dissimilar or over 6 mo. old...you'll hear nothing from the conventional bank. Cost app. or not. No questions. Secondary market? First, they won't like not having a sale within 1 mile. They won't like any sale over 6 mo. old. They won't like 2 sty compared to 1 sty or any log, berm, or other specialized construction. The in house bank? Nary a word in all probability. Secondary market will want more forms. Will want everything marked "average" will want "suburban"...no rural. There is not one part of the report they won't weasel on. This, of course, is supposed to protect fannie, freddy, and all those chinese investors. Does it do what it intends? Quite the opposite. The conventional lenders are the ones who are NOT hurting. Who DOES check the credit history of their clients and those clients live LOCALLY. The report serves to fill their files, confirm the values, and not as a vehicle to shift lending responsibilities off on appraisers. So? Can one conclude that strict lending guidelines like fannie mae's- standard of the secondary market- makes loans safer? I conclude it makes them less safe than the conventional lender. The appraiser who is free to pick what they think is the best comparable (regardless distance, style, or age of sale) will more accurately determine the market value of a property over the appraiser who, at every step of the process, is trying to make the report conform to those magic guidelines of the UW's, who themselves are clueless how much harm they are doing the appraisal process. True appraiser independence will start when fannie mae is no longer in charge of developing our appraisal forms...and no longer is authorized to substitute their judgments for ours. It is like a civil engineer being told by a state highway political appointee what size steel to use or how much concrete to use in building a bridge or how large the supports should be in a tunnel structure. Until we reach the point of true independence in the appraisal process, all the underwriters, reviews, laws, regulations, etc. are for naught.