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FHA Seeks Public Comment Regarding Minimum Property Requirements

II. The Blind Spot: Lender and AMC Coercion of Appraisers


This Request for Information (RFI) completely misses a structural reality: appraisers are


routinely pressured, blacklisted, and threatened by lenders and AMCs to completely


ignore or remove MPR deficiencies.


• The Intentional Deletion of Guardrails: MPR policies exist precisely to prevent the


exact catastrophic outcome seen in the baseline case: an avoidable foreclosure.


However, because lenders and AMCs operate under volume-driven profit models,


they view MPR compliance as a threat to their loan volume.


• The Threat of Economic Retaliation: When an ethical appraiser notes a critical


environmental or structural hazard (such as a septic system contaminating a water


source), the lender or AMC frequently demands the deletion of the deficiency. If the


appraiser refuses, they are retaliated against by being removed from panel rosters or


denied future assignments. This coercion forces the systemic erasure of property


defects before the loan ever reaches HUD underwriting.


• Recommendation: FHA's modernization must strengthen Appraiser Independence


Requirements (AIR) by implementing severe, mandatory civil penalties for any


lender or AMC executive found to have pressured an appraiser to modify or omit an


MPR defect. Furthermore, FHA must create an anonymous, expedited reporting


portal directly linked to the HUD Office of Inspector General (OIG) for appraisers to


flag compliance coercion.
I've lost a ton of FHA business due to realtor pressure. For several years I would run out and immediately inspect any FHA assignment I received so the realtors didn't have a chance to make the lender cancel it after they found out who the appraiser was going to be. And when they tried to anyway, I would tell the client that I would report that FHA case number to HUD along with a list of defects that I found and the most probable reason that the assignment was canceled from me. And that HUD would certainly flag any further originations from them for enhanced review. Clients that did that pissed me off, and I didn't care if I never received another assignment from them anyway. Unfortunately, realtor pressure on lenders to use number hitters and "blind to defects" appraisers is still alive and well. I don't work for many AMCs, so I can't speak to that issue.
 
I've lost a ton of FHA business due to realtor pressure. For several years I would run out and immediately inspect any FHA assignment I received so the realtors didn't have a chance to make the lender cancel it after they found out who the appraiser was going to be. And when they tried to anyway, I would tell the client that I would report that FHA case number to HUD along with a list of defects that I found and the most probable reason that the assignment was canceled from me. And that HUD would certainly flag any further originations from them for enhanced review. Clients that did that pissed me off, and I didn't care if I never received another assignment from them anyway. Unfortunately, realtor pressure on lenders to use number hitters and "blind to defects" appraisers is still alive and well. I don't work for many AMCs, so I can't speak to that issue.
I heard that FHA tracks the amount of repairs each appraiser calls for. And the more repairs that the appraiser calls for, the higher their score card is with FHA. Its the exact opposite of what realtors, loan officers and lenders want. No wonder there are vast amount of appraiser who refuse to touch a FHA appraisal. It just shows you the massive amount of BS in this business and in the end everyone blames the appraiser. No wonder they are doing everything possible to get rid of us.
 
This week I was contacted by the 3rd lender an owner is trying to get an FHA reverse mortgage from. I suspect the primary issue is that the owner painted flakeboard subfloors and is resistant to my calling out need for installation of finish flooring, since she doesn't want to pay for it. So here we go again. Can you imagine how much more expensive it would be if there's a bunch of water spilled on a portion of that flooring and it bulges up, flakes off, and becomes un-level? The lady is clueless. There are reasons for FHA condition requirements.
 
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I heard that FHA tracks the amount of repairs each appraiser calls for. And the more repairs that the appraiser calls for, the higher their score card is with FHA. Its the exact opposite of what realtors, loan officers and lenders want. No wonder there are vast amount of appraiser who refuse to touch a FHA appraisal. It just shows you the massive amount of BS in this business and in the end everyone blames the appraiser. No wonder they are doing everything possible to get rid of us.
Why would a scorecard matter with FHA?
 
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FHA INFO 2026-13
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June 23, 2026

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FHA Slashes More Red Tape to Promote Homeownership Affordability
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Today, the Federal Housing Administration (FHA) published its next sweeping set of policy updates for its Single Family mortgage insurance program executed through a series of Mortgagee Letters (ML). These 14 individual updates, launched as part of HUD’s recognition of National Homeownership Month, are designed to reduce costs, mitigate risk, and make mortgage credit more accessible for prospective American homebuyers with FHA-insured mortgages in accordance with President Trump’s Executive Order Promoting Access to Mortgage Credit.

These updates bring the total to more than 150 streamlining measures taken in the FHA Single Family program since the start of the Trump administration.

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.
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Date: June 23, 2026 Mortgagee Letter 2026-10 To: All FHA-Approved Mortgagees All Direct Endorsement Underwriters All Eligible Submission Sources for Condominium Project Approvals All FHA Roster Appraisers All FHA-Approved 203(k) Consultants All FHA-Approved Title I Lenders All HUD-Certified Housing Counselors All HUD-Approved Nonprofit Organizations All Governmental Entity Participants All Real Estate Brokers All Closing Agents Subject Purpose Effective Date Affected Programs Background Updates to FHA Quality Control Requirements for Appraisal Field Reviews This Mortgagee Letter (ML) updates FHA quality control (QC) requirements to allow greater flexibility and alternatives to appraisal field reviews. The provisions of this ML are effective immediately. All updates will be incorporated into a forthcoming update of the HUD Handbook 4000.1, FHA Single Family Housing Policy Handbook (Handbook 4000.1). The provisions of this ML apply to all FHA-insured mortgage programs. FHA has identified an opportunity to allow greater flexibility in its QC policy for Property and Appraisals by removing the requirement for Mortgagees to obtain appraisal field reviews on at least 10 percent of origination and underwriting QC reviews. The update makes field reviews an optional component of appraisal QC, maintaining FHA’s core appraisal compliance framework while giving Mortgagees the ability to tailor review methods based on case-specific risk. www.HUD.gov Mortgagee Letter 2026-10, Continued FHA’s previous appraisal field review requirement resulted in significant costs for Mortgagees, which often outweighed the limited risk mitigation benefits considering the frequent use of third-party tools and appraisal desk reviews. By making field reviews optional, FHA is removing a potential barrier to Mortgagee participation in FHA programs, as well as an expense that may be passed indirectly to consumers. In compliance with President Trump’s Executive Order, Promoting Access to Mortgage Credit, this change aligns FHA more closely with appraisal QC standards already adopted by the U.S. Department of Veterans Affairs and the mortgage industry generally. Summary of Changes FHA Single Family Housing Policy Handbook 4000.1 Quality Control, Oversight, and Compliance This ML: • updates requirements in Property and Appraisals (V.A.3.c.ii(C)). The Handbook 4000.1 sections impacted by this ML are provided in Attachment 1, with changes tracked in redline to help users clearly identify the policy requirements being revised or removed from the Handbook. The policy changes will be incorporated into Handbook 4000.1 as follows: Property and Appraisals (V.A.3.c.ii(C)) (1) Standard (a) Property and Appraisal Reviews For all FHA-insured Mortgages selected by the Mortgagee for origination and underwriting QC review, the Mortgagee must evaluate all Property documentation and the appraisal report used to support the Property Value and eligibility for FHA insurance. At a minimum, the Mortgagee must review all Property documentation and the appraisal report for completeness, technical accuracy, and overall quality in compliance with Property Acceptability Criteria for Forward Mortgages (II.A.3.a), Property Acceptability Criteria for Reverse Mortgages (II.B.4.a), and Appraiser and Property Requirements for Title II Forward and Reverse Mortgages (II.D). The Mortgagee should use valuation tools, Automated Valuation Models (AVM), multiple listing service data, public records data, and any other appropriate methods to identify potential valuation errors or other compliance issues. 2 Mortgagee Letter 2026-10, Continued (b) Field Reviews The Mortgagee may obtain appraisal field reviews if needed to adequately assess the appraisal report for compliance with all applicable requirements. Field reviews must be performed by Appraisers listed on the FHA Appraiser Roster and must be reported on the applicable Residential Appraisal Field Review Report form or report. (2) Exceptions [Text was deleted in this section.] Mortgagees are not required to perform the property and appraisal QC review (V.A.3.c.ii(C)(1)(a)) for Streamline Refinances where the Mortgagee was not required to order a new appraisal for a Property financed with an FHA-insured Mortgage. (3) Required Documentation The Mortgagee must retain all results from the property and appraisal QC reviews required by this section, including any reports from valuation tools or appraisal field reviews. Results include all selection criteria, review documentation, Findings, and actions taken to mitigate Findings.
 
Let's make them optional before we are forced to release the over 2,000 documents requested in the FOIA request that proves we were not requiring them in the first place - HUD Voice
 
It's disheartening..... no matter what appraisal thread I read, it's about side stepping what's to be reported, what's to be inspected, who's to do the appraisal, where is the appraisal is being conducted from, rules, regulations, certifications, being eased or redacted to ease up on the AMC machine, and push the valuation forward to make the loan.

No matter how you slice it and dice it, we're doomed....
 
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