Property Appraisal and Valuation Equity (PAVE)

On June 1, 2021, the 100^th anniversary of the Tulsa Race Massacre, President Biden announced the creation of an interagency initiative to combat bias in home valuations. This interagency initiative became the Task Force on Property Appraisal and Valuation Equity (PAVE). President Biden directed the PAVE Task Force to evaluate the causes, extent, and consequences of appraisal bias, and establish recommendations to root out racial and ethnic bias in home valuations. On March 23, 2022, the Task Force released the Action Plan to Advance Property Appraisal and Valuation Equity, which outlines the historical role of racism in the valuation of residential property, examines the various forms of bias that can appear in residential property valuation practices, and describes how government and industry stakeholders will advance equity through concrete actions and recommendations. For more information, visit pave.hud.gov.

A residential property appraisal is a written statement independently and impartially prepared by a qualified appraiser with an opinion of the market value of a home supported by the analysis of relevant market information. An appraisal is an important part of the homebuying process, as it establishes the value of the property to secure a home loan. Appraisals affect how much people make when they sell their home, how much people pay when they buy a home, and how much equity people can get out of their home when refinancing.

No. Title XI of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (Title XI) generally requires credit unions to obtain appraisals for real estate-related transactions regulated by the NCUA. In 2020, the NCUA amended its regulations to require credit unions to obtain appraisals when originating residential real estate loans of $400,000 or more. Loans for less than $400,000 generally require written estimates of market value instead of appraisals. While written estimates of market value do not have to be issued by state-licensed or -certified appraisers, they must still be issued by individuals with qualifications and experience to perform such estimates.

If you believe that your appraisal is too low, talk to your loan officer or contact the appraiser directly. Federal law allows a mortgage lender, mortgage broker, mortgage banker, real estate broker, appraisal management company, employee of an appraisal management company or any other person with an interest in a real estate transaction to ask an appraiser to do one or more of the following:

1. Consider additional, appropriate property information, including the consideration of additional comparable properties to make or support an appraisal.
2. Provide further detail, substantiation, or explanation for the appraiser's value conclusion.
3. Correct errors in the appraisal report.

Under Title XI, the Appraiser Qualifications Board (AQB) establishes the minimum education, experience, and examination requirements for real property appraisers to obtain a state license or certification. The AQB issues the Real Property Appraiser Qualification Criteria.

Appraisal discrimination is illegal under federal law and prohibited by professional appraisal standards. The Fair Housing Act and the Equal Credit Opportunity Act prohibit appraisers from discriminating against you. If you think you have been discriminated against, you can file a complaint with the state agency that regulates appraisers. To find out which agency to notify, contact the Appraisal Complaint National Hotline. The hotline doesn't handle complaints but will refer you to the appropriate authority. You may fill out a form on the website or call the toll-free number at 1.877.739.0096.

You may also file a complaint with a state or federal financial regulatory agency if you think your lender discriminated against you by relying on a biased appraisal. To submit a complaint against your credit union, please contact the NCUA’s Consumer Assistance Center or call 800.755.1030. You may also contact the Consumer Financial Protection Bureau at https://www.consumerfinance.gov/complaint/ or call 1.855.411.2372.

The U.S. Department of Housing and Urban Development administers the Fair Housing Act which makes it illegal for appraisers to discriminate. You may file a fair housing complaint directly with HUD's Office of Fair Housing and Equal Opportunity, online at www.hud.gov/program_offices/fair_housing_equal_opp/online-complaint or by calling 1.800.669.9777.