Three Comps and a Guess

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1. Six federal regulators, the CFPB, OCC, FDIC, NCUA, Federal Reserve and FHFA, issued a joint final rule on July 17, 2024 imposing quality control standards on automated valuation models used to value homes in mortgage lending, as required by the Dodd-Frank Act.Federal Reserve Board press release · 2024-07-17
2. Under the AVM rule, institutions must adopt policies designed to ensure a high level of confidence in AVM estimates, protect against data manipulation, avoid conflicts of interest, require random sample testing and reviews, and comply with nondiscrimination laws.Consumer Financial Protection Bureau · 2024-08-07
3. The AVM quality control final rule was published in the Federal Register on August 7, 2024 (89 FR 64538) with an effective date of October 1, 2025.Federal Housing Finance Agency · 2024-08-07
4. Regulators warned that because a single AVM can process a very high volume of valuations, bias embedded in such a model could cause widespread harm even though algorithms involve less human discretion than appraisals.Consumer Finance Monitor (Ballard Spahr) · 2024-07-02 · medium confidence
5. FHFA announced that Fannie Mae and Freddie Mac would raise the maximum loan-to-value ratio for purchase loans eligible for appraisal waivers from 80% to 90%, and for inspection-based appraisal waivers from 80% to 97%, meaning many buyers get no traditional appraisal at all.FHFA news release · 2024-10-28
6. The expanded appraisal waiver rules were announced on October 28, 2024 by FHFA, Fannie Mae and Freddie Mac and took effect for purchase transactions in the first quarter of 2025.HousingWire · 2024-12-18 · medium confidence
7. Freddie Mac said its automated collateral evaluation (ACE) tool, which uses proprietary models, historical data and public records in place of an appraisal, has saved borrowers $1.63 billion in appraisal fees.HousingWire · 2024-11-04 · medium confidence
8. Alongside the waiver expansion, FHFA and HUD released FHA appraisal data to broaden the Uniform Appraisal Dataset, which is used to screen appraisals for potential errors or bias and had previously covered only Fannie Mae and Freddie Mac loans.Scotsman Guide · 2024-10-28 · medium confidence
9. President Biden launched the interagency Property Appraisal and Valuation Equity (PAVE) task force on June 1, 2021, the centennial of the Tulsa Race Massacre, bringing together 13 federal agencies to examine racial and ethnic bias in home valuations.PAVE (HUD) · 2022
10. HUD announced in 2025 that it was streamlining the appraisal process and effectively disbanding the PAVE task force, citing American Enterprise Institute data attributing appraisal gaps to factors such as educational attainment, credit score and family formation rather than race.U.S. Department of Housing and Urban Development · 2025 · medium confidence
11. In a widely cited Marin City, California case, a Black couple's home was appraised at $995,000 in 2020 and then valued at $1,482,500 weeks later by a different appraiser after a white friend posed as the owner.San Francisco Chronicle · 2023-03-06
12. Paul Austin and Tenisha Tate-Austin settled their federal housing discrimination suit against appraiser Janette Miller for an undisclosed sum, with the appraiser admitting no liability but agreeing to anti-discrimination training.CBS News · 2023-03-08
13. Court documents in that case stated that three of the six comparable properties the appraiser used were not comparable except for being located in Marin City, including one bank-owned foreclosure sale from two years earlier.NPR · 2023-03-09
14. Zillow reports a nationwide median error rate of about 1.9% for Zestimates on homes actively listed for sale but roughly 7% for off-market homes, the situation most homeowners are in when they look up their value.Independent analysis of Zillow and Redfin published accuracy data · 2026 · low confidence
15. A University of Chicago sales-ratio study found property tax assessments in Wayne County, Michigan were regressive, with 73% of the lowest-value homes over-assessed compared with 49% of the highest-value homes.University of Chicago Center for Municipal Finance property tax data project · medium confidence
16. Philadelphia Fed research concludes that inexpensive houses are systematically over-assessed relative to expensive ones nationwide, attributing about 60% of the residual regressivity to assessors' flawed valuation methods and 40% to infrequent reappraisal.Federal Reserve Bank of Philadelphia
17. An independent study of Cook County, Illinois assessments from 2014 to 2016 found a regressive system causing a wealth transfer from owners of lower-value homes to higher-value homes, and reported that more than 90% of the values produced by the assessor's models were changed by hand before noticesProPublica Illinois · 2018 · medium confidence

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