A Power Grab in Plain Sight
The Bill They Hope You Never Read
H.R. 1625 (Senate Bill S.1635) isn’t about modernization, it’s about control. Behind the polished language lies a federal structure designed to remove the independent appraiser from the mortgage process entirely.
Section 2 of the bill creates a nationwide appraisal database, pulling in every report since 2017 and mandating public, downloadable access to appraisal-level data. This includes the appraiser’s name and ID, AMC and lender information, comp selection, adjustments, reconciliation commentary, and even borrower race and ethnicity. But an appraisal was never meant to be a public document, it is a confidential communication between the appraiser and the lender for a specific assignment.
This bill breaks that boundary.
And for many appraisers, the insult goes further: the data being taken has already been extracted, repackaged, and sold without consent, often by systems that appraisers themselves helped create or feed under duress. Now H.R. 1625 attempts to codify that theft under federal law and call it “access.”
It grants sweeping authority to an unnamed “Agency,” empowering it to expand data collection and issue binding regulations without returning to Congress. It opens the door for full, unredacted access by nearly every federal and state enforcement body.
No appraiser helped write this. No protections exist for the people doing the work. But if this passes, appraisers will be regulated, surveilled, and eventually replaced, without ever being asked.
It’s outrageous. It’s unacceptable. And it must be stopped.
Your Work. Their Database.
Every appraisal you’ve completed since 2017 is now on the table, and if H.R. 1625 passes, those reports may no longer belong to you.
Even more concerning: every appraisal you complete going forward could be automatically claimed as federal property, with or without your consent.
The bill creates a searchable federal repository that strips authorship, opens your work to public scraping, and invites exploitation by automated systems and third parties with no duty of care. This isn’t oversight, it’s seizure.
Harbor takes the opposite approach. It preserves appraiser authorship, enforces strict data boundaries, and prevents mass harvesting. Even as a federal system, Harbor is built on the principle that professional work product belongs to the professional, until willingly shared. That’s the difference.
The bill mandates the creation of a publicly accessible, searchable database containing every report submitted through FHA, VA, USDA, Fannie Mae, and Freddie Mac. This includes not just future reports, but your past work, retroactively scooped into a federal archive.
And that work? It isn’t just “data.” It’s your intellectual property, your analysis, your commentary, your adjustments, and conclusions. H.R. 1625 treats that original work as if it belongs to the government. It doesn’t.
The bill demands granular appraisal-level data: your name and license ID, your AMC and lender, the property address, inspection scope, comp selection, adjustments, reconciliation, and written narrative. It even includes borrower race and ethnicity, sale concessions, property rights, and any other datapoints the Agency decides to add later.
The stated goal is transparency. The real goal is to extract your expertise and feed it into the very systems designed to replace you.
You’re not being asked. You’re being harvested.
H.R. 1625 doesn’t just overstep, it tramples on fundamental legal protections. Your appraisal report is protected intellectual property under federal copyright law the moment it’s written, yet this bill attempts to seize that work and make it public without consent or compensation. That alone raises serious Fifth Amendment concerns under the Takings Clause.
It also violates the confidentiality standards of USPAP, which treat the report as a private communication between appraiser and client, not a public dataset. Worse, the bill enables the government to harvest your adjustment methods, reasoning, and commentary, proprietary valuation logic that could be reverse-engineered and repackaged by AVMs or enforcement agencies.
It’s not modernization, it’s misappropriation under the color of law.
⚖️ Potential Legal Challenges to H.R. 1625
1. Takings Clause, Fifth Amendment
When the government demands surrender of your appraisal reports, intellectual property, without compensation, it may constitute an unconstitutional taking.
- In Ruckelshaus v. Monsanto Co. (1984), the Supreme Court recognized that trade secrets submitted to the EPA could trigger Fifth Amendment takings protection.
- Scholars argue that forced disclosure of copyrighted professional work, like appraisals, could similarly invoke this protection under the Penn Central framework Idaho State Bar.
2. Inverse Condemnation & Ripeness, Knick v. Township of Scott
This landmark case reversed the prior requirement that plaintiffs exhaust state remedies before filing a federal takings suit.
- That means a direct federal lawsuit may now be filed promptly once the taking occurs, without delay or bureaucratic roadblocks. https://en.wikipedia.org/wiki/Knick_v._Township_of_Scott,_Pennsylvania
3. Copyright & Professional Work
Appraisal reports, complete with narrative explanations, adjustments, and reasoning, are creative works protected under copyright from the moment they are written.
- Courts have enforced copyright protections against unauthorized reporting or reprinting of similar professional content (see Wainwright Securities v. Wall Street Transcript Corp., 1977) WikipediaWikipedia.
4. Privacy & Professional Confidentiality (USPAP)
While not a federal statute, USPAP mandates that appraisal reports remain confidential between appraiser and client. Public release of appraisal files undermines this core professional standard, and could form the basis for regulatory or civil action.
🔷Contact Details🔷
Legislative Bill History
The Appraisal Modernization Act of 2025 was first introduced in the U.S. House of Representatives by Rep. David Scott (D GA), Ranking Member of the House Financial Services Committee. The bill was presented as a reform package designed to expand the use of automated valuation models (AVMs), streamline appraiser licensing across states, and broaden federal waiver authority.
After clearing the House, the measure was reintroduced in the U.S. Senate under the designation S.1635. Sen. Kevin Cramer (R ND) agreed to carry the legislation forward, giving it bipartisan traction in the upper chamber. From that point, the Act began its journey through Senate committees, positioned as the companion to the House version and framed as part of a broader housing finance modernization agenda.
Together, these two tracks H.R. 1625 in the House and S.1635 in the Senate represent the current legislative push to overhaul appraisal standards, regulatory oversight, and the role of AVMs in mortgage lending.
The Unnamed Agency
The Appraisal Modernization Act of 2025 is written with broad and vague language, much like Dodd-Frank. That earlier law left room for AMCs to insert themselves into the valuation process, and we risk seeing history repeat itself. Instead of giving appraisers a clear role, the bill creates openings where undefined powers can later be filled in by regulators or private actors with financial interests that do not align with housing integrity.
The bill references an “agency” that will oversee modernization but never explains who or what that agency is. This is not a small detail. By leaving the structure blank, the bill invites future interpretation that could hand critical authority to organizations outside of federal oversight. That omission means the implementing body could just as easily be an AMC, a coalition of AMCs, or a newly created entity modeled on the AMC framework.
Appraisers know from experience what that would mean. AMCs already control the ordering pipeline, collect large administrative fees, and push liability onto individual appraisers while insulating themselves from accountability. Giving that same group control under the label of an unnamed “agency” would centralize appraisal management in the hands of profit-driven middlemen rather than independent professionals.
By drafting the bill in such vague terms, Congress avoids debate over who really benefits from these reforms. The risk is that once passed, the law can be interpreted to serve private interests rather than the public, placing appraisers in an even weaker position. Without naming the agency or defining its role, the bill leaves the door wide open for an AMC-dominated model disguised as modernization.
Contact Action Plan
These are the key Senators to contact regarding the Appraisal Modernization Act. Each serves on the Senate Banking Committee or holds influence over housing and financial policy. We narrowed our outreach to these members because of their direct role in reviewing S.1635 and shaping how appraisal oversight will be structured going forward.
Tell them you and 65,000 other appraisers stand with the Harbor model.
- Senator Tim Scott (R-SC)
Senator Scott is the Ranking Member of the Senate Banking Committee, giving him direct authority over legislation tied to housing finance and banking reform. His leadership position ensures that he can set priorities for the minority caucus, making his voice essential in shaping or stopping provisions within the Appraisal Modernization Act. Contact Senator Scott
- Senator Thom Tillis (R-NC)
Senator Tillis has been highly active in financial regulation debates, especially those involving housing and lending practices. His record shows a willingness to engage with bipartisan reforms, but also a caution toward unchecked regulatory growth. Because he often negotiates compromises, contacting him is vital to ensuring appraisers’ concerns are not lost in the process. Contact Senator Tillis
- Senator Mike Crapo (R-ID)
As a former Chairman of the Senate Banking Committee, Senator Crapo brings years of institutional memory and influence over housing finance law. He has historically taken a strong stance on how federal housing programs operate and how oversight agencies are structured. His role as a senior statesman on the committee makes him a key figure to influence. Contact Senator Crapo
- Senator Cynthia Lummis (R-WY)
Senator Lummis has emerged as a sharp voice on financial oversight, particularly in areas where federal regulation intersects with state economies. She sits on the Banking Committee and has expressed interest in ensuring transparency and fairness in financial systems. Her independent streak and focus on accountability make her an important contact regarding hidden agency structures in the Act. Contact Senator Lummis
- Senator John Kennedy (R-LA)
Senator Kennedy is known for his blunt approach to fiscal and regulatory matters. On the Banking Committee, he often presses witnesses and regulators about accountability, government overreach, and unintended consequences of legislation. His skepticism of vague or overly broad laws makes him a strategic point of contact on this bill. Contact Senator Kennedy
- Senator Bill Hagerty (R-TN)
Senator Hagerty brings a business-minded perspective to financial policy, emphasizing growth and reducing regulatory burdens. With a background in both finance and international markets, he is attentive to how federal housing policies affect economic expansion. His focus on regulatory balance makes him important to appraisers concerned about being displaced by unchecked automation. Contact Senator Hagerty
- Senator Kevin Cramer (R-ND)
Senator Cramer is engaged in housing and finance legislation as part of his committee role. He has taken positions emphasizing the protection of rural and smaller housing markets from one-size-fits-all federal policies. His attention to fairness in regulatory application makes him an important voice when discussing how the Appraisal Modernization Act could centralize power in an unnamed agency. Contact Senator Cramer