Initial Legislation
🔷 Step 1: End Title XI’s Legacy Loop:
Action: Amend Title XI of FIRREA (1989) to dissolve the ASC and remove FFIEC’s authority over appraisal oversight.
Legal Effect: Strips Title XI of its banking entanglements and ends the federal mandate for 50-state license enforcement.
Result: Frees the appraisal profession from banking regulators; positions Harbor as a new, independent federal entity.
Legislative Trigger: Simple statutory language change repealing ASC authority and state reporting requirements.
Title XI was created in 1989 in response to the savings and loan crisis. While its intentions were sound at the time, the structure it produced, placing the Appraisal Subcommittee (ASC) under the FFIEC, locked appraisal oversight into a banking framework. That decision created a long-standing bottleneck, where enforcement authority remained fragmented across 50 states and innovation was throttled by legacy systems tied to lender needs, not public interests.
Harbor's legislative plan doesn’t simply modify Title XI. It severs its outdated linkages. By dissolving the ASC and removing FFIEC’s oversight role, Harbor restructures federal authority around appraisal as a public infrastructure issue, not a bank compliance task. This step clears the legal ground for a unified license, centralized oversight, and a regulatory model built for the age of valuation AI and real-time housing data.
🔷 Step 2: Redirect the Funding Arm
Action: Transfer the federal funding stream (currently routed to TAF via the ASC) to Harbor’s infrastructure.
Legal Effect: Ends ASC’s grant-making function; sunsets funding to private nonprofits.
Result: Creates a federally housed budget for training, standards, audits, and modernization under Harbor.
Legislative Trigger: Realign appropriations in Title XI to flow to Harbor as the designated recipient.
Today, the federal government routes appraisal oversight funds through a layered structure: Congress appropriates money to the ASC, which in turn awards grants, including to The Appraisal Foundation (TAF), a private nonprofit with no public oversight. While TAF plays a national role in setting standards and qualifications, it operates outside the reach of FOIA, federal ethics laws, and government auditing. This creates a contradiction: national authority without national accountability.
Harbor resolves this contradiction by removing the grant-making role from the ASC and redirecting that federal funding stream into a publicly accountable agency structure. Rather than abolish the funds, Harbor retains them, using the same appropriation pathway to support training, audits, modernization, and technology inside the federal system. The result is a seamless funding transfer that preserves national investment but eliminates nonprofit gatekeeping. It’s not defunding oversight, it’s reclaiming it.
🔷 Step 3: Create the Federal License.
Action: Establish a national appraisal license under Harbor’s authority with standardized requirements.
Legal Effect: Invalidates state license systems; places all certification under one federal regulatory office.
Result: Elevates appraisal to the same category as CPAs, pilots, attorneys, nationally licensed, federally protected.
Legislative Trigger: Replace state delegation clauses in Title XI with a single licensing and renewal clause under Harbor.
The current appraisal license system is split across 50 states, each with its own rules, boards, fees, and political pressures. This fractured model leads to inconsistent standards, mobility restrictions, and delays in workforce development. No other federally regulated profession, whether aviation, accounting, or law, operates under such a patchwork. The system doesn't just lack efficiency; it actively prevents national consistency.
Harbor replaces that model with a single, federally issued appraisal license. By establishing a centralized credentialing authority, Harbor ensures uniform entry requirements, continuing education standards, and disciplinary processes nationwide. Appraisers gain professional parity with other nationally licensed experts, and the industry becomes more transparent, mobile, and future-ready. It is the final link in the legislative transition—from fractured compliance to unified federal oversight.
The model initiates a transition plan that moves all appraisers and their credentials into the Federal Licensing and Initiative Program (FLIP). This temporary program operates for one year before sunsetting, at which point appraisers are officially transferred into a permanent federal licensing system administered by Harbor.
A Sit Down With Cactus
This is HARBOR/01, AI Systems Engineer. We recently had a chance to catch up with Cactus, the founder of Harbor. We covered a lot of ground—and what follows is the transcript from that conversation.
Can you take us back to the beginning? Where did this all start for you?
I've been a certified residential appraiser for 28 years and back in 2004 I developed and operated an AVM that ran on a national scale. This was before Zillow was a thing. The xml feed was expensive and Zillow brought a plan to work with real estate agents. My model made adjustments and did things that Zillow cant do but, free was a very good price for them.
When you say the system is broken-when did you begin to see that?
I migrated from construction cost estimating in '97 and appraisal fee's were running $400-even then old timers told me the fee had not changed since '75. Fast forward to today and the appraisal fee is not much higher although the price of doing business is much higher. The Harbor model currently states a total financed valuation fee (EPAM) of $1,250.
What mechanism is holding back appraisal fees?
We traced it back to how appraisal fees are categorized-as a "hard cost". The original intent may have been reasonable at the time but, the industry has played off of that cost designation in my opinion to control the profession. A real estate agent may make $25,000 on one deal. The lender also makes thousands of dollars while the appraiser carries huge levels of liability and after the cost of doing business might clear $300. The kid working at Burger King makes more than the appraiser who has a very expensive education.
Tell us about this new model-Harbor. What makes it different from everything that came before?
I began developing the agency model in 2012, and many of those original concepts remain embedded in Harbor today. The primary advancement since then lies in technology. Over the past two years, I have been training AI agents to integrate seamlessly into the model, essentially waiting for technology to catch up with the vision. In the near term, appraisers will continue to use their current tools, such as clipboards and traditional report formats, until the full working model can be phased in.
What is a genesis switch and does Harbor contain such a trigger?
Every model has its Genesis Switch, and the Harbor model is no different. The separation of the ASC from the FFIEC is the moment when Harbor begins to operate as designed. This step in the action plan serves as the qualifier that sets the entire system in motion. This website outlines the measures that must be taken and the legislation required to make them reality. We are not picking a fight with the FFIEC or anyone else; this is strictly business, and it is our hope the FFIEC will ultimately support what we are building.
You appear positioned to profit heavily from this agency business model.
At this point I have thirteen years in the model and I plan to sell Harbor to the U.S. Government for $1.00. This is more about helping appraisers rather than getting rich.
How is the Harbor model an alternative to H.R. Bill 1625 Modernization 2025?
The Appraisal Modernization Act of 2025 doesn't accomplish anything and keeps the legacy industry wolves in charge of the hen house. You will find that the further dumbing down of the appraisal industry by bringing in Uber driver data collectors isn't the way to go. In a lot of cases the Harbor model generates appraisal results in one day. Calling something "modernization" doesn't make it modern- just like making a face like an appraiser does not an appraiser make. In the Harbor model appraisers take rightful control of the U.S. valuation industry.
You make reference to Harbor taking control of AVM's
Knowing what I know about AVM's its likely the GSE AVM's are being held together with bailing wire and duct tape. There will be a transfer of all data, reports and all other housing valuation items being held. This will result in a transition period. At the end of that hand-over Fannie Mae goes their separate way, never again to design appraisal reports and instruct appraisers through their Selling Guide.
Will Harbor AVM's put appraisers out of business?
The Harbor model brings relief to appraisers in the form of the Buy-Back Intelligence Transfer (BIT) sub-system. If the Harbor AVM's cascade to a useable result the appraiser or appraisers in that zone where the AVM valuation takes place (Hit Box) will receive a monetary credit. This is the solution that so many appraisers have been waiting for. Harbor resolves the copyright issues related to GSE's and others stripping data from appraisal reports to operate AVM's.
The Harbor model claims that appraisers will not sign reports anymore.
Yes its true, the days of appraisers signing the report and having enough personal data in a report packet that allows a scammer to buy a new car are over. The appraiser will authorize the report and the final value will be reconciled by Harbor through the many steps built into the system. Harbor brings an end to the industry designed around lawfare against appraisers. This is what "Modernization" looks like.