Overview
Terraforming
As Fannie Mae moves toward privatization, the appraisal profession faces increasing pressure on independence, credibility, and control over valuation. While the industry continues to debate its direction, a solution has been developed over the past decade. That solution is complete and positioned to restore stability and strengthen the valuation process.
We present HARBOR, the Housing Appraisal & Risk-Based Oversight Registry. This is not a theoretical concept. It is a structural reset that replaces the fragmented oversight framework currently maintained by the Appraisal Subcommittee (ASC), The Appraisal Foundation (TAF), and state-level systems. In their current form, these entities operate without cohesion and lack consistent accountability.
Harbor establishes a unified federal framework for appraisal oversight, including a national license and the integration of advanced valuation AI. The objective is to improve stability, transparency, and accountability across the housing market while preserving the role and independence of the appraiser.
Day One Action Plan
🔹 Step One: Break the FFIEC–ASC Chain
Harbor begins by removing the Appraisal Subcommittee (ASC) from its embedded position within the Federal Financial Institutions Examination Council (FFIEC). Though the FFIEC created the ASC in 1989, its banking-centric authority has constrained innovation in the valuation space for decades. Severing this connection clears the way for Harbor to operate as a federal agency with independent oversight, no longer bound by outdated banking-era structures.
🔹 Step Two: End the State License Model
The 50-state license system is dismantled. Harbor establishes a single federal appraiser license, eliminating redundant CE systems, board politics, and jurisdictional red tape. Appraisers gain professional parity with CPAs, pilots, and other nationally credentialed roles, finally able to move, work, and grow within a unified framework designed for a national housing market.
🔹 Step Three: Reclaim the Federal Funding Arm
Harbor absorbs TAF not to preserve its structure, but to inherit its funding channel. This strategic move transfers control of federal appraisal oversight funds away from a private nonprofit and into a transparent, accountable agency structure. The result is a realignment of power, funding, and governance, all within a single public-facing system designed for long-term national stability.
Fannie Mae Full Cooperation
During federal conservatorship, Fannie Mae developed key valuation systems such as the Collateral Underwriter (CU), the UAD dataset, and internal AVMs under the authority and funding of the United States government. These tools are not private intellectual property; they are federally directed assets built with taxpayer support. Harbor asserts that all valuation models, datasets, and analytic platforms created during conservatorship are the property of the federal government and must be transferred to Harbor oversight as a condition of any transition to privatization.
This transfer is supported by legal precedent, including provisions in the Housing and Economic Recovery Act (HERA) of 2008 and federal procurement standards governing data and software rights. These frameworks require that systems created under federal conservatorship remain under federal control and cannot be retained, licensed, or repurposed for private use. As Harbor assumes national responsibility for appraisal oversight and valuation governance, these tools will be integrated into a unified federal infrastructure to ensure public assets serve public housing goals rather than private market leverage.
Harbor advises that any future GSE reform legislation include explicit mandates requiring the full transfer of all valuation-related systems, datasets, and scoring models to Harbor’s control. This provision will prevent continued influence by former conservatorship entities and ensure that all federally developed valuation infrastructure is permanently returned to the public it was created to serve.