Terraforming
As the appraisal profession observes Fannie Mae's move towards full privatization, many of us feel that something much larger is slipping away: our independence, credibility, and control over valuation itself. While discussions about the future continue, a dedicated group has spent the last decade developing a solution.
We present HARBOR—the Housing Appraisal & Risk-Based Oversight Registry. This is not merely a theoretical concept or a think tank; it represents a structural reset in appraisal oversight. Harbor aims to replace the fragmented and outdated valuation framework currently maintained by the Appraisal Subcommittee (ASC), The Appraisal Foundation (TAF), and a mix of state boards. In their existing state, these entities enforce complexity without cohesion and oversight without genuine accountability. The era of polite suggestions is over. Harbor is not about seeking permission—it’s about correcting course with a focus on a more effective appraisal oversight system, helping to establish a robust environment for the federal appraisal license and the integration of valuation AI.
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this connection clears the way for Harbor to operate as a federal agency with independent oversight—no longer bound by outdated banking-era structures.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
For years, GSEs and private entities have extracted appraisal reports—copyrighted professional work—to train their own AVMs, only to use those models to replace appraisers outright. Harbor reverses that equation. Under Harbor, AVMs are reclassified as federally regulated valuation tools, ensuring enhanced appraisal oversight. Models like those used by Fannie Mae’s Collateral Underwriter are brought into public control, and transparency is enforced. The UAD dataset, inspection data, and AVM output now serve the public—not just the enterprise. Importantly, Harbor introduces the first valuation AI that attributes authorship to the appraisers whose work built the data layer. Appraisers are credited, tracked, and—where appropriate—compensated. This initiative aligns with the need for a federal appraisal license to protect and recognize the contributions of appraisers. The era of silent data extraction ends here.