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Saturday, June 28, 2025

HUD Slashes Appraisal Requirements, Increases Use of AVM Valuations by Mary Cummins Real Estate Appraiser


June 27, 2025 HUD Secretary Scott Turner released the below press release entitled "HUD Slashes Red Tape to Homeownership Financing Costs." Some of that red tape is related to home appraisals which made some appraisers happy. The press release linked below links to the June 27, 2025 Mortgage Letter which details the rescission of the appraisal requirements, i.e. "Rescission of Outdated and Costly FHA Appraisal Protocols." Some of these changes would disrupt the home loan markets. Below are a few of the changes.

This was crossed out. (I) Economic Life/Section 223(e)The Mortgagee must confirm that the term of the Mortgage is less than or equal to the remaining economic life of the Property.  Appraiser not longer has to include economic remaining life. This could be an issue if the loan is 30 years but remaining economic life of property is less than 30 years. This happens with some older homes in average condition not to mention older mobile homes. Older mobile homes generally can't get loans for this reason. I could see people walking from loans when they're underwater just like during the Great Recession. 

FHA Minimum Photograph Requirements. 

Only front and rear photos are needed. No more angled photos to show all four sides. Sometimes you really need to see all four sides. People generally don't repair the sides as much as the front. I always include photos of the sides whether they ask for them or not. It takes maybe five more seconds.

The street scene no longer has to include a portion of the subject. Then the street scene could be from anywhere and not subject's street. It doesn't take any extra time or effort to include a tiny portion of the subject on the side of the street scene. This doesn't save any time.

Attic and crawl space photos no longer needed. Sure hope someone inspects the attic and crawl space which can hide a lot of expensive damage and problems such as water damage, mold, roof issues, previous fires, original pipes, foundation issues... I've been in attics where I saw holes going to the outside, sagging roof supports, lack of insulation, burn marks, mold, mildew...that weren't caught in any inspection. While it's a hassle carrying a ladder to look in the attic I think it could be important. A head and shoulder view is all that's needed so you could use a stick to prop up panel and use selfie stick to take the photo. If it's no longer needed, I'm sure they'll reduce appraiser fee so while it may be less work, there will probably be less pay.

Photos of common areas of 2-4 units no longer have to be included. Photos of condo common areas also no longer needed. I've seen a lot of 2-4 units and condos with major deferred maintenance in the common areas. This could have a large effect on value especially considering the recent major condo issues with huge special assessments, inadequate insurance and zero replacement budgets. It only takes a few minutes to take common area photos.

Appraiser no longer has to comment on upward or downward future market trends in detail. This will be horrible if we head into another real estate recession like the Great Recession. The 1004MC form, also known as the Market Conditions Addendum, was introduced by Fannie Mae in November 2008 and became a requirement for all one- to four-unit property appraisals delivered to Fannie Mae and Freddie Mac starting April 1, 2009. It was created in response to the 2008 housing crisis to standardize the analysis and reporting of market conditions by appraisers. As it is it's not mandatory with many loans. I still use it to figure out general time adjustments besides AI.

This was crossed out. Additional Appraisal Requirements for 223(e) Mortgages (09/14/2015)  "223(e)" refers to a section of the National Housing Act that allows for the insurance of mortgages in older, declining urban areas where there is a need for affordable housing. This section specifically facilitates the purchase, repair, rehabilitation, or construction of properties in these designated areas." Many can't get these loans for good reason. The cost to repair the home is more than the final value of the home.  It's not a good investment for the government. The borrowers could end up under water and walk then we have another real estate recession. This has happened before.

Another part of the changes appears to be the increased use of AVM or robot valuations and analysis. Sounds to me like they will be reducing the use of live real estate appraisers. Appraisers shouldn't be so happy about this.

"During the first Trump Administration, HUD made targeted technology investments through FHA Catalyst that have substantially improved FHA’s collateral valuation analytics. As a result, FHA is now able to extend the benefit of these investments to borrowers, lenders, and taxpayers in the form of streamlined appraisal procedures, lower costs, and quicker turn times."

Maybe that's why they don't want attic and crawl space photos or angled photos. They can probably use Google robot street images. FHA had been building their own AVM for a few years now. Using AVMs instead of live appraisers increases the risk appraisal values are over actual market value. The borrowers who will use AVMs will have homes that have a market value lower than the actual market value. This will be older homes in poor condition with no upgrades on odd lots near busy roads and environmental hazards. Borrowers with upgraded homes in good condition on prime lots with good views would have values reduced to average or mean using an AVM. They would want a live appraiser and get a different type of loan. This means most valuations using AVMs would end up over actual market value except the most average newer tract homes.

This next part could be very problematic as it could allow construction in some flood zones. This will be a huge issue as the government unwinds FEMA and climate change increases. This is a big issue in Florida, Texas, the south. It has to do with building above the high tide line which has been rising for years. People shouldn't build in those areas because they will lose their home in the next storm and now FEMA won't even help them. Many areas in Florida are at risk of losing their roads and highways to sea level rise and storms.

"Rescinded the Federal Flood Risk Management Standard (FFRMS) for New Construction Eligibility. Rescinding the FFRMS restores the previous established policy, thus removing what would have been limits on the land available for development and eliminating increases in the cost of construction for FHA-insured single-family properties, which would have exacerbated the insufficient supply of affordable housing for the next generation of homebuyers."

Here's another troubling change. "Rescinded the Mandatory Pre-Endorsement Inspection Requirements for Properties Located in Presidentially-Declared Major Disaster Areas. Modifying FHA disaster inspection requirements aligns FHA’s policies with industry standards and allows lenders the discretion to assess property condition and determine appropriate risk-based actions prior to endorsement. This update reduces costly and unnecessary delays and will improve the bandwidth of home property inspectors that are often overwhelmed following a natural disaster."

I remember the 1994 earthquake in LA. I had inspections scheduled but no phone to contact clients to see if I should change the appts. My first two appointments were totaled by the earthquake. I later had to do reinspections for properties in the middle of financing to make sure they weren't damaged. Most were damaged. Not only that but values plummeted after the earthquake. Why would the government want to give the same loan amount to a property which is probably greatly devalued or worth almost nothing? The government has to bail out the loans and banks.

I see some red flag issues with these recent HUD changes. They will reduce the confidence in real estate appraisal valuations, home loans and the real estate market in general. It will also upset asset backed securities markets and the stock market. Lenders, banks will make a lot more money at the expense of the homeowner and US tax payer. Similar loosening of regulations and changes were made before the Great Recession which is what caused the Great Recession. History has a tendency to repeat itself. We don't seem to learn.

While HUD can make administrative changes on its own sometimes they need the approval of Congress to make major changes in housing programs and funding. Maybe there should be some oversight on these changes such as the Finance Committee. In this new era of the government making executive orders without any approvals, oversight or even investigation this will probably stand as is. 

"HUD Slashes Red Tape to Cut Homeownership Financing Costs
FHA eliminates 12 costly and burdensome policies in sweeping rollback"

https://www.hud.gov/news/hud-no-25-086

"Rescission of Outdated and Costly FHA Appraisal Protocols"
https://www.hud.gov/sites/dfiles/OCHCO/documents/2025-18hsgml.pdf

Marhttps://www.hud.gov/sites/dfiles/OCHCO/documents/2025-18hsgml.pdfy Cummins of Cummins Real Estate is a certified residential licensed appraiser in Los Angeles, California. Mary Cummins is licensed by the California Bureau of Real Estate appraisers and has over 35 years of experience.


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