The real estate appraisal industry faces significant scrutiny regarding its regulatory framework and governance. Recent reports and ongoing lawsuits highlight systemic failures, including unethical practices and opaque self-regulation within key appraisal organizations. These issues extend beyond internal disputes, directly harming consumers through hidden fees and anticompetitive behavior in real estate finance. The lack of meaningful public oversight continues to threaten the stability of the housing market.
The Appraisal Regulation Compliance Council (ARCC) operates as the only independent academic research center dedicated to exposing these systemic risks and advocating for licensing reform. We spoke with Josh Tucker, co-founder of ARCC, to discuss the organization's latest findings. In this interview, we examine the push for transparency and how evidence-based research can protect the American consumer.
Ǫ: Recent investigations highlight significant governance failures and unethical practices within the appraisal regulatory structure. How did ARCC first identify these systemic issues?
Josh Tucker: After Dodd-Frank, appraisers had acquired and reported substantial evidence of unfair and deceitful practices due to the regulatory inaction in the form of emails, suppressed fees, and vendor agreements. These documents showed violations of appraiser independence, TILA, and FIRREA. But a cohesive reference of the events did not exist and as reported by individual appraisers in the field, there were no improvements post Dodd-Frank. Many argue it has gotten worse.
My position at the time gave me a unique view of this regulatory landscape. By late 2023 and 2024, appraisers began sending the data directly to me. At the same time, Lori Noble, successfully brought appraiser license law reforms to the forefront and worked at the Knee Regulatory Research Center at West Virginia University. Her knowledge of licensing law drew her to the data for academic research.
Once an identified systemic pattern was identified, we created ARCC to continue the research and begin outreach to address the profession's broader regulatory issues. Appraisal regulation is complicated and inefficient in its current state. State appraisal regulatory programs vary considerably across the country and performance. Some boards are composed of appraisers and attorneys, while others operate under state insurance departments or professional and occupational licensing agencies. Enforcement and oversight also vary by state. ARCC's research has identified instances that raise concerns about regulatory capture, including situations in which appraisal management company (AMC) representatives or affiliated interests may influence decisions affecting the industry.
State appraisal laws also differ significantly across all states. At the federal level, the Appraisal Subcommittee is responsible for monitoring state programs to help ensure compliance with Title XI and applicable federal requirements. Continued improvements in oversight and accountability remain an important policy issue. Former Consumer Financial Protection Bureau Director Rohit Chopra publicly expressed interest in the Appraisal Subcommittee's oversight role and met with representatives of ARCC as part of the Bureau's broader examination of appraisal and mortgage market practices.
Ǫ: A recent lawsuit filed by ARCC volunteer Board Member Dr. Cindy Chance raises questions about inappropriate relationships and hidden fees involving appraisal management companies. How do these hidden fees directly impact the average homebuyer?
Josh Tucker: ARCC's research found that many consumers are charged a single appraisal fee on their mortgage disclosures without a separate accounting of the amount paid to the independent appraiser and the amount retained by the appraisal management company (AMC). ARCC estimates that undisclosed AMC fee retention and markups cost consumers more than $12 billion over the past five years.
Limited fee transparency makes it difficult for consumers to understand the cost of appraisal services or compare charges among lenders. Because many lenders require payment of the appraisal fee early in the mortgage process, these costs may also increase the upfront financial burden for prospective homebuyers.
Ǫuestions surrounding appraisal fee disclosures are now being examined in multiple lawsuits. Hilgers Graben PLLC has filed three proposed class actions alleging that consumers were charged bundled appraisal fees without adequate disclosure of the amounts retained by appraisal management companies. The cases include one filed in California and two filed in Florida, including one in federal court. The allegations remain pending, and the defendants have not been found liable, the cases are listed in the references below.
References
- Appraisal Regulation Compliance Council (ARCC). Regulatory and Academic Briefing Memo.
- Appraisal Regulation Compliance Council (ARCC). AMCs Rigged the Appraiser Supply Chain: Hiding :12 Billion in Fees.
- Timmins v. ClearCapital.com Inc., Core Valuation Management Inc., and Rocket Mortgage LLC (California proposed class action).
•Arnold v. Appraisal Nation LLC, AMC Links LLC, and United Wholesale Mortgage, LLC. (Florida proposed class action).
Bernholtz v. Cross Country Mortgage, LLC et al. and Class Valuation, LLC (Florida proposed class action in the federal U.S. District Court for the Middle District of Florida)
Ǫ: You noted that opaque self-regulation with no public oversight leads to terrible outcomes. What specific regulatory reforms do ARCC believe are most urgent to fix this system?
Josh Tucker: ARCC believes the most important reforms are straightforward and focused on transparency.
First, mortgage disclosures should separately list the amount paid to the independent appraiser and the amount retained by the appraisal management company (AMC).
Consumers should be able to see who received their money and what services were provided.
Second, lenders should provide consumers with a copy of the appraiser's invoice as part of every residential mortgage transaction. This practice is already used in the U.S. Department of Veterans Affairs loan program and provides a clear record of the appraisal cost.
Third, ARCC believes oversight of AMCs should be strengthened. State regulatory structures vary widely, and many agencies have limited resources to monitor increasingly complex appraisal management operations. Improving oversight and accountability as mandated would promote consistent enforcement, increase public confidence and best protect consumers.
Ǫ: ARCC reported evidence to federal regulators showing consumer damages exceeding
:12 billion in hidden fees. How does your organization gather and verify this level of financial data?
Josh Tucker: ARCC's research began with appraisal records voluntarily provided by licensed appraisers. Those records show the fees offered to appraisers by appraisal management companies. ARCC then compared those amounts with the appraisal fees charged to consumers and combined the information with appraisal volume data from the Federal Housing Finance Agency's Uniform Appraisal Dataset (UAD).
Using that methodology, ARCC estimated that consumers paid more than $12 billion in appraisal management company fees and markups over a five-year period. The estimate is limited to transactions included in the FHFA dataset and does not include private lending,
portfolio loans or construction lending. As a result, ARCC considers the estimate conservative. The underlying federal dataset has not been updated since the end of 2024, so the estimate reflects the most recent data available at the time of the analysis.
The Appraisal Foundation's 2026 workforce report also notes that appraisal fees paid by consumers often include both the appraiser's compensation and the appraisal management company's fee, and that the average fee in 2010-2011 was $400 per report with today’s average reported as $425. In terms of purchasing power of the dollar the profession is compensated less per file today than 15 years ago when Dodd Frank became law. This should be a major red flag for regulators.
Ǫ: Fellow co-founder Lori Noble has a history of advocating for the removal of unfair barriers to entry in the appraisal profession. Why is removing these barriers crucial for the future of the industry?
Josh Tucker: ARCC believes expanding the appraisal workforce begins with reducing unnecessary barriers to entry while maintaining professional standards.
West Virginia was an early leader in this effort. The state adopted legislation directing the West Virginia Board of Registered Professional Real Estate Appraisers to recognize the minimum qualification criteria established by the Appraiser Ǫualifications Board (AǪB) for licensure. The law was intended to reduce unnecessary state-specific requirements while preserving national standards.
Following initiatives led in West Virginia and similar discussions in other states, The Appraisal Foundation established its State Harmonization Task Force in 2025. The task force works with state regulatory agencies to identify licensing requirements that exceed the AǪB's minimum criteria and to encourage greater consistency among the states.
ARCC believes that aligning state requirements with nationally recognized minimum standards can reduce the cost and time required to enter the profession while maintaining public protection. ARCC also supports reviewing state laws and regulations that unnecessarily limit the services licensed appraisers may perform in favor of unregulated alternative products that many lenders rely on. It doesn’t make any sense to prevent the most qualified individuals from performing these alternative products. Removing barriers that are not required by federal or state law can help strengthen the appraisal workforce and improve access to valuation services.
Ǫ: ARCC conducts nonpartisan, evidence-based research for policymakers. How can political leaders use your findings to enforce laws and protect the integrity of real estate finance?
Josh Tucker: Our mission is to provide this nonpartisan, evidence-based research that helps policymakers evaluate existing laws, identify regulatory gaps and consider reforms that improve transparency, accountability and consumer protection.
Our role is to gather and verify data, analyze trends and provide objective information to legislators, regulators and the public. We prepare state-specific research, review proposed legislation and explain how federal and state laws affect consumers, appraisers and the mortgage market.
Many policymakers are unfamiliar with how the appraisal system operates. ARCC's research is intended to help them make informed decisions based on documented evidence rather than anecdotal information. We welcome opportunities to provide research, answer questions and serve as an educational resource for public officials.
ARCC's research focuses on structural issues within appraisal regulation and appraisal management company oversight. By documenting industry practices and measuring their impact on consumers and the housing market, ARCC provides policymakers with independent research that can inform legislative and regulatory decisions that benefit society.
The organization's goal is to support transparent, competitive and accountable real estate markets through research, education and public policy analysis.
For more information, visit ARCC at https://arcc-usa.org and ARCC can be reached at info@arcc-usa.org.
