PLAN FOR PROPERTY APPRAISAL AND VALUATION EQUITY

Over the past few years, stories have circulated about properties being appraised for less than typical market value. When the property is reappraised, after the homeowner removes all evidence of his or her blackness, the property appraises for market value.

On October 14, 2020, it was reported that an unnamed individual (Complainant) filed a complaint against JPMorgan Chase Bank, N.A. with the United States Department of Housing and Urban Development (“Department”), alleging Complainant was injured by discriminatory acts based on Complainant’s race in violation of subsection 804(a) and Section 805 of Title VIII of the Civil Rights Act of 1968, as amended (“Act”).

On February 4, 2022, the Consumer Financial Protection Bureau published a blog article warning of the possibility of discrimination in the appraisal process.

Now on March 23, 2022, the Interagency Task Force on Property Appraisal and Valuation Equity published an Action Plan to Advance Property Appraisal and Valuation Equity. The plan is available as an executive summary and a full plan.

The Interagency Task Force on Property Appraisal and Valuation Equity (PAVE) is composed of thirteen federal agencies and offices, including the federal financial institution regulatory agencies. PAVE is co-led by the U.S. Department of Housing and Urban Development (Secretary Marcia L. Fudge) and the White House Domestic Policy Council (White House Domestic Policy Advisor Susan Rice).

The Task Force has made commitments in five areas:

Category 1 – Strengthening Guardrails Against Unlawful Discrimination in All Stages of Residentials Valuation.

Category 2 – Enhancing Fair Housing/Fair Lending enforcement and driving accountability in the industry.

Category 3 – Building a well-trained, accessible, and diverse appraiser workforce.

Category 4 – Empowering consumers to take action.

Category 5 – Giving researchers and enforcement agencies better data to study and monitor valuation bias.

The objectives of the task force are in the discussion phase. We will watch for the reality. Much is expected.