This note describes the provisions of the 21st Century ROAD to Housing Act related to single-family residential appraisals and appraisers (appraisers) and provides brief analysis. The note is based on the March 12, 2026, Engrossed Amended version of the bill passed by the Senate on that date.
Expanded FHA Appraiser Roster Eligibility
The bill would allow appraisers to be licensed or certified in one state or territory (state) and perform appraisals on Federal Housing Administration-insured mortgages (FHA) in all states if they meet certain conditions. These conditions include:
- meeting the requirements of the Uniform Standards of Professional Appraisal Practice (USPAP) competency rule before accepting an assignment; and
- meeting an FHA loan appraisal education requirement.
The courses for the education requirement can be provided by the FHA Secretary or a third-party approved by the FHA Secretary or state appraisal certifying or licensing agency under the bill.
The education requirement would not apply until at least 420 days after legislative passage – 240 days for the FHA Secretary to issue a mortgagee letter or guidance implementing the requirement, and then 180 days after that issuance.
This change would address FHA appraisal roster changes stemming from the 2008 Dodd-Frank Act and likely result in FHA appraisal roster requirements similar to pre-Dodd-Frank requirements.
Prior to the Dodd-Frank Act, the FHA appraisal roster regulation required residential licensure or residential certification (a higher standard) in one state and passage of a test on FHA appraisal methods and reporting. The Dodd-Frank Act and resulting HUD regulation eliminated FHA roster eligibility for licensed residential appraisers and required certification in every state in which an FHA loan appraisal was performed. The bill allows for licensed residential appraisers to perform FHA loan appraisals, and goes back to the one state requirement for licensure or certification.
For certified residential appraisers, the practical impact of the one state requirement is limited as most states provide for reciprocity – though appraisers who perform FHA appraisals in multiple states can potentially save on annual fees. For licensed residential appraisers, the bill opens up the FHA roster.
The bill language attempts to avoid some the disorderly transition of the Dodd-Frank Act changes. Instead of being immediately effective like the Dodd-Frank Act change, it only becomes effective after FHA guidance is issued. It provides a clear timeline for FHA guidance, whereas the HUD final rule implementing the Dodd-Frank Act change took 3 years.
As written, the FHA education requirement courses can be approved by either FHA or state appraisal regulators. It will be worth watching if that were to happen in practice.
With the explicit statutory reference to USPAP and the competency rule, it is possible that the Appraisal Foundation may create guidance concerning the competency rule for FHA loans. This would likely result in an additional expense for appraisers as the Appraisal Foundation monetizes updates to the USPAP standards and guidance.
Government Housing Agencies Added to Appraisal Subcommittee
The bill would add FHA, the Rural Housing Service of the Department of Agriculture, and the Veterans Administration to the Appraisal Subcommittee (ASC) membership.
This is a sensible and long overdue addition given these agencies involvement in residential appraisals, though it makes the construct of the ASC sitting under the Federal Financial Institution Examination Council (FFIEC) increasingly unwieldy.
Appraisal Subcommittee Fees on Appraisal Management Companies and Grants for Appraisal Workforce Development
The bill would allow the ASC additional flexibility in setting annual fees for appraisal management companies, subject to approval by the FFIEC.
The bill adds authority for the ASC to make grants to state appraisal regulators for appraisal workforce development and retention.
State Credentialed Trainees Added to National Registry and Permitted to Assist in Federally Related Transactions
The bill would add state trainees to the national appraisal roster managed by the ASC. The bill language makes clear that states are not required to implement trainee programs.
The bill would make explicit that trainees may assist state certified appraisers on federally related transactions, and that the certified appraiser is liable for the appraisal and valuation work performed.
Reconsideration of Value
The bill would require government and agency loans to have a reconsideration of value (ROV) process. The bill would allow FHA, USDA, VA, and FHFA to each implement its own reconsideration of value standards. The requirement would apply to any government or agency consumer-purpose, principal dwelling-secured loan.
Reconsideration of value was one of the policies promoted and expanded under the Property Appraisal and Valuation Equity Taskforce (PAVE). In truth, ROV processes existed on an ad hoc basis before PAVE, but without general standards. Arguably, ROV processes are already part of federal law under the Dodd-Frank appraisal independence requirements written into the Truth in Lending Act (TILA), 15 U.S.C. 1639e(c), and implemented in Regulation Z, 12 CFR 1026.42(c)(3). Because of the placement under TILA, a consumer’s exercise of a TILA-covered ROV is a protected right under the Equal Credit Opportunity Act, 15 U.S.C. 1691(a)(3), and Regulation B, 12 CFR 1002.2(z).
Appraisal Database
The bill would require a report from the General Accounting Office (GAO) on the feasibility of establishing a national public appraisal database 240 days after legislative passage, including FHFA, FHA, VA, and USDA data. After the report is issued, a Congressional hearing will be held.
Such a database was established by FHFA during the PAVE taskforce, but has ceased being updated under the current administration. FHA provided data to the database under the prior administration, but ceased doing so in the current administration. VA and USDA data were never included in the FHFA database.
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