Real Estate Appraisal & Valuation

Quick Takeaways on Property Appraisals

The National Association of REALTORS® encourages independent, credible valuations, recognizing them as an essential component of the real estate industry.
Appraisers, as valued members of NAR, help shape policy and inform other REALTORS® on issues impacting appraisals and valuations.

NAR Policy on Appraisals

What is a Property Appraisal?

Appraisal and valuation are extremely important steps in any home buying and/or selling transaction. A professional appraiser will use the information on the home and current housing market to provide an appraised value, which is very important to the home loan process. There are different methods to valuing a home, and the value of the home is often not the same as the price or cost.

Property Appraisal Resources for REALTORS®

NAR Provides members with a great deal of appraisal resources and benefits. Appraisers can create a professional website, participate in NAR governance, receive two appraisal related designations, General Accredited Appraiser (GAA) and Residential Accredited Appraiser (RAA), and access other benefits. We also highly recommend the use of RPR, The REALTORS® Property Resource®.

National Association of REALTORS® members (appraiser or otherwise) are invited to join us for the regular Supporting Your Value Webinar Series to hear updates from the experts.

The National Association of REALTORS® also supports appraiser independence. Please read our Appraiser Independence Page and our Responsible Valuation Property Policy for our complete stance.

The agent/appraiser relationship is an important one, and NAR has multiple resources for REALTORS® to improve communication between the two. Please visit the Agent/Appraiser Communication Resources Page to find resources to help.

Appraisal Management Companies (AMCs) are an option for lenders and appraisers to consolidate the process of obtaining a home appraisal. NAR supports the regulation of AMCs through FIRREA, the Financial Institutions Reform and Recovery and Enforcement Act.

See References for more information.

Featured

Appraisal Process Report

report

December 18, 2025

In October 2025, NAR surveyed its members about the recent use of data collectors in the valuation process. Requires member login.

Appraisal Issues Survey

report

December 19, 2025

This report focuses on the impact of appraisals on the current market and member business. Requires member login.

Residential Appraisal Process - FAQs for Agents

This brochure will help you provide guidance to your clients clarification regarding the residential appraisal process.

Appraisal Data Collectors: What You Should Know

Some appraisal management companies (AMCs) now send “data collectors” to take video, pictures, and measurements of properties instead of an appraiser.

Advocacy

What is the fundamental issue?

NAR members have identified several valuation issues impacting real estate transactions. Most concerns are related to appraisals, including appraiser independence, reconsideration of value policy, the increased use of automated or alternative valuation methods, a perceived shortage of appraisers, and the challenge of attracting new and diverse appraisers to the business.

I am a real estate professional. What does it mean for my business?

Appraiser Independence: Appraiser Independence Requirements set forth standards to safeguard the independence, objectivity, and impartiality of appraisers and prevent market participants from influencing an appraiser. However, industry compliance with AIR is not evident, and there is little oversight or enforcement mechanisms. NAR supports review of AIR for its effectiveness in enforcing independence and its impact on consumers and investors, including a mechanism for appraisers to voice AIR violations to regulators in an anonymous manner or with adequate whistleblower protections and ensuring that appraiser competence and quality is commensurate with compensation by developing tools that make these characteristics clear to market participants.

Reconsideration of Value: NAR supports a consistent framework within the mortgage industry for reconsiderations of value (ROVs), including clearly communicating the process and limitations to consumers and other stakeholders. Providing a consistent framework will build credibility in the valuation process and enable consumers to raise fair lending concerns.

Automated or Alternative Valuation Methods: Many in the housing industry, including NAR, support the role of appraisals and their contribution to the safety and soundness of the mortgage lending industry. However, there is an increased reliance by Fannie Mae and Freddie Mac (the GSEs) on automated valuation models (AVMs) for to inform appraisal waivers, as well as the use of inspection-based appraisal waivers and hybrid appraisals (where a property data collector inspects the home instead of the appraiser), rather than traditional in-person appraisals. NAR is supportive of technological advancements that support the housing market but has concerns with the use of automated valuations and other appraisal alternatives in purchase and other higher risk transactions.

Appraiser Shortages: Appraisers are leaving the profession at the same time that entry of new appraisers is dwindling. Entrepreneurial opportunities for appraisers are disappearing, and many are concerned with over-regulation in the field. There are also barriers to entry, such as education requirements, that could be affecting incoming appraiser numbers.

Appraiser Qualifications: It is becoming increasingly difficult to attract new entrants into the appraisal profession. In an effort to bring more qualified trainees into the profession, the Appraisal Qualifications Board (AQB) revised the Real Property Valuation Criteria to allow for more flexibility in fulfilling the college-level education requirements for appraisers and reducing the number of experience hours in early 2018. The AQB is now exploring alternative methods to provide trainee appraisers with the required education, including exploring virtual property inspections and partnerships with other educational institutions.

NAR Policy on Appraisals and Valuations

REALTORS® support and encourage credible, independent valuations of real property because valuations are critical to the health of the overall real estate industry.

A trustworthy valuation of real property ensures the real property value is sufficient to collateralize the mortgage, protects the mortgagor, allows secondary markets to have confidence in the mortgage products and mortgage-backed securities, and builds public trust in the real estate profession.

View the NAR’s Responsible Valuation Policy

Current Legislative and Regulatory Activities

On December 10, 2025, NAR sent a letterpdf to the The Appraisal Foundation’s Qualification Board (AQB) in response to its Exposure Draft Proposed Interpretations and the Retirement of Guide Note 4. In the letter, NAR stated that it values fair housing education, which is a recurring requirement for its members. The AQB's fair housing requirement for appraisers exceeds that of NAR. However, beginning in 2026, NAR will allow any course that satisfies the learning objectives for the AQB’s "Valuation Bias and Fair Housing Laws and Regulations" continuing education requirement and is approved by the AQB’s Course Approval Program and/or by state appraisal regulatory agencies to also satisfy NAR’s "Fair Housing Training" requirement. NAR also cautioned that the retirement of guidance on practicums could be disruptive without replacement language in place.

On November 12, 2025, Rep. Byron Donalds (R-FL-19) introduced H.R. 6025pdf – Appraisal Industry Improvement Act to amend the National Housing Act to authorize State-licensed appraiser to conduct appraisals in connection with mortgages insured by the FHA and to ensure compliance with the existing appraiser education and competency requirements, and for other purposes. This bill was referred to the House Committee on Financial Services

On November 7, 2025, Rep. Ayanna Pressley (D-MA-7) introduced H.R. 5975pdf – Appraisal Modernization Act to amend the Truth in Lending Act to require that financial institutions, appraisal management companies, appraisers, and other valuation professionals are serving the housing market in a manner that is efficient and consistent for all mortgage loan applicants, borrowers, and communities, and for other purposes; to study the feasibility of creating a national public appraisal database. This bill was referred to the Committee on Financial Services, and in addition to the Committee on Rules, for a period to be subsequently determined by the Speaker, in each case for consideration of such provisions as fall within the jurisdiction of the committee concerned.

On September 25, 2025, NAR sent a letterpdf to the Federal Housing Finance Agency (FHFA) in response to its request for input on "Proposed Collection; Comment Request: 'Minimum Requirements for Appraisal Management Companies (AMC)." In the letter, NAR stated that weak oversight and enforcement of AMCs’ requirement to provide rationale for an appraiser’s removal or reduced usage on a panel result in violations of appraisal independence. Further, NAR argues that appraisers should have a viable vehicle to lodge complaints with adequate whistle blower protections. Weak oversight and enforcement by Fannie Mae and Freddie Mac (the GSEs) and the Federal Housing Finance Agency (the FHFA) can impact the quality of service provided to the consumer and undermine the safety and soundness of the GSEs and the housing finance system.

On September 19, 2025, Rep. Barry Loudermilk (R-GA-11), along with cosponsors Rep. Daniel Meuser (R-PA-9), Rep. Scott Firzgerald (R-WI-5), Rep. Susie Lee (D-NV-3), Rep. Joe Neguse (D-CO-2), Rep. Brittany Pettersen (D-CO-7), and Rep. David Kustoff introduced H.R. 5520pdf – Portal for Appraisal Licensing Act of 2025 to amend the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 to establish a Portal for Appraiser Credentialing and AMC Registration Information, and for other purposes. Rep. Eugene Simon Vindman (D-VA-7), Rep. Michael Lawler (R-NY-17), and Rep. William R. Timmons (R-SC-4) later signed on as cosponsors. This bill was referred to the House Committee on Financial Services.

On August 1, 2025, Sen. Tim Scott (R-SC) introduced S.2651pdf - ROAD to Housing Act of 2025 to increase the supply of affordable housing in America. This bill was placed on the Senate Legislative Calendar under General Orders Calendar No. 143.

On July 28, 2025, NAR sent a letterpdf to the Senate Banking Committee leadership expressing strong support for the Renewing Opportunity in the American Dream to Housing Act of 2025 (ROAD to Housing Act), a landmark, comprehensive piece of legislation that addresses the full spectrum of housing needs while prioritizing pathways to homeownership for American families. The ROAD to Housing Act includes codification of reconsideration of value processes, as well as allowing licensed appraisers to complete FHA appraisals and adding appraiser trainees to the National Registry of appraisers.

On July 17, 2025, Sen. Raphael Warnock (D-GA), along with cosponsors Sen. Angela Alsobrooks (D-MD), Sen. Lisa Blunt Rochester (D-DE), Sen. Andy Kim (D-NJ), Sen. Cory Booker (D-NJ), Sen. Elizabeth Warren (D-MA), and Sen. Mark Warner (D-VA) introduced S.2322pdf - Appraisal Modernization Act. This bill is to amend the Federal Housing Enterprises Safety and Soundness Act of 1992 to require that financial institutions, appraisal management companies, appraisers, and other valuation professionals are serving the housing market in a manner that is efficient and consistent for all mortgage loan applicants, borrowers, and communities, and for other purposes. This bill was referred to the Senate Committee on Banking, Housing and Urban Affairs, and later added to the ROAD to Housing Act of 2025 in a modified form.

On May 12, 2025, NAR sent a letterpdf to the Office of Management and Budget, commenting on regulations that REALTORS® believe might be altered to stimulate increased competition or benefit the market. Among NAR’s suggestions are a call to eliminate the expansion of appraisal waivers for high balance purchase mortgages, retain policy standardizing ROV processes, and updating the appraisal Fee Disclosure and tolerance in TRID, allow appraiser compensation and fees charged by AMCs to be separated

On May 9, 2025, NAR sent a letterpdf to the Appraiser Qualifications Board responding to the concept paper, “Additional Experience Options: Should They Have a Place in Appraiser Qualifications?” NAR recommended an investigation into other professions to explore if the current number of required experience hours is appropriate or is an unnecessary burden and barrier to entry into the appraisal profession, establishing equivalency credit for experience in licensed and regulated fields including licensed real estate salespersons, real estate agents, and real estate brokers, and establishing equivalency credit for both education and experience in licensed and regulated fields involving valuation.

On May 7, 2025, Sen. Kevin Cramer (R-ND) and co-sponsor Sen. Ruben Gallego (D-AZ) introduced S. 1635pdf - Appraisal Industry Improvement Act. This bill is to amend the National Housing Act to authorize State-licensed appraisers to conduct appraisals in connection with mortgages insured by the FHA and to ensure compliance with the existing appraiser education and competency requirements, and for other purposes. This bill was referred to the Senate Committee on Banking, Housing, and Urban Affairs, and later added to the ROAD to Housing Act in modified form.

On March 27, 2025, Rep. Sean Casten (D-IL) introduced H.R.2413pdf and Sen. Michael Bennet (D-CO) introduced S. 1178pdf – GREEN Appraisals Act of 2025, to provide for accurate energy appraisals in connection with residential mortgage loans, and for other purposes. The House bill was referred to the Committee on Financial Services, in addition to the Committee on Veterans’ Affairs, for a period to be subsequently determined by the Speaker, in each case for consideration of such provisions as fall within the jurisdiction of the committee concerned, and the Senate bill was referred to the Senate Committee on Banking, Housing, and Urban Affairs.

On February 4, 2025, NAR sent a letterpdf to the Appraisal Subcommittee (ASC) providing comments and recommendations on the proposed rule regarding the enforcement authority over state appraiser and appraisal management company regulatory programs to ensure effective oversight and protection of consumers and lenders. NAR recommended that the proposed rule include additional monitoring of AMCs, whistleblower protection for appraisers, more consistency in regulation and investigation, monitoring to assess the adequacy of jurisdictions’ funding, and measurement of how effectively new rules and oversight achieve compliance.

On August 1, 2024, NAR sent a letterpdf to the Director of the Consumer Financial Protection Bureau (DFPB) in response to the Request for Information (RFI) regarding fees imposed in residential mortgage transactions, which states that, “REALTORS® believe that for regulatory oversight and enforcement purposes, transparency, and market efficiency, fees charged by AMCs should be identified separately from those charged by appraisers. To this end, REALTORS® urge the CFPB to amend the current structure of the CD to mandate that lenders stipulate separate line item for the appraisal fee and AMC fee. Furthermore, the CFPB should collect information on appraisals and AMCs fees for research and reporting to the public.”

On July 26, 2024, NAR sent a letter to The Appraisal Foundation (TAF) in response to its concept paper on the educational requirements for appraiser licensing. While NAR has no position on the educational requirements for appraisers, in the letter NAR applauds TAF for a forward-looking approach in this effort, as fostering a process to developing new appraisers of high quality is key to the long-term success of the housing market. NAR suggests using existing data on appraisers with and without college degrees to quantify whether a college education is a meaningful requirement. The letter also urges the Appraisal Qualifications Board (AQB) of TAF to establish equivalency credit for education and experience in licensed and regulated fields involving valuation such as licensed real estate salespersons, real estate agents, and real estate brokers.

NAR Committee

Real Property Valuation Committee

Current Legislation/Regulation

S. 4218 – VA Appraisal Modernization Act

H.R. 6025pdf – Appraisal Industry Improvement Act

H.R. 5975pdf – Appraisal Modernization Act

H.R. 5520pdf – Portal for Appraisal Licensing Act of 2025

US S 2651 - ROAD to Housing Act of 2025

S.2322pdf - Appraisal Modernization Act

S. 1635pdf - Appraisal Industry Improvement Act

H.R.2413pdf - GREEN Appraisals Act of 2025

S. 1178pdf – GREEN Appraisals Act of 2025

In-Depth

Congressional testimonies: Valuation

Letters to federal agencies: Appraisal FHA & VA

Letters to federal agencies: Appraisal Management Companies

Letters to federal agencies: Appraisals

Letters to federal agencies: Valuation

Letters to Congress: Appraisals

Letters to Congress: Valuation

Issue summary

NAR Federal Issues Tracker

Legislative Contact(s):

Keisha Wilkinson
kwilkinson@nar.realtor
202-383-1108

Regulatory Contact(s):

Keisha Wilkinson
kwilkinson@nar.realtor
202-383-1108

References

Terminology

BUSINESS ENTERPRISE VALUE (BEV)
"A term applied to the concept of value contribution of the total intangible assets of a continuing business enterprise such as marketing and management skill, an assembled work force, working capital, trade names, franchises, patents, trademarks, contracts, leases, and operating agreements." (The Dictionary of Real Estate Appraisal, 4th ed., Appraisal Institute)

GOING-CONCERN VALUE
"An operating business enterprise that is expected to continue." (The Dictionary of Real Estate Appraisal, 4th ed., Appraisal Institute)

GOODWILL
"An intangible, salable asset arising from the reputation of a business; the expectation of continued public patronage; including other intangible assets like trade name and going concern value...," (The Language of Real Estate, 5th ed., John W. Reilly)

Appraisal and Valuation: The Basics

What Is A Drive-By Appraisal And How Accurate Is It? (Rocket Mortgage, Oct. 31, 2024)

A drive-by appraisal, also sometimes referred to as a summary appraisal, is an alternative type of home appraisal during which an appraiser examines only the property’s exterior. To determine the home’s fair market value, the appraiser will consider the results of the appraisal and all available real estate records and data.

What Is A Desktop Appraisal And How Does It Work? (Rocket Mortgage, Jul. 29, 2024)

A desktop appraisal is a property valuation that is completed at the appraiser's desk, using third party data such as tax records or information listed on the multiple listing service (MLS), instead of an interior/exterior inspection of the property.

What is an appraisal? (National Association of Appraisers, Jan. 2025)

The National Association of Appraisers explains appraisal basics on this information sheet.

Consumer Guide: The Appraisal Process (National Association of REALTORS®, 2025)

“An appraisal is an opinion on a home’s market value that helps a lender ensure the purchase price is in line with the property value. The process is led by a licensed or certified residential appraiser—an independent third party engaged by the lender to provide a professional judgment on the home’s value. Appraisers do not represent the buyer or seller; their sole duty is to come up with a fair and accurate valuation of the property. If you are taking out a mortgage on your new home, your lender will usually require you to get an appraisal to help establish the “loan-to-value (“LTV”) ratio,” or the percentage of the home's price that you'll borrow.”

Understanding Appraisals and Why They Matter (Federal Deposit Insurance Corporation (FDIC), Jun. 2023)

“Whether you are buying a new home, refinancing your existing home loan, or selling your home, it is important to understand how an appraisal is used to assess the value for the property. A lender uses an appraisal not only to assess the value of the property, but also to determine such things as your interest rate, required down payment, and whether you will be approved for the loan. This article provides important information you should know about the home loan process, the role of an appraisal in determining the value of your property, and what you can do if you believe an appraisal is not accurate.”

Role of Appraisers in Determining Property Value (Houston REALTORS®)

“The value of your home is a calculated figure that plays a pivotal role in real estate transactions, influencing everything from mortgage approvals to negotiations between buyers and sellers. At the heart of this calculation are appraisers whose expertise in evaluating property goes far beyond mere speculation. Appraisals employ rigorous analysis, market knowledge, and strict adherence to guidelines to assess a property's actual value. In this article, understand appraisers' vital function and the challenging method by which they determine the worth of your most significant investment: your house.”

Appraisal and Fair Housing

FHA Rescinds Multiple Appraisal-Related Policies (National Association of REALTORS®, Mar. 21, 2025)

On March 19, 2025, the Federal Housing Administration (FHA) published Mortgagee Letter (ML) 2025-08, Rescinding Multiple Appraisal Policy Related Mortgagee Letters, to immediately rescind the policy guidance published in the following MLs:

ML 2024-16, Extension to the Effective Date of Appraisal Review and Reconsideration of Value (ROV) Updates, dated August 6, 2024;
ML 2024-07, Appraisal Review and Reconsideration of Value, dated May 1, 2024; and
ML 2021-27, Appraisal Fair Housing Compliance and Updated General Appraiser Requirements, dated November 17, 2021.

Appraisal Bias Undervalues Homes and Robs Homeowners of Equity — Here's How To Spot It (Business Insider, Jul. 22, 2024)

Bias in the appraisal process strips homeowners of wealth and hurts the values of neighboring homes.

Studies show that homes in areas with mostly residents of color are often undervalued compared to homes in majority white areas.

Red flags that could indicate discrimination include mentions of an area's racial makeup or poorly chosen comps.

Protecting Homeowners from Discriminatory Home Appraisals (Office of Public Affairs, U.S. Department of Justice, Mar. 13, 2023)

The CFPB administers and enforces federal consumer financial protection laws like the Equal Credit Opportunity Act (ECOA), which is a landmark civil rights law that protects individuals against discrimination in accessing and using credit. These protections apply to every aspect of a credit transaction with a mortgage lender, including the important step of mortgage lenders relying on home appraisals before approving a loan.

The Department of Justice (DOJ) enforces both ECOA and the Fair Housing Act (FHA), which protects individuals from many forms of discrimination in housing, including discriminatory residential valuations conducted by appraisers and the use of those appraisals by mortgage lenders.

Black Couple Settles Lawsuit Claiming Their Home Appraisal Was Lowballed Due to Bias (NPR, Mar. 9, 2023)

“This time the couple decided to "white wash" the house. They removed family photos and art work, books, hair products and anything else that might indicate that a Black family lived there. They also asked a white friend to be present at the house and greet the appraiser as if she were the homeowner and to display some of her family photos in the house. The Austins were not at home during the appraisal. The new appraiser concluded the house was worth $1,482,500 – nearly half a million dollars higher than Miller's estimated value.”

Window to the Law: Ensuring Impartial Appraisals (National Association of REALTORS®, Feb. 7, 2023)

“Real estate transactions rely on an objective appraisal to determine a home’s market value, but evidence suggests there’s potential for racial bias in the appraisal process. Learn more about the Property Appraisal and Valuation Equity action plan to eliminate racial and ethnic bias in home valuations and find tips to ensure an impartial appraisal.”

Fair Housing & Appraisal Bias (Appraisal Institute)

“The Appraisal Institute is the leading professional association of real estate appraisers. The Appraisal Institute’s Code of Professional Ethics and Standards of Professional Practice comprise requirements for ethical and competent practice, and advance equal opportunity and nondiscrimination in the appraisal profession. The Appraisal Institute’s work includes an array of professional education and advocacy programs, and stewardship of the highest level professional credentials in residential and commercial real estate appraisal.”

Valuation Issues

Modernizing Home Appraisals Would Advance Accuracy, Transparency, and Equity (Urban Institute, Jul. 18, 2025)

“Appraisals play a critical role in the American homebuying process by informing lending decisions, determining property value, and managing financial risk. As such, appraisals’ accuracy is vitally important for a fair and efficient housing market. Yet the current appraisal process continues to show room for improvement, as it hasn’t kept pace with market changes, larger data availability, and new technologies…Recent legislative efforts are attempting to address this problem to improve fairness and transparency, but additional measures could ensure the valuation process is based on objective market inputs – not private negotiations between buyers, sellers, and their real estate agents.”

The Importance of Getting Hybrid Appraisals Right (National Association of REALTORS®, Apr. 3, 2023)

“In theory, hybrid appraisals promise to speed the appraisal process, provide opportunities for agents to earn fees for collecting data, and reduce delays. However, appraisers’ experience with hybrid assignments raise troubling concerns. Agents need to be aware of who’s collecting data on their listings, avoid conflicts of interest, and be present during appraisal inspections.”

The Cure for Appraisal Gap Anxiety (HousingWire, Mar. 24, 2023)

“An appraisal gap is the difference between what a buyer agreed to pay for a home in a purchase contract and what an appraiser concludes as the fair market value of the property. This is usually viewed as a problem when the appraised value is below the purchase contract amount since lenders will not approve a loan amount higher than the appraisal. And homebuyers certainly don’t want to overpay and start off their ownership journey with negative equity.”

Appraisal Resources for NAR Members

Supporting Your Value: Discover AI Tools for Appraiser (National Association of REALTORS®, Jan. 30, 2025)

Appraisers face a constant challenge to provide accurate property valuations amid changing market conditions. New policies require appraisers to clearly identify market trends and apply specific time adjustments to comparable sales data based on these trends and include the methodology used to determine these adjustments in the appraisal report. But how do appraisers derive these adjustment amounts and what new technology can be used in the process? Jim Amorin, author of the Generative Shift, Preparing Appraisers For Artificial Intelligence Models Like Chat GPT, and Josh Walitt, educator and Principal Consultant at Walitt Solutions, dove into this topic exploring the various AI tools that can be used to develop adjustments and how to use them, but also how appraisers can make sure the information they are getting with those tools is accurate.

Residential Appraisal Process: FAQs for Agents was developed by NAR’s Real Property Valuation Committee for agents who are interested in educating prospective homebuyers about appraisals. NAR has found that confusion persists about appraisal regulations, especially those that affect how real estate agents and their clients communicate with appraisers. Frequently asked questions include “Can I speak to the appraiser?” and “What kind of information should I provide to the appraiser?”

Charlie Lee, from NAR Legal Affairs gave us a Window to the Law: Working with Appraisers video in Dec. 2018, in which he discussed the regulatory background of appraiser independence rules, the different roles of appraisers and real estate agents, and then covered some best practices.

NAR's Appraiser Independence page provides NAR's position on appraiser independence, background on the issues, and resources for communicating with appraisers.

Appraisers are sometimes asked by lenders and AMCs to include distressed transactions as comparable sales, to complete the appraisal in unreasonable and unrealistic time spans, and comply with a scope of work not justified by the fee being offered. NAR believes this interferes with appraiser independence, causing harm to the real estate recovery, and harm to consumers.²

In February 2012, NAR released its Responsible Valuation Policy, which supports and encourages credible, independent valuations of Real Property.

Valuation/Valuation Issue Summary (National Association of REALTORS®)

Find the most up-to-date information about NAR’s Advocacy efforts surrounding valuation and valuation issues.

Appraisal Management Companies (AMCs)

An Appraisal Management Company (AMC) works with lenders and appraisers to facilitate the ordering, tracking, quality control, and delivery of appraisal reports. On February 4, 2025, NAR issued a comment letterpdf to the Appraisal Subcommittee (ASC) in response to a proposed rule on the "ASC Enforcement Authority Regarding the Effectiveness of State Appraiser and Appraisal Management Company (AMC) Regulatory Programs."

NAR policy supports independent valuations of real property performed by state credentialed appraisers in adherence with the Uniform Standards of Professional Appraisal Practice (USPAP); therefore, it is crucial that effective oversight of both appraisers and the appraisal management companies is in place and exercised. While the proposed rule codifies ways the states should oversee appraisers, it omits specific language on AMC monitoring and ways to report AMC violations.

This comment letter suggests additional monitoring, adding whistleblower protection, promoting consistency in regulation and investigation, monitoring adequacy of jurisdictions’ funding, and measurement of how effectively new rules and oversight affect compliance.

¹ The Appraisal Foundation, A Guide to Understanding a Residential Appraisal (Washington, DC), 3, www.appraisalfoundation.org
² NAR Statement on Appraiser Independence, April 2011
³ Data on appraisal issues are from a monthly survey for the REALTORS® Confidence Index, posted at www.nar.realtor

Commercial Appraisal

Seven Essential Steps to Valuing a Company: Insights from the Hospitality Industry (Kiplinger, May 31, 2024)

There are several methods to value a company, including the discounted cash flow (DCF) method, comparable company analysis and asset-based valuations. The choice depends on the nature of the business and the purpose of the valuation.

How Much is My Property Worth? Determining Fair Market Value (Hotel Management, Feb. 16, 2024)

Due to the fluctuating nature of the hotel business, the most common way brokers will evaluate your property is based on current performance, while considering past results and future potential. Employing a room revenue multiple and a capitalization rate based on your net operating income are the most straightforward mechanisms for determining how much your property is worth based on actual property performance.

Beyond the Dark Store: Exploring Valuation Challenges and Methods for Big-Box Retail (Invoke Tax Partners, Jul. 2, 2024)

The dark store theory argues that operational big-box stores should be valued as if they were empty, basing property tax assessments on the characteristics of vacant and possibly obsolete properties. This approach has led to significantly lower tax assessments for operational stores, impacting municipal budgets and redistributing tax burdens. The theory’s application often involves the sales comparison approach, where the chosen comparable properties are vacant, potentially skewing the market value assessments of fully operational stores.

How To Value a Retail Business (Top Hat Business Brokers, Feb. 8, 2024)

With a market-based valuation, your company’s earning potential in relation to market demand will determine its value approximation. The purpose of this valuation method is to deem a business’s fair market value using the going rate of competing companies and similar enterprises in the same market.
When using a market-based retail business valuation method, you must specify the goods and services your company offers. The method also includes an assessment of the business’s goodwill or the difference between what someone would pay to buy the business and its amount of net assets.

Key Challenges in Property Appraisal for Commercial Markets (Real Estate Business Review, Dec. 4, 2025)

“The complexity of commercial and industrial appraisals stems from the number of regulations and standards that apply and that are regularly modified to reflect current economic realities and professional practice…Moreover, various approaches are often used in commercial and industrial property valuation – income capitalization, cost, and sales comparison. Selecting and justifying the most appropriate methodology for a specific asset entails technical abilities and comprehensive knowledge of local market dynamics.”

Rethinking Commerical Property Valuation Processes as Markets Shift (EY, Aug. 20, 2025)

“Enhancing the valuation function is crucial for effective asset management and gaining a competitive edge. A streamlined and technology-enabled valuation process not only improves returns but also attracts a diverse investor base. Real Estate investment managers need to regularly assess their valuation policies to verify they are current with changing market dynamics. Now is the time to embrace innovative solutions that enhance valuation capabilities and position firms for success in the competitive real estate market.”

Seven Essential Steps to Valuing a Company: Insights from the Hospitality (Kiplinger, May 31, 2024)

How Much is My Property Worth? Determining Fair Market Value (Hotel Management, Feb. 16, 2024)

Beyond the Dark Store: Exploring Valuation Challenges and Methods for Big-Box Retail (Invoke Tax Partners, Jul. 2, 2024)

eBooks & Other Resources

Appraising the Appraisal (eBook)

The Performance Appraisal Handbook (eBook)

Real Estate Appraisal (eBook)

The Art of Real Estate Appraisal (eBook)

Valuing a Business (eBook)

How to Get Started in the Real Estate Appraisal Business (eBook)

Business Valuation: An Integrated Theory (eBook)

Business Valuation and Taxes: Procedure, Law and Perspective (eBook)

Business Valuation for Dummies (eBook)

The Market Approach to Valuing Businesses (eBook)

Real Estate Market Valuation and Analysis (eBook)

The Small Business Valuation Book: Easy-to-use Techniques That Will Help You... Determine a Fair Price, Negotiate Terms, Minimize Taxes (eBook)

Books, Videos, Research Reports & More

As a member benefit, the following resources and more are available for loan through the NAR Library. Items will be mailed directly to you or made available for pickup at the REALTOR® Building in Chicago.

The Valuation of Office Properties: A Contemporary Perspective (Appraisal Institute, 2009) HD1393.58.U6 S55

Business Valuation Bluebook: How Successful Entrepreneurs Price, Buy, Sell and Trade Businesses (Facts on Demand Press, 2005).HD 1387 Si4

Business Valuation Discounts and Premiums (John Wiley & Sons, Inc., 2001) HD 1387 P88bv

Have an idea for a real estate topic? Send us your suggestions.

The inclusion of links on this page does not imply endorsement by the National Association of REALTORS®. NAR makes no representations about whether the content of any external sites which may be linked in this page complies with state or federal laws or regulations or with applicable NAR policies. These links are provided for your convenience only and you rely on them at your own risk.

Appraisal & Valuation