Interagency leaders who developed PAVE call dismantling ‘partisan’ and ‘reckless’

Goal of reversal came from Project 2025, seeking to eliminate DEI efforts

Interagency leaders who developed PAVE call dismantling ‘partisan’ and ‘reckless’

Goal of reversal came from Project 2025, seeking to eliminate DEI efforts

It wasn’t a huge surprise to many of the crafters of a federal interagency task force on housing appraisal bias when some of its policies were terminated. After all, it was one of the goals laid out by Project 2025.

The Interagency Task Force on Property Appraisal and Valuation Equity (PAVE) brought together 13 separate agencies in 2021 by the Biden administration to ensure “all Americans can benefit fairly from the equity built through homeownership.”

The task force’s executive action plan summary outlines the historical role of racism in the valuation of residential property, examines the various forms of bias that can appear in residential property valuation practices, and describes how government and industry stakeholders will advance equity through concrete actions and recommendations.

Project 2025’s “Mandate for Leadership,” a policy blueprint created by the Heritage Foundation and other conservative groups, states on page 508: “Departmental leadership should: Immediately end the Biden Administration’s Property Appraisal and Valuation Equity (PAVE) policies and reverse any Biden Administration actions that threaten to undermine the integrity of real estate appraisals.”

On July 10, the administration started that process. In a press release, Department of Housing and Urban Development (HUD) and Office of Management and Budget (OMB) called it a “Woke Biden-Era Task Force,” and stated policies in the plan were being terminated to “reduce regulatory burden and expand access to homeownership.”

Scotsman Guide talked with some of the leaders from among the agencies who helped craft the task force, which is now being partially disbanded by HUD and OMB.

One of the architects of the original task force who worked with all of the federal agencies and the White House to launch the interagency effort talked exclusively with Scotsman Guide about the disbanding. They did not want to be named.

“The PAVE action plan that the task force ultimately delivered to President Biden was a comprehensive body of work that considered broad bipartisan input from industry, government, consumer advocates and key stakeholders,” they said. “Any attempt to paint it as a partisan effort or in any way a burdensome or obstructive process is false. The dismantling was clearly coming as stated in Trump’s Project 2025, and part of a very partisan and reckless agenda that takes no care or concern for the fundamental critical business importance of fair appraisals to ensuring property collateral values are accurate. It also considered crucial consumer protections and fairness. And no home buyer would argue they don’t want that.”

The official continued: “The appraisal values are underpinning trillions of dollars of loans and securities and is not something to play political games with. It’s crucial for financial stability and important this administration take housing and the law seriously,” they said. “I think the industry and consumers can see through what this is and the most important thing is that we continue to modernize and create fair, unbiased and efficient processes and data for property appraisals and the data that underpins this critical asset class.”

Julia Gordon had been assistant secretary for housing at HUD in May 2024 and signed the Mortgagee Letter implementing the Borrower-Initiated Reconsideration of Value (ROV) requirements. The ROV update to the policy was one of the terminated policies.

In a phone call with Scotsman Guide, Gordon said the purpose of the ROV policy update last year was to ensure borrowers understood they could raise their hand if they had concerns about their appraisal and that lenders would follow up on their concerns.

“If an appraiser does something incorrectly, it makes sense for borrowers to have a clear process to raise their concerns,” she said, adding that at the request of lenders, the Federal Housing Administration and Federal Housing Finance Agency aligned their ROV policies to minimize regulatory burden and complexity for lenders.

Gordon says it’s difficult to know what the impact will truly be, but “I hope this administration agrees that racial and ethnic bias in appraisals is wrong, and I hope they don’t deny it ever occurs.”

Another former official in the Joe Biden administration, speaking to Scotsman Guide on background, said HUD’s actions don’t change the fact that it’s still illegal to discriminate, but it’s accurate to say they’re targeting this as part of its “anti-woke DEI” efforts. They also said another aspect is the administration is citing this as part of its deregulation effort, and that PAVE was creating more burdens for lenders.

“It’s a huge endeavor, and not easy to turn off and on,” the official said, noting that it’s not something that can go away with a single switch. “And even if this goes away, this has helped make huge strides in public awareness of appraisal bias. There have been legal settlements that have set a precedent in favor of those claiming discrimination.”

While they say not all lost if PAVE is undone piece-meal, they do say it’s an obstruction to progress as a whole. “One problem is, if a homeowner believes there has been appraisal bias, while they can file a complaint with HUD, maybe HUD won’t process the claim or get back.”

Another point the official made was how the rollback would inadvertently be hurting homeowners in rural communities that are also underserved and might be facing appraiser bias.

“Is it a lot about race? Absolutely. All about race? Definitely not.”

While these pieces of PAVE have been terminated, the policies are just three of 25 actions within the PAVE plan that are being ended.

The terminated policies related to Reconsideration of Value and Appraisal Fair Housing Compliance include:

  • ML 2024-16, Extension to the Effective Date of Appraisal Review and Reconsideration of Value (ROV) Updates
  • ML 2024-07, Appraisal Review and Reconsideration of Value
  • ML 2021-27, Appraisal Fair Housing Compliance and Updated General Appraiser Requirements

Maureen Yap, vice president of public policy at the National Fair Housing Alliance, also expressed concerns about the removal of the provisions.

“While everyday consumers face a fair and affordable housing crisis, the administration is taking away every tool that could help people achieve the American dream of safe, stable housing,” Yap said. “This action makes it more difficult for appraisers to understand their liability under the Fair Housing Act and does nothing to make housing more accessible to consumers in America.”

Skylar Olsen, who had been Zillow’s chief economist until earlier this month, said: “In the case of PAVE’s closure, it’s not just about closing a DEI program. It’s a move that continues to blur our lens over the issues that matter to our communities. Government data sources and research teams are gradually being defunded. Appraisal data is not as readily available as, say, home prices. PAVE was an important source of insight. Now we are a little more blind.”

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