ValuSignal

The Signal / Profession / October 17, 2026

The coal question for appraisersWill more efficient valuation technology shrink the appraisal profession, or grow it?

In 1865 William Stanley Jevons argued that burning coal more efficiently would lead Britain to burn more of it, because lower-cost power would find new uses. Appraisal faces the same question now that AI is lowering the cost of analysis. Appraisers already do complex property work, but only for clients whose stakes justify today's fee. If the profession broadly adopts tools that cut the hours, the fee can drop to where clients priced out today start ordering, while the appraiser earns more for each hour worked. That new demand is where Jevons would expect the growth.

AI-generated illustrations of a fictional ironworks and streetResearch checked October 17, 202612 chapters, 164 sources
01 / The forecastThe coal question

At the end of 2007 the national appraiser registry held 121,407 credentials. At the end of 2025 it held 89,618, 26% fewer.2829

89,618appraiser credentials, Dec. 31, 2025121,407 in 2007
65,857distinct appraisers, ASC estimate67,550 a year earlier
19%of GSE loans skipped the appraisalJune 2026, combined waiver share; 28% in March

A credential is a state license, and many appraisers hold more than one, so the Appraisal Subcommittee also counts individuals: about 65,857 in December 2025, give or take 5%, down from 67,550 a year earlier.28 The mix changed more than the total did. Since 2007, certified general credentials, which cover commercial and complex work, rose 10%. Certified residential credentials fell 21%. The licensed tier, the entry level, fell 80%, from 30,286 to 6,123, so far fewer people are entering the profession.2829 PAREA, a program that trains new appraisers through simulated assignments instead of a supervisor, had produced 53 completions and 31 Licensed Residential credentials at the Appraisal Institute as of October 8, 2025.3031

Over the same years Fannie Mae and Freddie Mac, the two government-sponsored companies that buy mortgages from lenders (the GSEs), stopped requiring an appraisal on a large share of loans. These are called waivers: the lender skips the appraisal and relies on Fannie’s or Freddie’s own data. The combined waiver share was about 50% in March 2021 and fell to 16% in June 2025.35 It climbed back to 28% in March 2026 (31.7% at Freddie Mac, 25% at Fannie Mae), then fell to 19% in June as higher rates cut no-cash-out refinancing, where waivers are most common.159

The forecast I see most often in appraiser Facebook groups follows from those numbers: lower-cost data and models keep replacing appraisals until the profession is small. I think that forecast is too simple. Economists sort demand into two kinds. When demand is elastic, a lower price leads people to buy a lot more. When demand is inelastic, a lower price barely changes how much gets bought. Appraisers sell both kinds of work, and the two respond to lower costs very differently.

Appraisers who invest in better technology and in training for harder problems can sell into the elastic side: estate, divorce and litigation assignments, zoning and land use questions, backyard-unit (ADU) and short-term rental income, new kinds of housing such as fourplexes and small condos, highest and best use, hazard and rebuild cost. As AI makes those answers more cost-efficient to produce, more people can afford to ask for them, and the profession can grow with the work. The rest of this article calls this complex property work.

Many appraisers I talk to see complex work as a fixed pool: so many estates, divorces and hard properties a year, shared among the few people who take them. I think the pool is far larger than the orders that reach us. When an executor, investor or homeowner is quoted $2,000 to $5,000 for a complex assignment, in my experience many of them look for something else: an agent’s price opinion, an online estimate, the county’s assessed value, a contractor’s number or their own guess. Those substitutes cost less and often miss the layers that make the property hard to value. Each one stands for a buyer who wanted the answer and did not pay today’s price for it, and that is the demand a lower price could bring back.

The other kind is the mortgage appraisal report, which this article calls loan work. Demand for it is inelastic. It moves almost in step with the number of mortgages, and a lower-priced appraisal does not create more mortgages. Waivers, automated models and lower-cost data collectors already handle part of that work. Loan work is unlikely to grow much when its price falls, but I do not expect it to disappear, and chapter 12 explains how the new report format could help it. Most appraisers do both kinds of work, and the question this article asks is which part of a practice will grow.

The chapters below run both kinds of work through three tests from chapter 02, compare appraisal with four other professions, and name the barriers appraisers cannot remove on their own.

Loan work

Sells
The mortgage appraisal report
Demand
Inelastic, set by loan volume and agency rules
What lower-cost technology does
Handles part of it: waivers covered 28% of GSE loans in March 2026 and 19% in June159
Likely result
Work that rises and falls with loan volume, with waivers taking a share

Complex property work

Sells
Answers about use, rules, income, land and risk
Demand
Possibly elastic: at $2,000 to $5,000, many buyers settle for a substitute
What lower-cost technology does
Lowers the cost of each answer, so more buyers can ask
Possible result
A profession that grows with the work; not yet measured (chapter 08)
Most practices hold both columns. The left column is documented. The right column is a hypothesis: the evidence supports it in part, and chapter 08 explains where I expect it to show up first.
02 / Jevons, 1865The rule and its limit

More efficient coal engines raised Britain’s coal use

In The Coal Question, published in 1865, the economist William Stanley Jevons argued that using coal more efficiently would increase Britain’s total coal consumption. As coal became more cost-efficient to use, people found new things to use it for, and those new uses burned more coal than the efficiency saved.1 One of his examples was Scottish iron making: the coal needed to make a ton of iron fell to less than a third of what it had been, while the industry’s total coal use rose tenfold.12

Coal per ton of iron
under ⅓
Total coal used by the industry
10×
“It is wholly a confusion of ideas to suppose that the economical use of fuel is equivalent to a diminished consumption. The very contrary is the truth.”
William Stanley Jevons, The Coal Question, 1865, ch. VII1
Scottish iron making as Jevons described it. Bars show relative change, not tonnage.12

Economists call the extra use the rebound effect. When the extra use is larger than the saving, they call it backfire, which is the case Jevons described. Backfire only happens when demand is elastic: as the price falls, the amount people buy has to rise faster than the price drops. If the price of a service drops 20% and people buy 50% more of it, total spending goes up. When demand is inelastic, a lower price sells only a little more, and total spending falls.2

Move the slider to lower the price and see what happens to total spending on each curve.

The two demand curves an appraiser can land on as AI cuts the cost of analysisA conceptual model with no data: demand indexed to 100 at the starting price. Elastic demand (elasticity 1.6), the side complex property work could reach, is the solid line with circles. Inelastic demand (elasticity 0.3), the side of loan work, is the dashed line with squares.
Quantity demanded against price for an elastic and an inelastic curve0400800120020406080100Price of the service (100 = today)Quantity

100 is today’s price. Moving left lowers the price of the analysis.

Elastic: complex property work
100 units bought
Total spend 100
Inelastic: loan work
100 units bought
Total spend 100

Energy research limits how far the idea goes. Kenneth Gillingham, Matthew Rapson and Gernot Wagner reviewed the evidence for Resources for the Future in 2014. They found that typically 5% to 40% of an efficiency saving comes back as extra use of the same service, and that the full effect across the economy usually stays under 60%. Backfire, where more than 100% comes back, is rare in energy.3 So the question for appraisal is which kinds of appraisal work have elastic demand. One profession can sell into both curves, and the rest of this article follows that split.

How much of an efficiency saving comes back as extra useRanges from the RFF review of energy studies. Backfire, the Jevons case, starts at 100%.

Direct reboundSame service, typical range

5% to 40%

Total reboundAcross the economy

Usually under 60%

BackfireThe Jevons case, rare in energy

Over 100%

Source: Gillingham, Rapson and Wagner, RFF DP 14-39.3

The idea returned to business news in January 2025. After DeepSeek released a low-cost AI model, Microsoft chief executive Satya Nadella posted “Jevons paradox strikes again!” about AI use and computing.4 On NPR’s Planet Money on February 4, Stanford economist Erik Brynjolfsson set three tests for Jevons to raise employment in an occupation. Farming fails the third. He named radiologists, translators and coders as candidates.5

  1. Test 1AI makes the worker more productive
  2. Test 2The price of the work falls
  3. Test 3Buyers order enough more that total spending rises

The rest of this article puts appraisal through those tests. Loan work fails the third (chapter 04). Complex property work could pass it (chapters 05 to 08), but only if appraisers pass the first by adopting better tools and the market lets the second happen (chapter 10).

The second test can read like a call for appraisers to cut their fees and earn less. That is not my argument. Better tools should lower what each complex assignment costs to produce, so the price can fall while the margin rises. Take an assignment that takes ten hours and sells for $3,000, which earns $300 an hour. If tools cut it to five hours and the fee drops to $2,000, it earns $400 an hour, and the client pays a third less. Jevons saw the same thing in coal: efficiency made each use of coal more profitable, so coal found more uses.1 The lower price reaches the clients from chapter 01 who settle for substitutes today, and the higher margin pays for the tools and training the work takes.

03 / Four professionsFour outcomes

Radiologists grew, tellers rose and fell, bookkeepers split from accountants, translators shrank

We can now check how Brynjolfsson’s candidates did, along with older cases that have run their full course. The results differ, and the differences line up with two things: whether a licensed person still signs the work, and whether people bought more of it as its price fell.

  • A dark radiology reading room: two monitors glow with grayscale scan images beside an empty chair.

    Grew

    Radiologists

    Geoffrey Hinton said in 2016 that hospitals should stop training radiologists. In 2026, residency programs offered 1,241 diagnostic radiology positions and filled 97.6% of them.67118

    Caseloads, 2018 to early 2025
    +25%
    Applicants, 2023 to 2026
    2,014 to 1,741
    Share of time on image reading (2012 study)
    36%

    Applicants have fallen since 2023, and researchers dispute how much of the volume growth comes from an aging population.

  • An empty bank teller window with a brass grille, a marble counter and a pen on a chain.

    Grew, then fell

    Bank tellers

    ATMs cut tellers per urban branch from 20 to 13 between 1988 and 2004, while banks opened 43% more urban branches. Mobile banking later replaced the branch itself.121315814

    Tellers, 2006
    about 608,000
    Tellers, 2025
    339,200
    BLS projection, 2025 to 2035
    -13%

    The first technology changed a task inside the branch. The second replaced the channel.

  • A wooden desk with an open handwritten ledger, a mechanical adding machine and a laptop at the edge.

    Split

    Bookkeepers and accountants

    Accountants and auditors grew from 39,000 in 1910 to 1,795,000 in 2000 as tax rules and regulation expanded. Bookkeeping clerks declined after 1970 as software took over the entries.151617

    Bookkeeping clerks, 2025 to 2035
    -6%
    Accountants and auditors
    +5%
    Financial analysts
    +7%

    Inside the same field, data-entry jobs shrank and judgment jobs grew.

  • A translator’s desk at dusk with stacked bilingual dictionaries, an open book and a brass lamp.

    Shrank

    Translators

    Erik Brynjolfsson named translators as a Jevons candidate in February 2025. Research on 2010 to 2023 associates Google Translate adoption with about 28,000 fewer translator positions than expected.215

    Translator employment growth, 2010 to 2023
    about 3%
    All jobs, same period
    about 13%
    Positions below counterfactual
    about 28,000

    Machines took over the output itself, and no license was needed to sign it.

  • AI-generated illustrations. Figures come from the cited sources.

Radiology is the case most often cited for Jevons. Average radiologist pay reached $571,000 in 2025, according to Medscape figures reported by Fortune, and caseloads rose 25% from 2018 to early 2025.6 Two caveats apply: applicants fell from 2,014 in 2023 to 1,741 in 2026,11 and researchers attribute 73% to 88% of projected imaging growth to an aging, growing population, a projection others have publicly disputed.8910 The narrower lesson is that imaging got less expensive, volume rose, and radiologists kept the licensed read.

Tellers show the second outcome. ATMs reduced tellers per urban branch from 20 to 13 between 1988 and 2004. Banks opened 43% more urban branches, so teller jobs still grew, about 2.0% a year after 2000.1213 Mobile banking then replaced the branch. The Bureau of Labor Statistics counted about 608,000 tellers in 2006 and 339,200 in 2025, and projects a further 13% decline by 2035.15814 James Bessen found the same arc in textiles, steel and autos: demand was elastic early in each industry’s life and inelastic later, so employment rose and then fell.24

Accountants and bookkeepers split inside one field. Accountants and auditors grew from 39,000 in 1910 to 1,795,000 in 2000 as tax rules, regulation and managers’ demand for data expanded. Bookkeeping clerks declined after 1970 as software took over the entries.15 BLS projects bookkeeping clerks down 6% from 2025 to 2035, accountants up 5% and financial analysts up 7%.1617157

Law split the same way. Software took over most document review, yet lawyers and judges grew from 272,000 in 1970 to 927,000 in 2000, and BLS projects lawyers up 5% to 2035.181520

Translators were on Brynjolfsson’s list, and they show what happens when the output itself is automated. Carl Benedikt Frey and Pedro Llanos-Paredes link the spread of Google Translate to about 28,000 fewer translator jobs than expected from 2010 to 2023. Translator employment grew about 3% while all jobs grew about 13%.21 BLS projections show the same decline for typists and travel agents, whose output software also took over.2223

Economists who study automation find the same rule. Jobs grow when tools take over tasks and people move to harder ones, and they shrink when the tool replaces the whole output.252627 Appraisal has both kinds of work in it. On a simple loan, ACE and waivers replaced the output itself, the value, much as machine translation replaced the translation. Measurement, data collection, research and drafting are tasks, and tools make them faster while the appraiser still signs the opinion. That is the radiology pattern, and it is the one complex property work could follow.

Where each profession landed, and the edge appraisal sits onEach profession is placed by how elastic demand for its output was and by what technology did to its work. Appraisal sits at the center. Hover or focus any point for the evidence. Placement is ValuSignal’s reading of the cited sources.

Swipe sideways to see the whole map.

Outcome map: professions by demand elasticity and by what technology did, with appraisal at the edgeLawyers, radiologists and accountants grew: demand was elastic and technology augmented the work. Typists, travel agents, translators, bookkeepers and tellers after 2006 shrank: technology replaced the output or the channel. Tellers moved from the growth quadrant to the shrink quadrant when mobile banking replaced the branch. Appraisal sits at the center, with one path toward complex property work and one toward loan work alone.Grewtools took tasks, judgment stayedShrankoutput or channel replacedLess elastic demandMore elastic demandTechnology replaced the outputTechnology augmented the workmobile banking, after 2006LawyersRadiologistsAccountantsTellers, 1988 to 2006BookkeepersTellers, after 2006Travel agentsTranslatorsTypistsLoan work onlyInelastic: follows loan volumeAdd complex property workElastic demand? Not yet measuredAppraisal today
Data table
Outcome map placements (0 to 1)
PointDemand elasticityAugmented the workOutcome
Lawyers0.580.87Grew
Radiologists0.760.81Grew
Accountants0.660.75Grew
Tellers, 1988 to 20060.560.67Grew
Bookkeepers0.10.24Shrank
Tellers, after 20060.360.18Shrank
Travel agents0.150.16Shrank
Translators0.450.07Shrank
Typists0.060.05Shrank
Appraisal today0.50.5At the edge
Loan work only0.420.36Likely path for loan work alone
Add complex property work0.90.555Possible path, unmeasured
The pattern across professions
OutcomeProfessionsWhat they had in common
GrewRadiology, accountants, lawyersA licensed sign-off was required; tools took over a task while judgment tasks remained; demand rose with complexity.
Grew, then shrankTellersA period of augmentation inside the branch, then replacement of the branch as a channel.
ShrankTranslators, typists, travel agents, bookkeepersThe output itself, or the channel, was automated, with little licensed judgment attached.
04 / Two tracksValuation’s first efficiency shock

Lower-cost analysis already handles many simple loans

For many simple loans, the lower-cost option already works: lenders skip the appraisal, and the loans perform fine. Freddie Mac launched automated collateral evaluation (ACE), a system that accepts a home’s value from data with no appraisal, in June 2017. It covered nearly 40% of originations at its peak in the third quarter of 2020, and 87% of ACE loans were refinances. After adjusting for differences between the loans, ACE loans had about 8.9% lower 90-day default rates than comparable appraised loans.34 That is the strongest evidence against the idea that every loan needs an appraisal.

  1. The single lineOne kind of valuation, ordered for a loan
  2. The switchLower-cost technology sent the simple loans down a different track
  3. Two tracksWhich track appraisers ride depends on the work they choose to sell

Track 1: Loan work

What is the collateral worth today for this loan?

0204060~50%Mar 202116%Jun 202526%Feb 202628%Mar 202619%Jun 2026
GSE waiver share, 5 reported points, no smoothing.3533159

Track 2: Complex property work

What could the property be worth under a use, a rule, a plan or a risk?

?Demand has not been measured. Buyers include builders, owners, investors, insurers, private lenders and attorneys.

Nearly half of plain refinances, where the owner takes no cash out, skipped the appraisal in February 2026 (47.5%). In early 2025 Fannie Mae extended that option to home buyers who put as little as 10% down.3337 Fannie says 5.34 million loans from January 2018 to June 2026 used appraisal alternatives, and puts the avoided fees near $3 billion at about $550 a loan. The Appraisal Institute says the figure is better read as an estimate of avoided fees than as evidence that housing got materially more affordable.36

Where an appraisal is still ordered, the inspection is being split off and handed to someone else. In a property data report, a non-appraiser visits and records the home, and an appraiser works from that record. Freddie Mac puts a property data report at about $200 against about $600 for an appraisal, and says ACE with a property data report closes purchases about 12 days faster. In hybrid testing, appraisers working from those reports were about twice as likely to identify condition and quality eligibility correctly.40

Appraisers have mostly refused this split, sometimes called bifurcation. In a 2020 survey of more than 4,000 appraisers, run by an errors and omissions insurance broker with a trade publication, 75.0% said they would refuse analyst-only work. Asked separately why, most cited liability for a collector’s data and inadequate fees, and institutions set both.54 The Appraisal Institute asked FHFA Director Pulte in March 2025 to reconsider expanded waiver and hybrid eligibility.56

This resembles the teller pattern: the waiver skips the appraisal, and the data collector takes the inspection. In Brynjolfsson’s terms, loan work passes the first two tests and fails the third. Technology made it more productive and cut its price, to nothing on a waived loan, but a lower-priced appraisal does not create more mortgages. GSE appraisal volume follows interest rates because it follows loan volume: about 544,000 GSE appraisals in November 2020, about 97,000 in February 2023.3339 Nobody has measured whether a lower fee or a better report wins loans back from waivers, or whether valuation work as a whole grew.

Complex property work, the other track, answers what a property could be worth under a use, a rule, a plan or a risk. Builders, owners, investors, insurers, private lenders, executors and attorneys buy it when it is affordable and skip it when it is not, so its demand can be elastic. Nobody has measured how elastic, and chapter 08 explains where I expect it to grow first.

The two-track model
Feature Track 1: Loan work Track 2: Complex property work
QuestionWhat is the collateral worth today for this loan?What could the property be worth under a use, rule, plan or risk?
Who requires itGSEs, FHA, VA, bank regulatorsBuilders, owners, investors, insurers, private and DSCR lenders, attorneys, executors
Demand elasticityLow; set by transaction volume and rulesPossibly higher: buyers priced out today settle for substitutes; not yet measured
What lower-cost technology didStood in for the appraisal on a share of loans: waivers, ACE, property data reportsMostly untested at scale
Closest analogTellers after mobile banking; bookkeepers after softwareRadiology; accountants and financial analysts
Who captures gains by defaultGSEs, data vendors, AMCs, lower-cost data collectorsWhoever delivers consistent, defensible complex analysis at scale
05 / The complexity stackWhy Track 2 exists

Eight questions an AVM finds difficult to answer

ACE and waivers work where a model has enough sales of similar homes. The examples below show what a model, or a rushed appraisal, has to answer when it does not. Each layer is a separate question with its own data source, and the answers change one another. The hillside parcel in the illustration is invented, but every card beside it describes a real place and a real rule. This is the complex property work from chapter 01, and it is where Brynjolfsson’s third test could pass: someone has a reason to pay for each answer, and better tools make each one more cost-efficient to produce.

  1. 01Legal rightsWhat does the owner hold?

    Beach keys that follow 1940s tract lines

    A locked weathered wooden gate at the top of a bluff path above a Pacific beach.

    $1M to $2Mbroker estimate of a beach key

    At Point Dume in Malibu, deeded beach-gate rights depend on the original tract, so two similar homes on one street can differ, and only a title check shows it. A local broker estimates a key adds $1 million to $2 million. In 2016 the California Coastal Commission fined Warren and Henny Lent $4.2 million for blocking a public access easement at Las Flores Beach while renting the home as having a private beach.6062

  2. 02Zoning and useWhat may be kept or built here?

    Horse rights measured in square feet

    A small wooden corral with a horse and a weathered barn on a dry foothill lot.

    4,000 sq ftof lot per horse in an LA K district

    Los Angeles K districts require at least 4,000 square feet of lot per horse and keep enclosures 35 feet from habitable rooms on the same lot. A nonconforming horse use ends if no licensed horse is kept for three consecutive years. Neighboring cities such as Claremont set their own ratios.6569

  3. 03Neighbor effectsWhat can a neighbor’s permit change?

    A neighbor’s ADU can make your horse use nonconforming

    The same corral with a newly built small cottage just beyond the side fence.

    75 ft to 35 ftproposed neighbor distance

    A June 24, 2026 Los Angeles City Planning report addresses state-law ADUs and SB 9 units built inside the distance rules that protect horse keeping next door. It proposes cutting the neighbor distance from 75 feet to 35 feet and creating a legal nonconforming status.66

  4. 04Added unitsWhat is the second unit worth?

    The same ADU house, $500,000 apart

    $1.2M$1.5M$1.8M$2.1M
    Appraiser A: $1.4MAppraiser B: $1.9M

    $1.4M vs $1.9Mtwo appraisals of one house

    The Los Angeles Times reported a Burbank home bought for $1.3 million that added a $200,000 ADU. One appraiser valued it at $1.4 million and another at $1.9 million. Of 642 comparable Los Angeles sales in three months, 106 had ADUs, and one 1,200 square foot ADU was valued at $0. Freddie Mac’s September 2026 ADU guide calls ignoring an ADU for lack of comparables an unacceptable practice.7576

  5. 05Income rulesWhich income is legal?

    A short-stay rule that removed most listings

    A row of brownstone stoops at night; one building’s windows are dark and shuttered.

    -83%NYC short-stay listings in a year

    New York City began enforcing Local Law 18 on September 5, 2023. Airbnb listings for stays under 30 nights fell 83%, from 21,900 in July 2023 to 3,700 in July 2024, according to AirDNA. In Dallas, the city’s 2023 short-term rental zoning is before the Texas Supreme Court in case No. 25-0748.8082

  6. 06Land valueWhat is the dirt worth under a new rule?

    Land is a rising share of home value

    7.7%54.3%

    7.7% to 54.3%county land share range

    FHFA researchers estimate the national land share of home value rose from 38.2% in 2012 to 40.9% in 2019. County land shares range from 7.7% to 54.3% between the 1st and 99th percentiles. When zoning changes what a lot can hold, the land value moves first.79

  7. 07View and orientationWhat does the window look at?

    View premiums from 8% to 60%

    8%60%

    8% to 60%ocean view premiums, Bellingham

    In Bellingham, Washington, the best ocean views carried premiums of about 60% and the weakest about 8%, falling with distance from the water. In New Zealand, water views averaged 9.7% in Auckland and 10.9% in Christchurch, higher where views are scarcer.8485

  8. 08Carrying costsWhat will it cost to hold?

    Florida condo inspections and reserve rules

    A twelve-story coastal condominium tower wrapped in scaffolding and green netting.

    1,438Fannie-ineligible Florida condo buildings

    Florida’s 2022 condo law requires milestone inspections of buildings three stories and taller once they turn 30, and a 2025 law gave associations until December 31, 2025 to finish their first structural reserve studies. Florida condo prices fell 4.5% year over year against 2% for single-family homes, and 1,438 Florida buildings were ineligible for Fannie Mae loans in April 2025.1601619697

Each layer comes from a different record: title and tract history, the municipal code for the parcel, a neighbor’s permits, rent comparables, ordinances and pending lawsuits, feasibility studies, a site visit, assessments and insurance quotes. A brokerage in Yorba Linda reports that the standard appraisal form has no fields for stalls, arena footing or trail access, and describes a barn costing about $150,000 that appraised at $40,000 to $70,000; that is one brokerage’s account, without sales data behind it.70

Every property carries its own thumbprint

The layers also act on each other. Card 03 shows one case, where a neighbor’s ADU can make a horse use nonconforming. A short-stay rule changes what an added unit can earn, and so what the land under it is worth. Each home ends up with its own combination of rights, rules, units, views and costs, a thumbprint that the subject and every comparable sale carry separately. Two homes can match on bedrooms, square footage and lot size and still differ on several layers, so each comparison means working out how one combination moves value against another. A paired-sales adjustment for one layer assumes the others hold still, and on these properties they often do not. I see that as the next technical frontier in residential valuation, and the work where better tools would help most.

Models show their limits on the same properties

When few sales share a home’s thumbprint, a model has little to learn from. Automated valuation models (AVMs), the computer estimates behind tools like the Zestimate, struggle with the same properties. Zillow reports a median Zestimate error of about 1.94% for homes on the market and 7.06% for homes off it, meaning half of off-market estimates miss by more than 7%. The Close notes that once a home is listed, the list price becomes an important input, which helps explain the gap.86 Condition shows the same limit. A 2024 Cityscape study of Atlanta and Memphis found mean AVM error 4.35 points higher for homes in poor condition than for homes in good condition.89

Zestimate error on and off the marketMedian error as Zillow reports it, percent of value.
  1. Zestimate median error, home on the market
    1.94%
  2. Zestimate median error, home off the market
    7.06%

Source: The Close, June 2026, reporting Zillow’s figures.86 Bars scaled to 10%.

06 / What gets builtValuation risk and housing form

Cities are allowing more kinds of housing. Lending still favors the kind appraisers know.

A growing number of states and cities are rewriting their zoning to allow more kinds of housing. Much of American zoning, written over the 20th century, produced the conforming suburb: similar detached homes on separate lots, usually a drive away from shops and transit. A 2019 New York Times analysis found that in many American cities, building anything other than a detached house was illegal on about 75% of residential land.163 The reforms below allow a wider range of homes on the same land: small condo buildings, townhomes, duplexes and fourplexes, backyard and basement ADUs, upper-floor lofts and detached homes on smaller lots, often within walking distance of shops and public transit.

People need that range. Harvard’s Joint Center for Housing Studies puts the income needed to buy a median-priced home above $120,000.123 Smaller homes on shared land cost less, and they suit people a detached house does not: young buyers, older owners who want less space, families who want a rental unit out back.

  1. 2020California

    SB 13, AB 68, AB 881: one ADU plus one junior ADU per single-family lot

    ADU permits rose from 1,336 (2016) to 30,354 (2024)7172
  2. 2022California

    SB 9 lot splits and duplexes

    Los Angeles: 28 lot-split applications, none approved, by November 202278
  3. 2019 to 2024Oregon

    HB 2001 middle housing

    Middle housing rose from 8% to 11% of permits in 45 cities117
  4. 2017 to 2022Minneapolis

    Triplexes legal citywide

    1% of about 21,000 permitted units were in 2 to 4 unit buildings119
  5. 2023Washington

    HB 1110: 2 to 6 units per lot by city size and transit

    No outcome data yet120
  6. Sept. 2025Texas

    SB 15 small lots; SB 840 housing by right on commercial land

    No outcome data yet114115
A conforming subdivision at blue hour: similar two-story detached houses with front garages along a curving street.The same street rebuilt as a layered neighborhood: brick rowhouses, a fourplex and a three-story building of stacked flats with front stoops.
  1. The safe betDetached homes on separate lots, the street appraisers value every day
  2. What reforms now allowTownhomes, fourplexes, small condos and backyard units, a short walk from shops and transit

AI-generated illustration of a fictional street

Variety makes valuation harder. A street of similar detached houses gives an appraiser plenty of recent sales to compare. A fourplex, a townhome in a small condo complex or a house with a basement unit and a backyard cottage may have few comparable sales nearby, and the agency rules treat the extra units with caution. To a lender, a value that is harder to support reads as collateral risk.

The rules show where that caution sits. Fannie Mae allows one ADU per parcel and none with a 2 to 4 unit dwelling, while FHA now counts 75% of rent from an existing ADU.99103 A condo adds rules for the whole project on top of the unit. Fannie Mae waives its full project review for condo buildings of up to ten units outside a larger development, but the project’s insurance and the priority of its association dues still apply.164

So the safer play today is the conforming subdivision. Builders put up detached homes that the current appraisal workforce values every day, and lenders finance them on standard terms. Townhouses sold with the land under each unit fit the same pattern and reached a record 18.7% of single-family starts in Q3 2025.109 Small multi-unit buildings went the other way.

Buildings with 2 to 4 units fell from about 6% of new homes to about 1%Share of US housing completions in 2 to 4 unit buildings, selected years. Computed from FRED annual data; shares are approximate.
0%2%4%6%5.9%19725.7%19851.7%20001.4%20101.1%2025
18.7%Townhouse share of single-family starts, Q3 2025, the highest since the series began in 1985. 17.4% by Q2 2026.109110

Source: FRED series COMPU24USA and total completions, shares computed by ValuSignal;112 townhouse share from Census data via NAHB.

Data table
2 to 4 unit share of completions
YearShare
19725.9%
19855.7%
20001.7%
20101.4%
20251.1%

Builders and lenders have worked around this for years. In 2022 the Terner Center reported that appraisers may not understand small multi-unit buildings and the value they create, so developers often pay for early projects themselves.105 The National Association of Home Builders says these loans fall in a gap between residential mortgages and conventional apartment-building loans.106

A 1920s brick fourplex with two entry doors and stacked porches, softly focused.
How the gap happens

A builder finishes a new fourplex three blocks from a rail station and finds a buyer at $1.8 million. The only fourplex sale nearby in three years is a 1920s building with its original kitchens. The other comparables are detached houses on bigger lots. The appraisal comes in at $1.55 million, and the buyer’s lender lends against the lower number. Now the buyer has to find $250,000 more in cash, the builder has to cut the price, or the sale falls apart.

An illustration with invented figures. Builders describe the same comparable-sales problem in the Terner Center’s 2022 brief.105

Appraisal is one obstacle among several. In California, planners named cost, subdivision law and construction defect liability ahead of valuation when few lots were split under the state’s lot-split law.78

Once these neighborhoods exist, buyers pay for them. Homes in Kentlands, Maryland, sold for about 12% more than comparable conventional homes, and a later study of four such communities found an average premium of 11%.124153 They also open a lower price point: in Portland, a new unit in a triplex or fourplex cost about half as much as a new house.117118

New home prices in Portland, 2024
  1. New house, Portland, 2024
    $916K
  2. New triplex or fourplex unit, Portland, 2024
    $460K

Source: Sightline, citing City of Portland data.117118

Zoning reform makes middle housing legal. Lending decides whether it gets built, and lenders lend where they trust the collateral. A national appraisal workforce that values complex property predictably, with the same methods and well-supported comparables in every state, would lower that perceived risk and open lending to more than the conforming subdivision. Chapter 09 looks at what that workforce would take.

07 / Before and afterWhat cost-efficient analysis looks like

The tools that cut the cost of hard problems are already allowed

UAD 3.6 is the new standard appraisal report format that Fannie Mae and Freddie Mac require for new submissions starting November 2, 2026; chapter 12 has the full timeline.4142 The redesigned report asks for more detail on every property, and the measurement and AI rules now allow the tools that keep that extra work affordable.

Two hands hold a steel measuring tape along the brick corner of a house.
The same hands hold a tablet against the brick corner, its camera scanning the wall.
Tape and sketch, then a phone or tablet scan under the same ANSI standard.AI-generated illustration
A residential appraisal before and after cost-efficient analysis
Part of the workLegacy formsNow
ReportSeparate forms by property type, such as the 1004, 1073 and 2055One dynamic report for all 1 to 4 unit properties43
Condition and qualityOne rating for the dwellingSeparate interior and exterior ratings, component-level condition43
MeasurementTape and hand sketchANSI Z765-2021 required since April 1, 2022; phone apps accepted; vendors report LiDAR floor plans in 10 to 15 minutes4546
Research and draftingManualAI tools that rank comparables; USPAP AO-41 (April 2026) sets the framework for using AI5147
ReviewHuman reviewersFannie Mae ran computer vision on 1 million appraisals in 2023 to flag condition and quality ratings49

The LiDAR timing is Opteon’s claim about its own staff; Clear Capital reports, from 2,100 early UAD 3.6 reports, fees about $65 higher in comparable markets and appraisers about 28% faster after the first weeks. Both are vendor data.4644

More on the new report in our UAD 3.6 series.

08 / Where demand isTrack 2, sized

Eleven places where complex property work could find buyers

Brynjolfsson’s third test asks whether buyers would order enough more of the work as its price falls. Nobody has measured that for complex property work, so this chapter looks for the next best signs: a rule that creates a new analysis requirement, a buyer who already pays for a report, and a buyer who settles for a cheaper substitute. The fire insurance case below shows the third, where an insurer’s rebuild estimate stands in for a replacement cost analysis. The research found ten such cases. I add an eleventh from my own experience, and I think it is the strongest.

Among the documented cases, ADU feasibility and rent is the clearest. Fannie Mae now lets borrowers count rent from a backyard unit toward the income they qualify with, up to 30% of it, on a one-unit home they live in, and its loan-approval software began accepting it on March 21, 2026. Neither announcement says how appraisers should report the unit or find rent comparables for it.77155 Freddie Mac’s guide requires at least one ADU comparable for a zoning-compliant unit and two for a non-compliant one, allows older and out-of-area sales, and says these assignments take additional work.76 California permitted 30,354 ADUs in 2024, more than 26.6% of all homes permitted statewide, and in Los Angeles an ADU raises sale price 7% to 9%.7274

DSCR and short-term rental income is next. A DSCR loan is approved on the property’s rent rather than the borrower’s income, and it belongs to non-QM lending, the loans made outside the standard mortgage rules. Investor and DSCR loans rose from 22% of non-QM production in August 2022 to 35% in August 2026. Moody’s found that 30% of the DSCR programs it surveyed let borrowers use the higher of appraised rent and actual rent, with no cap.127 AirDNA counted 1.73 million available short-term rental listings in November 2025.130 On average, rental rules move value only a little: in Los Angeles County, house prices and rents fell about 2% to 3% just inside the borders of cities that restricted short-term rentals.83154 For a single property, though, the rules decide whether the income exists at all, as New York’s short-stay rule in chapter 05 showed.

New wood framing rising on the concrete foundation of a home lost to wildfire, with charred trees behind.

The largest documented gap

71%

of 74,070 California homes destroyed by fire from 2018 to 2023 were underinsured, by about 19% on average. Insurers’ own rebuild estimates at the point of sale came in below the incurred loss 75% to 95% of the time.131

After the 2021 Marshall Fire in Colorado, 74% of policyholders were underinsured.149 AI-generated illustration.

Replacement cost has the largest gap and the least clear buyer. Of 675 households surveyed by United Policyholders after the 2025 Los Angeles fires, 69% of those with total losses said their coverage would not rebuild their homes, with average underinsurance of about $247 per square foot.132 Policies on the California FAIR Plan, the state’s insurer of last resort, reached 645,987 in September 2025, up 169% in four years.91 The San Francisco Fed found that distance from fires added only about 2% to the value of an average home from 2018 to 2021, so wildfire risk shows up more in insurance and carrying costs than in price.92

Layered development matters most for housing and is the hardest to open up, because institutions control four of the six barriers in its way. Private and non-QM lenders set their own scope of work outside agency forms, which makes them the likeliest early buyers of deeper analysis.

Renovation and after-repair value (ARV) analysis has a large base: 297,045 flips in 2025, about 112,000 of them financed (computed). Gross returns were 25.5%, the lowest since 2008, and thinner margins limit what investors will pay.126

Opportunity scorecardSort by opportunity or strength. Strength reflects how well the research supports both an analysis gap and a paying buyer.
BuyersSize proxyDemand trigger
ADU feasibility and ADU rent analysisOwners, lenders now counting ADU rent, investors30,354 California ADU permits in 2024Fannie Mae ADU income; Freddie Mac ADU guideStrong
DSCR and short-term rental income with regulatory statusRent-based (DSCR) and other nonstandard lenders, investorsDSCR 35% of non-QM loans; 1.73M short-term rental listingsSTR ordinances and litigationMedium to Strong
Estate, divorce and litigation valuationExecutors, estate and family law attorneys, litigantsNo national countDeaths, divorces and disputes, not loan volumeMedium
Insurance replacement cost and rebuild valuationHomeowners, insurers, public adjusters, attorneys$1.3T Western wildfire reconstruction value (vendor)Wildfire losses; FAIR Plan growthMedium
Layered development valuationBuilders, construction lenders, community development lenders, municipalities19,000 2 to 4 unit starts in 2025Zoning reform; UAD 3.6 data depthMedium
Highest and best use and land valueOwners, small developers, investors, estate attorneysLand 40.9% of value nationallyZoning reformMedium
Renovation and ARV scenario analysisPrivate and short-term renovation lenders, flippersAbout 112,000 financed flips in 2025 (computed)Private credit growthMedium
Hazard and carrying-cost adjusted valueLenders, investors, condo buyers, insurers1,438 Fannie-ineligible Florida condo buildingsFlorida SB 4-D; Risk Rating 2.0Medium
Model validation and AVM quality control supportLenders, AVM vendors, GSEsAVM rule in force since Oct. 1, 2025RegulationMedium
Rights, easement and use-entitlement analysisBuyers, sellers, attorneys, high-value lendersNiche; no national countCoastal enforcement; neighbor ADUsWeak to Medium
Portfolio monitoring for single-family rental and build-to-rent operatorsOperators, servicers, trustees68,000 build-to-rent starts in 2025Fund reporting, securitizationWeak

Size proxies come from sources cited in chapters 05, 06 and 08; the build-to-rent count is from NAHB.128 The legal valuation row rests on my own judgment; no national data measures it.

09 / A national workforceLicensing and delivery

Federal portability covers federally related loans and little else

Chapter 06 ended on a need: lenders want values that are equally predictable in every market. Appraisal licenses are issued state by state, so an insurer, a DSCR lender or a national builder that wants the same analysis in 30 states needs appraisers licensed in each of them. Federal law, 12 U.S.C. 3351(a), requires states to honor another state’s credential on a temporary basis, but only for federally related transactions, which are mainly loans by federally regulated lenders that require an appraiser.134 Insurance, tax appeal, estate and private lending work sit outside that guarantee. For that work the rules vary by state; California, for example, says no temporary permit is needed.136 Appraisers work around the patchwork by holding several credentials, about 1.36 per person in 2025 (computed).28

Interstate licensure compacts by professionMember jurisdictions. Appraisal has no compact; federal temporary practice applies to federally related work only.
  1. Nurse Licensure Compact43 jurisdictions
    43
  2. Interstate Medical Licensure Compact44 states plus 2 territories
    46
  3. PSYPACT (psychologists)43 jurisdictions
    43
  4. Real estate appraisersNo compact proposed
    0

Sources: Nurse Licensure Compact; Interstate Medical Licensure Compact, which reports 240,184 licenses issued as of September 30, 2026; PSYPACT.138139140 Large holdouts include California and New York for nursing.

The federal fix has stalled. H.R. 5520, the Portal for Appraisal Licensing Act, would build a shared platform with the ASC for licensing, renewals and reciprocity. It has seen no action since it was introduced and sent to committee in September 2025, and a 2020 version also stalled.137 I found no proposal for an interstate appraiser licensure compact.

Consistency is the case for a national standard. In Fannie Mae’s random-sample quality reviews, the most common defect is collateral discrepancies, such as inaccurate condition and quality ratings and poor comparable selection.144145 The overall defect rate is low: in ACES’s second-quarter 2025 data, 1.51% of loans had a critical defect, and of those serious errors, 5.9% involved the appraisal.146

A national licensed workforce, in this article’s sense, is a delivery standard: shared tools, defined scopes of work, portable licensing and local appraisers on inspection. Independent appraisers can build it on shared infrastructure without consolidating into a few firms. The shared tools come first, and they are where appraisers have been slowest.

10 / The barriersWhich ones appraisers control

Appraisers have been slow to adopt technology. That is the barrier they control.

The research behind this article found eleven barriers between lower-cost analysis and new demand for complex property work. Lenders, appraisal management companies (AMCs, the middlemen that order appraisals for lenders), the GSEs, regulators and legislatures control most of them. The one appraisers control is their own use of technology, and residential appraisal has been slow to adopt it for a long time.

When I asked the companies that make appraisal report software, they told me that fewer than half of their residential users use the mobile inspection app, even though many of those apps come free or bundled with the software. The rest sketch the house and take notes on paper, then type it all in again at the office. By my estimate, fewer than half subscribe to market analysis software that helps derive adjustments and build a solid work file. Neither figure comes from a published survey. AI use is wider. In a McKissock poll with no stated sample size, 40% said they use AI for narrative and 23% had not used it.53 Menlo Ventures estimates that only about 3% of people who use AI pay for it,162 and I expect the share among appraisers is lower, which suggests most of that use is free chat tools that help with writing.

The standards no longer stand in the way. USPAP, the profession’s national standards, now includes Advisory Opinion 41, which adds no new requirements and sets out how to evaluate any tool, including AI. The National Association of Appraisers called generative AI another tool and noted that its members range from advanced users to non-users.4748

That gap is the opportunity, and it is Brynjolfsson’s first test, the one appraisers control. Appraisers who invest in technology and well-built systems can solve hard valuation problems in less time, which lowers what the work costs to produce. On the elastic side of the market, a lower cost brings in clients who could not justify the fee before, so those appraisers can grow their business by growing demand in their own markets.

Some of that growth needs no one else to move. Legal work, which I rate on my own judgment in chapter 08, faces no institutional barrier: executors and attorneys already order it, and a stronger report at a lower fee is worth ordering in more cases. Tool adoption blocks five of the eleven opportunities from chapter 08, more than any other barrier, and for legal work it is the only one. The other ten also need lenders, AMCs, the GSEs, regulators or legislatures to move. Brynjolfsson’s second test sits with them, because a lower cost becomes a lower price only if the saving reaches the client, and FHFA cites GAO that AMCs keep at least 30% of the fee.57 Chapter 11 sorts those changes by who can make them.

How many of the eleven opportunities each barrier blocksTool adoption blocks the most, and it is the only barrier appraisers control on their own.
  1. Tool adoptionAppraisers
    5
  2. Liability on new and split assignmentsInsurers, appraisers, lenders
    4
  3. Demand nobody has measuredResearchers, associations
    4
  4. State-by-state licensingStates, ASC, Congress
    3
  5. Few comparables for new formsAppraisers, data providers
    3
  6. Lender ordering systems and AMC feesLenders, AMCs
    3
  7. Scattered rules and rights dataMunicipalities, data vendors
    3
  8. Complex work at residential feesLenders, AMCs, appraisers
    3
  9. GSE and FHA form and eligibility rulesGSEs, FHA, FHFA
    2
  10. Waivers and AVMs skip the appraisalGSEs, lenders
    1
  11. Data collection moves to lower-cost collectorsGSEs, AMCs, appraisers
    1
11 / What it takesActions by who can take them

What adapting takes, and who else has to move

Adapting is the appraiser’s part: tools that make deep analysis affordable, and training in land use and zoning, income and rental regulation, construction cost, hazard and insurance. Two more changes are up to institutions. Licensing and delivery have to give national clients consistent coverage, and GSE and FHA rules have to recognize middle housing. The list below assigns each change to the people who can make it. Your checkmarks are saved in this browser.

0 of 12 checked · Saved in this browser only.

12 / May 20, 2027A date to decide
215days until UAD 3.6 is required for every new GSE appraisal submission
  1. UAD 3.6 mandate
  2. Last day for UAD 2.6 under the exception
  3. UAD 3.6 mandatory for all new submissions

UAD 3.6 becomes mandatory for all new submissions on May 20, 2027, and UAD 2.6 retires on June 28.4142 From that date every GSE appraisal carries structured condition, quality, measurement and comparable data that models can read and check.

Run the three tests from chapter 02 once more. Loan work fails the third, and it will keep following loan volume. UAD 3.6 may still help it: the new report records far more about a home than UAD 2.6 did, and that detail could show how many properties are too complex for a waiver. Complex property work can pass all three tests if appraisers adopt the tools that cut its cost and share the saving: part lowers the price for the client, and part stays with the appraiser as margin. If demand then rises as the price falls, lower-cost analysis can grow the profession the way more efficient coal use grew coal consumption.

The same date works as a deadline for deciding which part of your practice should grow. Three steps fit before it. Switch to the mobile inspection app that may already come with your report software. Subscribe to a market analysis tool that helps derive adjustments and build the work file. Then pick one complex niche in your market, such as estates, ADUs or small multi-unit buildings, and build the comparable and rules file for it.

The layered street at dusk: brick rowhouses, a small apartment building and a corner building of flats with lit windows.
A street with more than one kind of home, if the analysis to finance it becomes cost-efficient enough.AI-generated illustration
Appendix A / Evidence mapHow this article was built

Every claim traces to a finding, including the ones against it

This article was drafted from a research file of 157 findings and 152 sources; ten more sources were added during fact-checking and editing. These are the findings that carry the most weight on each side. Each one is cited in the chapter linked beside it.

Supports the argument

  • Jevons, 1865Coal per ton of Scottish iron fell to under a third while the industry’s total coal use rose tenfold.Chapter 02
  • Radiology grewResidency programs offered 1,241 positions in 2026 and filled 97.6%, ten years after a prediction that radiologists would be obsolete.Chapter 03
  • Accountants up, bookkeepers downBLS projects bookkeeping clerks down 6% and accountants up 5% from 2025 to 2035.Chapter 03
  • One ADU house, two valuesTwo appraisers valued the same Burbank home with an ADU at $1.4 million and $1.9 million.Chapter 05
  • Models miss conditionMean AVM error was 4.35 points higher for homes in poor condition in a 2024 study of Atlanta and Memphis.Chapter 05
  • Small multi-unit buildings fadedBuildings with 2 to 4 units fell from about 6% of new homes in 1972 to about 1% in 2025.Chapter 06
  • Fire losses underinsured71% of California homes destroyed by fire from 2018 to 2023 were underinsured, by about 19% on average.Chapter 08

Cuts against it

  • Backfire is rareIn energy, typically 5% to 40% of an efficiency saving comes back as extra use, and the total effect usually stays under 60%.Chapter 02
  • Translators shrankMachine translation is linked to about 28,000 fewer translator jobs than expected from 2010 to 2023.Chapter 03
  • Waivers already workACE loans had about 8.9% lower 90-day default rates than comparable appraised loans.Chapter 04
  • Waivers take a shareWaivers covered 28% of GSE loans in March 2026 and 19% in June.Chapter 01
  • Townhouses at a recordTownhouses reached 18.7% of single-family starts in Q3 2025, so builders do build some attached homes.Chapter 06

Appendix B: seventeen objections the argument was tested against

NarrowJevons backfire is rare; energy research mostly finds partial rebound.

Agreed. Backfire needs elastic demand, so this article applies it only to complex property work and names the data that would test it.

ConcedeWaivers proved technology replaces appraisals, and those loans performed better.

True for simple refinance and purchase loans, which are loan work. This article’s claim is about complex property work.

NarrowAppraisers are not the main barrier; lenders could not even order hybrids.

Agreed: institutions control several barriers. Tool adoption is the one appraisers control, and it blocks more opportunities than any other.

NarrowAppraisers reject bifurcation for rational reasons: liability and fees.

Both causes are set by institutions. Bifurcation (someone else collects the data) is a different thing from tool adoption (the appraiser collects better data faster).

NarrowBuilders already build attached product; townhouses are at a record.

Fee-simple townhouses finance like detached homes. The lag is in condo regimes and 2 to 4 unit buildings.

ConcedeThe typical new lot is far smaller than a quarter acre.

Correct: the 2025 median was 8,543 square feet, and the argument does not rely on lot size.

HoldsMarkets already pay for walkable mixed neighborhoods.

They do, and hedonic models captured the Kentlands premium. The friction sits at construction financing, early comparables and eligibility rules.

NarrowMinneapolis and SB 9 show low uptake for reasons other than appraisal.

Cost, subdivision law and defect liability matter. Appraisal is presented as one documented friction among several.

NarrowThe national housing shortage is disputed.

Estimates run from 3.7 to 5.5 million homes, so the article argues from affordability instead of a single shortage figure.

HoldsTranslators show AI can shrink a profession that looked like a Jevons candidate.

Professions shrank when the output itself was automated with no licensed judgment attached. Appraisal’s licensed opinion is protected only for federally related transactions.

ConcedeGains flow to adjacent roles: data collectors, analysts and vendors.

A real risk, which is why the article asks appraisers to own the analysis and the tools.

NarrowRadiology’s growth came from aging and population growth.

Accepted. The narrower lesson: imaging got less expensive and radiologists kept the licensed read while volume rose.

NarrowA national licensed workforce means consolidation and fewer independents.

Defined here as a delivery standard: shared tools, defined scopes, portable licensing, local appraisers on inspection. Independents can build it on shared infrastructure.

OpenThere is no proof complex property demand grows when price falls.

Agreed, and chapter 08 says so. The case rests on legal work such as estates, divorces and disputes, whose demand follows those events rather than loan volume.

OpenComplex work is a fixed market: only so many estates, divorces and disputes happen each year.

The events are fixed in the short run, and the share that gets an appraisal can change. At $2,000 to $5,000, many parties settle for an agent’s opinion, an online estimate or an assessed value, and a lower price could win some of them back.

NarrowAppraisal quality is fine; critical defect rates are low.

GSE reviews still cite condition, quality and comparable selection most often, so the argument is about consistency on complex property, without a crisis framing.

NarrowHazard effects on price are small on average.

Hazard is framed through carrying costs and insurance, where the evidence is larger; the small average price effect is cited as context.

Verdicts: Holds, the claim survives as written; Narrow, it survives with tighter wording; Concede, the objection is true and the argument builds on it; Open, the data does not exist yet.

Research checked October 17, 2026. Figures marked computed were calculated by ValuSignal from the cited data. Vendor figures are company claims and are labeled as such. The ironworks, streets, parcel and interiors are AI-generated illustrations made with Higgsfield and show no real property. The author is a residential appraiser. General information, not legal, lending or appraisal advice.

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  89. Zhu, Neal, Young, AVM accuracy, Cityscape 26(1), 2024Academic
  90. FHFA, Final rule on AVM quality controlPrimary
  91. California FAIR Plan key statisticsPrimary
  92. FRBSF Economic Letter 2024-22, Wildfires and real estate valuesPrimary
  93. FEMA, Risk Rating 2.0 national rate analysisPrimary
  94. RFF, Housing market overvalued due to unpriced climate risksAcademic
  95. Insurance Journal, Risk Rating 2.0 full-risk increases, Dec 2025Trade
  96. TD Economics, Florida condo market, May 2025Trade (bank research)
  97. Mortgage Professional America, Fannie-ineligible Florida condos, Apr 2025Trade
  98. HUD, FHA MPR modernization redline, Handbook 4000.1Primary (draft)
  99. Fannie Mae Selling Guide B2-3-04Primary
  100. Fannie Mae Selling Guide B4-1.4-07Primary
  101. Fannie Mae Selling Guide B4-2.1-03, Ineligible projectsPrimary
  102. CNU, FHA raises commercial space finance cap, Dec 2012Advocacy
  103. Conduit Street, FHA recognizes ADU income, Oct 2023Trade (summary of HUD letter)
  104. Gyourko and Rybczynski, Financing New Urbanism, Wharton WP 369Academic
  105. Terner Center, Unlocking the Potential of Missing Middle Housing, Dec 2022Academic
  106. NAHB, Financing Missing Middle HousingTrade
  107. Chapple et al., Implementing the Backyard Revolution, UC Berkeley 2021Academic
  108. Brown, Appraising properties with ADUs using the income approachTrade (summary of journal article)
  109. NAHB Eye on Housing, Townhouse construction share gains continue, Jan 2026Trade (Census data)
  110. NAHB Eye on Housing, Short-term townhouse construction weakness, Aug 2026Trade (Census data)
  111. NAHB Eye on Housing, Best year for missing middle since 2007, Mar 2026Trade (Census data)
  112. FRED, Completions in 2 to 4 unit buildings (COMPU24USA)Primary
  113. NAHB Eye on Housing, Shrinking lots trend levels off, Jul 2026Trade (Census data)
  114. City of Dallas, SB 15 information sheetPrimary
  115. City of Dallas, SB 840 information sheet, Aug 2025Primary
  116. Office of the Texas Governor, SB 15, SB 840, HB 24 signing, Aug 2025Primary
  117. Sightline, Oregon's zoning reforms are working, Jun 2025Advocacy
  118. City of Portland, Middle housing production, Feb 2025Primary
  119. Pew, Minneapolis land use reforms, Jan 2024Trade (research nonprofit)
  120. Washington HB 1110 final bill reportPrimary
  121. Congressional Research Service, Estimates of a housing shortage, Dec 2025Primary
  122. Cato, Questioning the shortage narrative, Sep 2025Advocacy (think tank)
  123. Harvard JCHS, State of the Nation's Housing 2026, price-to-income mapAcademic
  124. Tu and Eppli, Valuing New Urbanism: The Case of Kentlands, 1999Academic
  125. Washingtonian, Kentlands once seemed like a failure, Apr 2018Trade
  126. ATTOM, 2025 Year-End Home Flipping ReportVendor (data)
  127. HousingWire, DSCR loan volume growth and fraud risks, Sep 2026Trade
  128. NAHB Eye on Housing, Weaker conditions for built-for-rent, Mar 2026Trade (Census data)
  129. Econofact, Do private equity firms own 20% of single-family homes?Academic
  130. AirDNA, US review November 2025Vendor (data)
  131. Insurance Business, Insurers' rebuild estimates drive underinsurance, Sep 2026Trade (academic study)
  132. United Policyholders, 2025 LA Wildfires 12-month surveyAdvocacy
  133. Cotality, Wildfire Risk Report 2025Vendor
  134. 12 U.S.C. 3351Primary
  135. Federal Register, ASC Policy Statements, May 28, 2013Primary
  136. California BREA, Temporary Practice PermitsPrimary
  137. Appraisal Institute, PAL Act key points, 119th CongressTrade
  138. Nurse Licensure CompactPrimary
  139. Interstate Medical Licensure CompactPrimary
  140. PSYPACT mapPrimary
  141. Opteon, company milestones, Mar 2022Vendor
  142. HousingWire, Opteon acquires Equity Valuation Partners, Nov 2025Trade
  143. Class Valuation, Staff appraiser team, Jul 2025Vendor
  144. Fannie Mae Quality Insider, Jan 2025Primary
  145. Fannie Mae Quality Insider, Dec 2025Primary
  146. ACES, Q2 2025 Mortgage QC Industry TrendsVendor
  147. HousingWire, VA loan appraisal rules and fees, Jun 2026Trade
  148. Foley and Lardner, Texas SB 15, 17, and 840, Jul 2025Trade (law firm)
  149. Cookson, Gallagher, Mulder, Coverage Neglect in Homeowners InsuranceAcademic
  150. Appraisal Buzz, State of the industry update, 2016Trade
  151. Banking Day, Valex clears 1,000 valuations a day, 2007Trade
  152. MortgageOrb, Private lending in 2025Trade (secondary)
  153. CNU, Study confirms TND price premium (four communities)Advocacy (academic study)
  154. Koster, van Ommeren, Volkhausen, Short-Term Rentals and the Housing Market: Airbnb in Los Angeles, CEPR DP13094Academic
  155. Fannie Mae, DU Version 12.1 release notes, Mar 21, 2026Primary
  156. ASC, Idaho appraiser program final compliance review, Dec 6, 2024Primary
  157. BLS OOH, Financial AnalystsPrimary
  158. BLS OOH 2008-09, Tellers (archived)Primary
  159. Appraisal Institute, Appraisal Now, Sep 1, 2026Trade (AEI data)
  160. Withum, Key changes from Florida HB 913: inspections and reserves, 2025Trade (accounting firm)
  161. Withum, SIRS update: what HB 913 did and did not do, 2025Trade (accounting firm)
  162. Menlo Ventures, 2025: The State of Consumer AI, Jun 2025Investor survey
  163. Emily Badger and Quoctrung Bui, Cities start to question an American ideal: a house with a yard on every lot, The New York Times, Jun 18, 2019Press (data analysis)
  164. Fannie Mae Selling Guide B4-2.1-02, Waiver of project review (08/05/2026)Primary

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