21st Century ROAD to Housing ActWhat the new housing law changes for appraisals and collateral risk, and when

The Senate Banking Committee approved the ROAD to Housing Act, S. 2651, by 24 to 0 on July 29, 2025. The Senate attached it to the 2026 defense authorization bill, and it was dropped from the final version. The House then used its own bill, H.R. 6644, as the vehicle, and the two chambers traded amendments through the spring. The Senate passed the final text 85 to 5 on June 22, 2026, and the House 358 to 32 on June 23.

Under Article I, Section 7 of the Constitution, a bill the president neither signs nor returns within ten days, Sundays excepted, becomes law. The bill was presented on June 29. President Trump did not sign it and, as HousingWire reported, tied that to Congress not passing the unrelated SAVE America Act. It became law on July 11. The enacted short title is the “21st Century ROAD to Housing Act”; the earlier Senate bill carried the shorter name.

Since 2008, FHA has required a state-certified appraiser. Section 403 amends the National Housing Act so that a state-licensed appraiser can also appraise FHA-insured properties, if the assignment is within the scope of practice for that credential and the appraiser completes new FHA-specific education. Appraisers already on the FHA roster do not need the new course. HUD has 240 days from enactment to issue guidance, and the change takes effect no later than 180 days after that guidance. If HUD uses the full time, licensed appraisers could start FHA work by about September 4, 2027. As of October 25, 2026 we found no HUD mortgagee letter on it.

The same section adds a “State credentialed trainee appraiser” category to the National Registry, leaves liability for a trainee’s work with the supervising certified appraiser, and does not require any state to create a trainee credential. It lets the Appraisal Subcommittee adjust National Registry fees with the approval of the FFIEC, authorizes workforce grants, and adds VA, USDA’s Rural Housing Service and HUD to the FFIEC Act provision that houses the ASC.

How many appraisers does that reach? Our snapshot of the ASC National Registry from October 11, 2026 holds 87,520 active credentials, and 5,780 of them, 6.6%, are Licensed. Among the credentials that can appraise residential property under a residential scope (Certified Residential plus Licensed), the Licensed share is 12.3%. These are credentials, not people: an appraiser licensed in three states counts three times.

The House version of the Appraisal Modernization Act, H.R. 5975, would have written a detailed ROV standard into the Truth in Lending Act. The enacted Section 704(a) is one sentence.

The sentence tells USDA, VA, the FHA Commissioner and the FHFA Director to require lenders on federally backed loans to have a procedure for borrower requests. It sets no deadline, no form and no list of triggers. FHFA moved first. According to the National Fair Housing Alliance, FHFA issued a regulatory order on September 18 “stating FHFA’s view that the 2024 policies comply with the ROAD Act” and requiring Fannie Mae and Freddie Mac to stay in compliance. NFHA called it the first federal action implementing the right. We could not find the order on FHFA’s own site, so this account is NFHA’s. GSE loans therefore have a settled process. For FHA, VA and USDA loans, we found no notice under 704(a) as of October 25, 2026.

On October 7, the American Bankers Association and 11 other financial and real estate trade groups wrote to all four agencies asking for one uniform process built on the Fannie Mae and Freddie Mac standards. Before passage, ICBA and another group wrote to Congress on November 16, 2025 with “significant concerns regarding Section 705,” the earlier number of this provision, and the Mortgage Bankers Association reportedly raised lender liability concerns. Baker Donelson describes the enacted provision as implementation dependent, because most large lenders already run ROV under GSE and fair lending expectations.

Section 704(b) asks the Comptroller General to study whether a searchable, downloadable, appraisal-level database is feasible, drawing on appraisal and automated valuation data held by FHFA and the GSEs, HUD, USDA and VA. GAO has to weigh privacy, antitrust, the Freedom of Information Act, the Home Mortgage Disclosure Act, appraiser professional conduct, and whether records back to January 1, 2017 could be included. The report is due 240 days after enactment, and Congress must hold a hearing on it. The Act does not create a database.

For collateral teams, a public database would add something the market lacks today: appraised values and comparable selections that any reviewer could benchmark against. It would also raise questions about appraiser privacy and model training on appraisal data. If GAO finds it unworkable, appraisal data stays inside the GSE and agency systems that hold it now.

A search of the enrolled text finds no provisions on automated valuation model quality control, hybrid or desktop appraisals, appraisal waivers, PAREA, de minimis thresholds or appraisal bias standards. Those topics are moving through a separate track: Executive Order 14393 of March 13, 2026, and the October 22, 2026 order on housing costs. Neither order cites the Act.