Fair Lending Statement

RaiseAppraisal.com is committed to fair and equitable treatment of all users and to producing analyses and documents that do not consider, encode, or propagate any form of housing or lending discrimination.

1. We Do Not Consider Protected Class Characteristics

Our software does not consider, request, infer, or use any of the following in any analysis, comparable selection, ROV argument, or generated document:

• Race
• Color
• Religion
• National origin
• Sex
• Familial status (including pregnancy, having children)
• Disability
• Age
• Marital status
• Receipt of public assistance income
• Exercise of any right under the Consumer Credit Protection Act
• Any other characteristic protected by federal, state, or local fair lending or fair housing law

2. Sensitive Context Is Not a Valuation Input

Crime statistics by location have been identified by HUD's Fair Housing Office as a potential proxy for protected class discrimination because crime patterns can correlate with the demographic composition of neighborhoods. We do not use crime data to estimate value, score a borrower, make a protected-class inference, or justify a valuation outcome. If crime, demographic, or similar location context is reviewed, it is limited to checking whether proposed comparables remain in a reasonably comparable market area and do not jump from one materially different neighborhood context to another.

3. Demographic Data Is Not a Valuation Input

Race composition, ethnic origin, household income distribution, and similar demographic signals are not used to support a valuation conclusion, score a borrower, or make a protected-class inference. If neighborhood context is reviewed, it is used only as a guardrail for comparable relevance and market-area consistency.

4. Our Location Analysis Uses Only Neutral Factors

When we analyze location and propose location-based comparable adjustments, we use only objectively neutral factors:

• Geographic proximity (distance in miles)
• ZIP code matching
• Geographic features documented in public records (lot size, school district as a public-records attribute, geographic district)
• Property-record characteristics published by county assessors

We do not use as valuation drivers:

• Neighborhood demographics
• “Quality” or “desirability” ratings derived from demographics
• Crime statistics (except as the limited comparable-area guardrail described above)
• Any subjective characterization of an area

Algorithmic Exclusions

Our analysis pipeline is engineered with explicit exclusions:

• AI prompts include negative instructions: “Do not use neighborhood demographics, race, ethnicity, or any protected characteristic to support a value conclusion.”
• Crime or demographic context is not integrated as a scoring, valuation, or protected-class inference input.
• Any location-context review is limited to comparable-area consistency and avoiding unsupported jumps between materially different neighborhoods.
• Location-tier classification uses objective proximity and appraisal-defined market context, never a protected characteristic.

Algorithm Audit

Every year, we conduct an internal review of our algorithm's outputs across geographic regions to monitor for unexplained variation that could indicate disparate impact. Our methodology:

1. Sample of recent outputs aggregated by 5-digit ZIP
2. Comparison of opportunity scores, ROV success rates, and algorithm flags across ZIP-level demographics (using publicly available census tract data for the audit only — never used in the production algorithm)
3. Statistical analysis to identify any output disparities not explained by neutral factors
4. Where disparities are found, root-cause analysis and remediation

The audit findings are reviewed by leadership and outside counsel as needed. Material findings result in algorithm or product changes.

If you believe an appraisal you received was influenced by your race, color, religion, national origin, sex, familial status, disability, or other protected characteristic — independent of your use of RaiseAppraisal — you have rights and resources:

File a Fair Housing Complaint

HUD FHEO

Office of Fair Housing and Equal Opportunity. File online at hud.gov/fairhousing/fileacomplaint. Phone: 1-800-669-9777.

CFPB

Consumer Financial Protection Bureau. File online at consumerfinance.gov/complaint.

State AG

Many state Attorneys General investigate housing discrimination.

Information About Appraisal Bias

The federal PAVE (Property Appraisal and Valuation Equity) task force published an Action Plan in 2022 outlining the federal response to appraisal bias: pave.hud.gov.

The CFPB and HUD jointly maintain consumer-facing information about appraisal bias and how to address it: consumerfinance.gov/about-us/blog.

The federal PAVE task force has identified Reconsideration of Value (ROV) as a key tool for addressing appraisal bias. By making it easier for borrowers to prepare a well-supported ROV request, RaiseAppraisal contributes to the broader effort to ensure fair and accurate property valuations.

However:

• We do not specifically detect or label individual appraisals as “biased” — that determination requires investigation by HUD or other authorities and consideration of evidence beyond what's in a single appraisal report.
• Our software is a tool for ROV preparation, not a bias-detection system.
• If you suspect bias, please use the resources above to file a complaint with the appropriate authority.

We do not promise that using our software will:

• Eliminate appraisal bias from any individual transaction
• Result in a higher appraised value
• Result in a successful ROV outcome
• Guarantee fair treatment by your lender, AMC, or appraiser

We promise only that our software does not contribute to discrimination and is engineered to be neutral with respect to protected characteristics.

If you believe our software produced output that suggested or relied on protected class characteristics, please report it:

Email

compliance@raiseappraisal.com

Subject

“Fair Lending Concern”

Every report is reviewed by our compliance team. Where appropriate, we update our software, prompts, and templates to address concerns.

Entity

RaiseAppraisal.com (Malama Funding LLC)

Team

Compliance Team

Email

compliance@raiseappraisal.com

See also: USPAP & Appraiser Independence Statement · Privacy Policy · Complaint Filing Educational Guide