Complaint Filing — Educational Guide

A complaint is a serious step.

When you file a formal complaint with a state appraisal board, an AMC, or the CFPB, you are alleging that a regulated professional or business has engaged in misconduct. Such complaints:

• Can trigger investigations, audits, and disciplinary proceedings
• Become part of the appraiser's permanent regulatory record
• May subject you to legal exposure if the complaint is found to be malicious, retaliatory, or knowingly false
• Should be reserved for cases where you have factual basis to believe a violation occurred, not for cases where you simply disagree with the appraiser's professional judgment

Disagreement is not misconduct.

An appraiser concluding a value lower than you hoped, or weighting comparables differently than you would, is not, by itself, misconduct or grounds for a complaint. The appraiser is the trained professional whose judgment determines value, and reasonable professionals can disagree.

A formal complaint is appropriate when you have factual basis to believe one of the following occurred:

• The appraiser failed to develop or report the appraisal in accordance with USPAP
• The appraiser made material factual errors that affected the value (e.g., wrong square footage, wrong bed/bath count)
• The appraiser used comparables that were clearly not credible (e.g., distressed sales without adjustment, sales from outside the relevant market)
• The appraisal showed evidence of bias based on a protected class characteristic (race, color, religion, national origin, sex, familial status, disability)
• The appraiser had an undisclosed conflict of interest
• The AMC or lender exerted improper pressure on the appraiser

Try the lender's process first.

Before filing a regulatory complaint, exhaust the lender's reconsideration of value (ROV) process. Most appraisal disputes can be resolved through ROV without escalating to a regulator. The very tool you used to prepare your ROV (RaiseAppraisal) was designed to support this process.

If the lender accepts your ROV and a revised appraisal is issued, a complaint may no longer be necessary or appropriate.

The right venue depends on what kind of issue you're alleging.

1. Suspected Bias Based on a Protected Class

If you have factual basis to believe the appraisal was influenced by your race, color, religion, national origin, sex, familial status, disability, or other protected characteristic:

HUD FHEO

Federal authority that investigates appraisal-bias claims under the Fair Housing Act. File online at hud.gov/fairhousing/fileacomplaint. Phone: 1-800-669-9777.

CFPB

Monitors appraisal practices and lender behavior. consumerfinance.gov/complaint.

State AG

Many state Attorneys General investigate housing discrimination. Find yours at naag.org/find-my-ag.

2. USPAP Violations or Professional Misconduct

If you have factual basis to believe the appraiser violated USPAP (Uniform Standards of Professional Appraisal Practice) or otherwise engaged in professional misconduct:

State board

Each state has a board that licenses and regulates appraisers. Find yours via the Appraisal Subcommittee's National Registry: asc.gov/National-Registry/FindAnAppraiser.

Appraisal Foundation

Maintains USPAP. Q&As may help you understand whether something is a USPAP issue: appraisalfoundation.org.

3. AMC (Appraisal Management Company) Misconduct

If you believe the AMC pressured the appraiser, mishandled the assignment, or acted improperly:

State AMC regulator

Most states regulate AMCs separately from appraisers. Often the same agency that regulates appraisers also regulates AMCs.

Lender compliance

Federally regulated lenders have internal AIR (Appraiser Independence Requirements) compliance functions. Contact the lender directly to report concerns about the AMC.

4. Lender Misconduct (AIR, RESPA, TILA)

If you believe the lender violated AIR, RESPA, TILA, or other federal lending laws:

CFPB

consumerfinance.gov/complaint

OCC

National banks: helpwithmybank.gov

FDIC

State banks (FDIC-insured): fdic.gov/consumers/assistance

NCUA

Credit unions: mycreditunion.gov

Other lenders

CFPB

5. Loan Officer or Mortgage Broker Misconduct

Loan officers and brokers are licensed through NMLS. File a complaint at nmlsconsumeraccess.org.

6. State-Specific Consumer Protection Issues

All states have consumer protection divisions that handle housing-related complaints — contact your State Attorney General.

A formal complaint should be specific and factual. Generally:

1. Identify yourself (most boards do not accept anonymous complaints)
2. Identify the subject of the complaint (name, license number, employer if applicable)
3. Describe the transaction (property address, loan number if applicable, dates)
4. State the specific allegations — what did the person do (or fail to do) that you believe constitutes a violation?
5. Provide supporting documentation — copies of the appraisal, your ROV submission, the lender's response, any communications relevant to the complaint
6. Cite the specific rule or law you believe was violated if known (e.g., “USPAP Standards Rule 1-1(b)” or “Fair Housing Act Section 805”)
7. Sign and date the complaint

To protect yourself from defamation or retaliation claims, do NOT include:

• Personal attacks or speculation about the appraiser's character
• Allegations you cannot factually support
• Statements you know or suspect to be false
• Threats or demands
• Any reference to the appraiser's race, religion, or other protected characteristics (unless the complaint is specifically about discrimination, in which case stick to factual indicators)

A complaint should read like a careful, professional report of what you observed and why you believe it warrants investigation.

Each agency has its own process, but generally:

1. Acknowledgment — Most agencies acknowledge receipt within a few days to a few weeks.
2. Initial review — The agency determines whether the complaint falls within their jurisdiction and whether it states a potential violation. Many complaints are dismissed at this stage.
3. Investigation — If the complaint moves forward, the agency investigates. The subject of the complaint is generally notified and asked to respond. You may be asked for additional information.
4. Resolution — Outcomes range from dismissal, to a warning, to license discipline, to civil or criminal referrals. Most investigations take many months.
5. Notification — You will generally be notified of the outcome, though detailed findings may not be shared.

You will not have a “case manager” pushing your complaint forward — these processes can be slow. Be patient.

For straightforward complaints (e.g., wrong square footage), you can usually file on your own.

For complaints involving discrimination, significant financial harm, or potential litigation, consider consulting an attorney who specializes in fair housing, consumer protection, or real estate. Many such attorneys offer free consultations.

Resources for finding an attorney:

• National Fair Housing Alliance: nationalfairhousing.org
• Local legal aid: lsc.gov/find-legal-aid
• State bar lawyer referral services

If your complaint is about us — for example, you believe we generated a document that violated AIR or contained false information — please contact us first:

Email

compliance@raiseappraisal.com

Subject

Compliance Concern

We take such concerns seriously and investigate every report. If you remain unsatisfied, you may also file with:

• The CFPB: consumerfinance.gov/complaint
• The FTC: reportfraud.ftc.gov
• Your state's Attorney General

We built RaiseAppraisal to help borrowers exercise their right to a fair appraisal review. Most appraisal disputes are resolved through the ROV process without anyone needing to file a complaint. Filing a regulatory complaint should be reserved for cases where you have factual basis to believe a real violation occurred — not for cases of disappointment with a professional's judgment.

The tools above exist to protect consumers from genuine misconduct. Use them carefully, factually, and only when warranted.

See also: USPAP & Appraiser Independence Statement · Fair Lending Statement