USPAP & Appraiser Independence Statement

RaiseAppraisal.com is software that helps borrowers and their representatives prepare a Reconsideration of Value (ROV) request for submission to a lender or Appraisal Management Company (AMC). Our work is built around respect for the appraisal profession and strict adherence to the federal Appraiser Independence Requirements (AIR).

This page explains exactly what we are, what we do, and — equally important — what we do not do.

RaiseAppraisal is a software tool.

The borrower (or their loan officer or broker, when authorized) operates the tool. They upload an appraisal, answer questions about their property, and the software produces a packet of documents the user can review, edit, and submit through their lender's standard ROV process.

We are functionally analogous to tax-preparation software like TurboTax — we do not file your taxes, we do not represent you to the IRS, and we are not your accountant. We provide the tool; you are the actor.

We are not, and we do not act as:

• A licensed appraiser
• An Appraisal Management Company (AMC)
• The lender, the borrower's representative in the appraisal process, or any “party in the mortgage transaction” within the meaning of AIR
• A direct communication channel with appraisers — we never contact appraisers on a user's behalf
• The provider of an appraisal, valuation opinion, or value certification

The documents we generate are tools the user submits as part of their own lender-defined ROV process. The user is the submitter; we are not.

What AIR Prohibits

AIR (codified by Dodd-Frank Section 1472, embodied in FNMA Selling Guide B4-1.3-12 and equivalent FHLMC, FHA, and VA guidance) prohibits any party in the mortgage transaction from “coercing, influencing, or otherwise causing the value to be based on any factor other than the appraiser's independent judgment.”

Why We Are Not Bound by AIR (and How We Behave As If We Were)

AIR governs lenders, AMCs, and parties in the mortgage transaction. As a software tool used by the borrower, RaiseAppraisal is not a regulated party under AIR. The borrower's right to request reconsideration of value with factual support is expressly preserved by FNMA B4-1.3-12 and parallel FHLMC, FHA, and VA guidance.

Even though we are not directly bound by AIR, we voluntarily adhere to its principles:

The “Coercion” Line

Industry interpretation of AIR distinguishes between:

• Permitted: Submitting factual information for the appraiser's consideration, including alternative comparables and noted property characteristics, framed as questions or requests
• Prohibited: Demanding a specific value, threatening consequences, providing target values, or otherwise pressuring the appraiser

Our entire document framework — the language we use, the tone we strike, what we include, and what we never include — is engineered to stay on the permitted side of this line.

The Uniform Standards of Professional Appraisal Practice (USPAP) governs the conduct of licensed appraisers. RaiseAppraisal is not an appraiser, so USPAP does not directly apply to us. However, the documents we help borrowers prepare are intended to assist the appraiser in performing their USPAP-compliant duties.

We respect USPAP by:

1. Never providing a valuation opinion. Our software generates analyses, comparable suggestions, and arguments for the borrower to consider submitting. We do not provide a value, an opinion of value, or a valuation conclusion.
2. Citing factual sources. All comparable sale data we surface comes from public records and licensed real estate data providers, with sources cited.
3. Respecting the appraiser's independent judgment. Our documents acknowledge that the appraiser is the trained professional whose judgment determines the final value. We provide information for their consideration; we do not direct their conclusion.
4. Not soliciting USPAP violations. Our generated arguments do not ask the appraiser to violate any USPAP standard. The appraiser remains free to maintain their original conclusion if they believe their analysis is correct.

FIRREA (Financial Institutions Reform, Recovery, and Enforcement Act) requires appraisals for federally-regulated transactions and sets minimum standards for those appraisals. RaiseAppraisal does not perform FIRREA-regulated activities — we do not appraise, we do not lend, we do not regulate. The appraisals we help users challenge are FIRREA-regulated work products produced by licensed professionals.

Our role is downstream: we help the consumer of an appraisal (the borrower) understand and respond to that appraisal through their lender's ROV process.

Every document we generate carries:

1. A “not an appraisal” disclaimer clarifying our role
2. A “no value coercion” statement affirming that the appraiser's independent judgment is sole and final
3. An AI disclosure noting that the document was generated with AI assistance and that the user is responsible for review and accuracy
4. A factual basis — every comparable, every adjustment, every claim must be grounded in public records or licensed data sources

Our generated documents do not, and our software is engineered not to produce:

1. A target value for the appraiser to reach
2. A demand that the appraiser change the value
3. A statement that the appraiser is wrong or has violated USPAP
4. Any threat, accusation, or coercive language
5. Any reference to the borrower's protected class characteristics, the neighborhood's demographics, or any other factor prohibited by ECOA or the Fair Housing Act
6. Any value opinion attributed to RaiseAppraisal

FNMA Selling Guide B4-1.3-12 (Reconsideration of Value) and parallel FHLMC, FHA, and VA guidance recognize that the borrower may request a reconsideration of value when the borrower disagrees with the original appraisal's value conclusion and has factual basis to support a different conclusion. This right is what RaiseAppraisal helps borrowers exercise.

The lender, AMC, and appraiser receive the borrower's submission, evaluate it on its merits, and the appraiser independently determines whether to revise the appraisal. The appraiser's decision is final.

Most states regulate the practice of appraisal and require licensure for any person providing a valuation opinion or appraisal. RaiseAppraisal does not provide valuation opinions or appraisals — we provide software that helps borrowers organize their factual support for an ROV request. We do not believe state appraisal practice statutes apply to our software, but we comply by:

1. Never providing a value
2. Never operating in any state's defined “appraisal practice” activities
3. Disclaiming clearly in every document that we are not an appraiser
4. Not holding any license, registration, or credential in the appraisal field, and not implying we hold any

If a state regulator wishes to discuss our service, we welcome the dialogue. We are not aware of any state that classifies software like ours as the practice of appraisal, but we are prepared to make our case if questioned.

If you receive an ROV submission from one of our users:

1. The submission is the borrower's, not ours. The borrower has authored or reviewed and submitted it.
2. The information is factual. Comparable sales come from public records and licensed data providers, with sources cited.
3. The tone is collaborative. Our software produces requests, not demands.
4. No target value is being communicated. Our software does not generate target values or value demands.
5. Our software is AI-assisted. This is disclosed on every document. The borrower is responsible for review and accuracy of any submission.

If you have concerns about a specific submission generated by our software, contact us at compliance@raiseappraisal.com and we will investigate promptly.

We welcome feedback from appraisers, AMCs, lenders, and regulators. If you believe a document generated by our software fell short of the standards above, please tell us:

Email

compliance@raiseappraisal.com

Subject

“Compliance feedback re: ROV document”

Every report is reviewed by our compliance team. Where appropriate, we update our document templates and AI prompting to address concerns.

Entity

RaiseAppraisal.com (Malama Funding LLC)

Team

Compliance Team

Email

compliance@raiseappraisal.com

Mail

[address]

See also: Fair Lending Statement · Complaint Filing Educational Guide