AppraisalPilot

Field Report No. 04

Is the new executive order waiving appraisals? What it actually says

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On its own, the October 22, 2026 executive order doesn't waive a single appraisal. It tells the FHFA Director to consider waiving appraisals on some limited cash-out refinances, where the GSEs' data support it, and it sets no date for that. In Field Report No. 04, Josh Stalk, Licensed Residential Appraiser (NV), reads the order's appraisal lines word for word, then walks through what a hybrid appraisal actually is on the new report (UAD 3.6), from the GSEs' own documents.

What does the October executive order say about appraisals?

The order is Executive Order 14438, "Decreasing Housing Costs for the American People," signed October 22, 2026 and published in the Federal Register on October 28, 2026 (91 FR 68007). Two sections touch appraisals.

Section 2 is about a pilot. If the FHFA Director determines it is "in the best interests of the [Enterprises] or the Federal Housing Finance Agency (FHFA), and the American public," he is to direct Fannie Mae and Freddie Mac to establish a pilot program, "applicable only to mortgages made after the establishment of the pilot program," that reviews their loans "using automated valuation models and other available data to assess current market value, and to identify borrowers who appear to satisfy equity and other requirements for cancellation of mortgage insurance." Servicers would be told "to reduce or eliminate unnecessary documentation requests, appraisal costs, and other administrative barriers to cancellation."

Section 4 is about title acceptance. Again only if the Director determines it is in the best interests, the GSEs are to expand the title acceptance pilot "into an ongoing program, available nationwide through both Enterprises." Then the line that made the headlines:

"In expanding the program, the Director shall consider: ... waiving appraisals, income re-verification, and other documentation requirements for limited cash-out refinances that reduce the borrower's monthly payment, where the Enterprise's existing data support doing so"

In March, an earlier order, Executive Order 14393, "Promoting Access to Mortgage Credit," told six federal financial regulators, the FHFA Director among them, that they "shall consider" expanding "the use of alternative valuation models, desktop and hybrid appraisals, and artificial intelligence valuation tools," and "reducing appraisal requirements for low-risk transactions, including low loan-to-value refinancing and small-balance loans."

Does the order change anything for appraisers today?

Josh's read: read it the way you'd read an engagement letter. Every appraisal line in the October order is conditional: if he determines, shall consider, where the data support it. The order sets no date for any of it, and those lines are written to the FHFA Director. Until the FHFA, Fannie Mae or Freddie Mac act, the guides you work under haven't changed.

Waivers aren't new, either. Fannie Mae's Selling Guide already has value acceptance, where "an appraisal is not required" for eligible loans, and limited cash-out refinances are already on its list. Working RE reported in March 2026 that, by the AEI Housing Center's count, appraisal waivers were used on roughly 23 percent of GSE loans in October 2025.

Are hybrid appraisals taking over?

On October 27, 2026, HousingWire ran an opinion column headlined "UAD 3.6 is coming. Hybrid appraisals are built for it." Its author, an executive at Class Valuation, a company that sells hybrid appraisals, writes: "Hybrid eligibility has risen to the high-90% range for some programs." Eligible isn't the same as used: Working RE says there's no good count yet of how many hybrids are being done.

What is a hybrid appraisal on the new report?

Four things, from the GSEs' own documents.

  1. It's still your appraisal. Fannie Mae's Selling Guide (B4-1.2-03) says a hybrid uses property data collection "by a trained and vetted third party (such as a real estate agent, insurance inspector, appraiser, etc.)." The data collection and the appraisal report are separate assignments.
  2. The collector collects. You rate. The URAR Reference Guide says a property data report "is limited to property characteristics and does not include opinions of value." Fannie Mae says the appraiser relies on the data collected, and other sources if needed, to identify property characteristics, including condition. Your quality and condition ratings stay yours.
  3. The report says what you did. Property Valuation Method is always required: Traditional, Hybrid, Desktop or Exterior. Pick Hybrid, and Property Data Report Used must be Yes, with the collector's occupation, company name and company address. The effective date of a hybrid is the date you develop the opinion of value, not the day the data was collected.
  4. Your certification has to match what you did. The UAD compliance rules warn when the certification doesn't line up with the Property Valuation Method (UAD1515 for a hybrid: "The Appraiser Certification (#10) does not align with the 'Property Valuation Method'."). On a hybrid, it's the version that begins: "I did not personally perform an onsite inspection of the subject property."

More on what the compliance rules catch: UAD 3.6 mistakes the GSEs flagged in early reports.

The order says traditional, but a data collector went instead of you. Which method do you pick?

Hybrid. The URAR Reference Guide says it plainly: "Regardless of what was ordered, Property Valuation Method represents what was completed." A recent collection of property data, in place of your own onsite inspection, is a hybrid. Traditional means the appraiser who signs the report inspected the inside and the outside, on site. A desktop is built on other third-party data, not a recent collection of property data.

What should I do this week?

  1. Read the order's appraisal lines yourself. They're word for word in the Field Notes.
  2. Watch for announcements from the FHFA, Fannie Mae and Freddie Mac. Until they act, the guides you work under haven't changed.
  3. If you take hybrid work, check the property data report before you start: the collector's occupation, company name and address, and how they inspected the outside and the inside.
  4. Before you sign a hybrid, make three things match: Property Valuation Method says Hybrid, Property Data Report Used says Yes, and your certification says you did not personally perform an onsite inspection.

The Field Notes have the order's appraisal lines word for word, a hybrid checklist with its sources, and a reply you can send when someone asks if appraisals are going away.

Education, not legal or compliance advice. Check your client's and each GSE's current requirements.

Questions appraisers ask

Does the October 2026 executive order waive appraisals?

Not on its own. Executive Order 14438 says that, in expanding the title acceptance program, the FHFA Director "shall consider" waiving appraisals, income re-verification and other documentation requirements for limited cash-out refinances that reduce the borrower's monthly payment, where the Enterprise's existing data support doing so. It sets no date for that. Until the FHFA, Fannie Mae or Freddie Mac act, their current guides apply.

Does the order replace appraisals with automated valuation models?

No. The automated valuation models are in a different section, Section 2, a pilot to find borrowers who appear to qualify to cancel their mortgage insurance. It would apply only to mortgages made after the pilot is set up, and only if the FHFA Director determines it is in the best interests of the GSEs or the FHFA, and the American public.

What Property Valuation Method do I pick for a hybrid appraisal on the new report?

Hybrid Appraisal, whenever a recent collection of property data took the place of your own onsite inspection. The URAR Reference Guide says that regardless of what was ordered, Property Valuation Method represents what was completed. Property Data Report Used must then be Yes, and the effective date is the date you develop the opinion of value.

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