Originally published in the December 5, 2025, issue of AI’s Appraisal Now
Reprinted with permission from AI

The Appraisal Institute recently submitted comments to the U.S. Department of Housing and Urban Development (HUD) in response to its request for information on the future of reverse mortgage programs. In its letter, the Appraisal Institute emphasized the importance of retaining the second appraisal requirement, calling it a vital safeguard against overvaluation that protects the Mutual Mortgage Insurance Fund, supports accurate collateral valuation for investors, and ultimately safeguards senior homeowners.

The comments noted that many senior-owned properties exhibit deferred maintenance or condition issues that may not be fully captured in a single appraisal. A second appraisal provides an essential check that helps identify outliers, reduces the risk of inaccurate valuations, and ensures that the final value conclusion is both credible and defensible. The Institute stressed that any additional time or cost associated with this safeguard is minimal compared to the risks of removing it.

While acknowledging that HUD could refine the criteria for when a second appraisal is triggered and how appraisal results are reconciled, the Appraisal Institute underscored that the requirement itself remains crucial to maintaining program integrity.