How the Mortgage Credit Order affects appraisers

By Mike Mignogna, MAI, SRA, AI-GRS, Appraisal Institute

President Trump’s Executive Order, Promoting Access to Mortgage Credit, was issued a little more than a month ago. While it is largely focused on residential lending, it carries meaningful implications for the broader valuation profession, including commercial appraisers. The order includes five appraisal-related policy directives, and even though it is short on specifics, it sets in motion a regulatory review process that could reshape how collateral risk is evaluated across asset classes.

At its core, the directive emphasizes modernization. This includes expanded use of alternative valuation methods, increased reliance on artificial intelligence, and reduced regulatory friction for lower-risk transactions. For commercial appraisers, the concern is not whether these changes will remain confined to residential lending, but how quickly they may migrate into standards for commercial underwriting.

One of the most significant areas to watch is the potential revision, or even retirement, of the Interagency Appraisal and Evaluation Guidelines. These guidelines have long provided the framework for when an appraisal is required as opposed to an evaluation. If these guidelines are revised, lenders could gain broader discretion to rely on evaluations, AVMs, or hybrid approaches in transactions that historically required full appraisals.

Similarly, an expanded use of alternative valuation tools, particularly AI-enabled models, introduces both opportunity and risk. While technology can enhance efficiency, it also raises concerns around data integrity, model transparency, and applicability in complex or thinly traded commercial markets. Commercial assets often require nuanced analysis that automated systems may struggle to replicate consistently.

The Executive Order also calls for simplification of appraiser qualification criteria, which could have longer-term implications for the profession. Any effort to reduce experience requirements may accelerate entry into the field, but it could also create a wide range of competency standards, particularly if states adopt changes unevenly.

Equally important is the potential for expanded appraisal waivers and increased federal de minimis thresholds. While currently more relevant to residential lending, such changes could influence supervisory expectations more broadly, particularly for smaller-balance commercial transactions. Federal banking regulators raised appraisal threshold levels in 2019 and 2020, reducing the number of transactions that require a full appraisal. But higher thresholds heighten safety-and-soundness expectations: evaluations must be well supported, independent, and appropriate, especially where complexity, volatility, or concentration risk is present, so regulatory relief does not replace prudent collateral risk management.

As these issues evolve, coordinated stakeholder engagement will be critical. A fragmented response from the profession risks creating inconsistent messaging at a time when policymakers are actively shaping implementation. Early collaboration among appraisal organizations and industry participants can help identify shared priorities, reinforce common principles such as independence and credibility, and ensure that modernization efforts are paired with appropriate safeguards.

To that end, the Appraisal Institute has already convened a stakeholder working group with other organizations to begin identifying key issues and to lay the groundwork for that collaboration and coordination as specific policy proposals emerge.

Ultimately, the commercial appraisal profession is not immune to the policy direction outlined in this Executive Order. As federal agencies begin implementation over the coming months, the focus should be on ensuring that innovation and expanded access do not come at the expense of independent, credible valuation, particularly in markets where complexity and risk demand it most. The Appraisal Institute will remain organized, engaged, and prepared to respond quickly as proposals emerge.

Michael Mignogna, MAI, SRA, AI-GRS is president of the Appraisal Institute.