Project 2025 Tracker / What’s done, what’s next

15. Department of Housing and Urban Development · Notable · Day one

End the Property Appraisal and Valuation Equity (PAVE) policies

Partially done

508 15. Department of Housing and Urban Development

“Immediately end the Biden Administration’s Property Appraisal and Valuation Equity (PAVE) policies and reverse any Biden Administration actions that threaten to undermine the integrity of real estate appraisals.”

What has happened

  1. Partially done

    The second half of the Quote — reversing Biden actions that bear on appraisal integrity — advanced when HUD's Office of General Counsel withdrew its "Appraisal Elements of Proof" guidance of 2022-05-06, one of the thirteen OGC documents withdrawn effective 2025-09-25 and announced in the Federal Register on 2026-07-17. That guidance was the enforcement-facing product of the PAVE period.

  2. Partially done

    HUD and OMB's Office of Information and Regulatory Affairs jointly announced "the termination of burdensome policies introduced under the Biden-era's Property Appraisal and Valuation Equity (PAVE) task force", HUD's own headline calling it a move that "Effectively Disband[s]" the task force. The release says the terminated policies are the ones directing members to "issue guidance on anti-discrimination obligations, review policies and practices, and issue new policies focused on 'eliminating bias and advancing equity in home appraisals'", and that removing them frees lenders and appraisers from "unnecessary regulatory hurdles". It is `partial`, not `done`, for two reasons the release itself supplies: it terminates "specific policies" rather than the whole interagency program, which spanned agencies beyond HUD, and the American Enterprise Institute quotation HUD prints describes the agencies as "beginning to roll back certain PAVE-inspired policies". HUD published no Federal Register document ending PAVE, and pave.hud.gov does not resolve in DNS. The release does name the instruments, below the AEI quotation: "The terminated policies related to Reconsideration of Value and Appraisal Fair Housing Compliance include: ML 2024-16 … ML 2024-07 … ML 2021-27" — all three already rescinded by Mortgagee Letter 2025-08 of 2025-03-19, so this announcement records the disbanding of the task force rather than a fresh policy change.

  3. Partially done

    The instrument that actually ended HUD's PAVE-era appraisal policy is FHA Mortgagee Letter 2025-08, four months before the announcement below. It "rescinds Federal Housing Administration (FHA) Single Family Housing policy changes issued in ML 2024-07, Appraisal Review and Reconsideration of Value Updates, ML 2024-16, Extension to the Effective Date of Appraisal Review and Reconsideration of Value (ROV) Updates, and ML 2021-27, Appraisal Fair Housing Compliance and Updated General Appraiser Requirements, to restore previous policy", effective immediately, and its Summary of Changes strikes thirteen paragraphs of Handbook 4000.1 including the borrower-initiated Reconsideration of Value process and its Quality Control Plan requirement. Its Background ties it to the window: "On January 20, 2025, the President issued Executive Orders aimed at reversing policies that have adversely affected key sectors, including the housing market. As part of this ongoing effort, FHA is focused on eliminating policies that have created barriers, increased regulatory and financial burdens, and deepened disparities in lending practices." These are the three documents HUD's July release later listed as the terminated policies. `partial` rather than `done` for the reason given in the next event: this is HUD/FHA, and PAVE was an interagency task force.

Research log

What was searched, and what didn’t count as evidence

Research notes

  • Negative search on the obvious instrument: the Federal Register carries nothing. Full-text searches of the Federal Register since 2025-01-20 for “Property Appraisal and Valuation Equity”, “appraisal bias” and “reconsideration of value” each return 0 documents, in any type. PAVE was created by an interagency task force rather than by rule or order, so the press announcement is the Primary record and there is no rulemaking tail to follow.
  • The address pave.hud.gov no longer resolves, checked against two separate name servers, and hud.gov/pave returns not found. A dead subdomain is a real observation about the program’s fate but not Evidence, so it is recorded here and in the note rather than as Evidence.
  • The court opinions we keep and search, from CourtListener’s bulk file, (from CourtListener’s bulk file, complete to 2026-06-30) mention PAVE once, in an unrelated veterans’ case. Litigation after 2026-06-30 is not among those records and is unknown.
  • The route to the Mortgagee Letters, recorded because an earlier search gave up on it: the older address hud.gov/program_offices/administration/hudclips/letters/mortgagee opens only to a redirect pointing at hud.gov/hudclips/letters/mortgagee, which is an ordinary table. That table is incomplete: read on 2026-09-03 it lists ML 2025-02, -03, -11, -20, -22, -23, -24 and ML 2026-01 to -10, and does not list ML 2025-08 or ML 2025-15 to 2025-19 at all, though it does annotate ML 2024-16 as “Superseded in full by ML 2025-08”. Those letters are reachable only at their PDF addresses, of the form hud.gov/sites/dfiles/OCHCO/documents/YYYY-NNhsgml.pdf, which is how ML 2025-08 was read. A negative taken from the index alone would be false.
  • https://www.hud.gov/sites/dfiles/OCHCO/documents/2025-18hsgml.pdf — FHA Mortgagee Letter 2025-18 of 2025-06-27, “Rescission of Outdated and Costly FHA Appraisal Protocols”, read in full. It removes the remaining-economic-life and excess-photograph requirements and other FHA-specific protocols. It is appraisal deregulation generally rather than PAVE specifically, so it is recorded here rather than as Evidence. ML 2025-24 (2025-12-23, appraiser roster management) and ML 2026-10 (appraisal field-review quality control) continue in the same direction on the index.
  • Done is still refused, and the reason is unchanged and is about scope, not evidence: PAVE was an interagency task force (FHFA, VA, USDA, CFPB, DOJ among others) and this record covers HUD and FHA only. Every PAVE-era FHA appraisal Mortgagee Letter HUD itself names is now rescinded.
Action
eliminate
Object
Property Appraisal and Valuation Equity (PAVE) policies
ID
1410