November 10, 2022
Appraisal Bias: What a 2022 NCRC Investigation Found
By Joseph T Ellington Jr – Licensed Residential Appraiser, Capital Valuations. Updated September 2026; discussing a 2022 investigation.
In a 2022 mystery-shopper investigation, the National Community Reinvestment Coalition (NCRC) recruited interracial couples in the Baltimore area to present the same homes for separate appraisals under different conditions. NCRC reported that in one test, a Black partner received a $310,000 value and a White partner $350,000. These are NCRC’s reported test results, not appraisals performed by Capital Valuations. The investigation raises serious questions, while an individual value difference alone does not establish the precise cause.
What to examine in an appraisal report
Check factual descriptions of the property, neighborhood, condition, living area, comparable sales, adjustments, and any unsupported language. Ask whether comparable sales were selected and treated consistently. Our comps guide explains the analysis; our ROV guide explains how to assemble evidence.
| Concern | Useful supporting material |
|---|---|
| Wrong property details | Plans, permits, photographs, public record correction |
| Omitted sale | Address, close date, verified terms, reason it is comparable |
| Potential bias | Exact report language, inconsistent treatment, dated communications |
How a borrower can challenge a lender appraisal
The lender generally manages a reconsideration of value (ROV) request and communicates with the appraiser. The CFPB explains the ROV process. A borrower may also raise discrimination concerns through appropriate fair housing and regulatory channels; the U.S. Department of Justice explains Fair Housing Act protections. A review can correct an error or leave the original conclusion intact. No value change can be promised.
Our practice
An appraisal opinion should follow the property, assignment scope, credible market evidence, and professional obligations, free from a person’s protected characteristics. Joe is a Virginia Licensed Residential Appraiser serving Hampton Roads. For an independent assignment, contact Capital Valuations with the intended use; a lender appraisal dispute should first be directed through that lender.