# What DOJ’s Disparate-Impact Rollback Doesn’t Change About AVM Fairness

- Source: https://avm.digisavvy.dev/blog/avm-fairness-fifth-factor-and-doj-disparate-impact-policy/
- Author: AVMetrics
- Published: December 17, 2025
- Category: Articles

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The Department of Justice’s recent move to eliminate disparate-impact liability under its Title VI regulations has raised understandable questions across housing and credit markets. But for lenders, GSE partners, and valuation providers preparing for the **AVM Quality Control Standards**, one thing is clear:

**The obligations around AVM fairness haven’t gone away.**

The interagency AVM rule—effective October 1, 2025—explicitly requires institutions to establish policies, practices, procedures, and control systems to ensure AVMs **comply with applicable nondiscrimination laws.** That requirement remains fully intact. So do the supervisory expectations of prudential regulators, FHFA, and CFPB around managing **fair lending and bias risk** in automated systems, whether or not DOJ narrows its enforcement tools under Title VI.

Even with political shifts, the industry continues to operate under:

- **The Fair Housing Act**, where disparate-impact liability is still recognized by the Supreme Court.
- **ECOA/Reg B fair lending expectations**, which continue to incorporate statistical evidence of adverse outcomes.
- **Growing scrutiny of AI and automated valuation**, highlighted by recent GAO recommendations urging clearer guidance on emerging technology risks.

In short: **Regulatory pendulums swing—but AVM fairness risk remains.**

Institutions still need independent, statistically rigorous testing to understand whether their AVMs or cascades produce unjustified disparities, and to document business justification and alternatives when they arise. That’s where AVMetrics’ **fifth-factor validation** fits the bill. Our analysis is national, extensive, independent, thorough, examiner-ready and tested for significance.