A Claremont appraiser works for the client, the party who engages the appraiser for the assignment, but not for the client's interest in the result. The client defines the assignment and receives the report; the intended users, the people the report names as entitled to rely on it, may include others; and the opinion of value itself belongs to no party. On a mortgage the client is the lender or its appraisal management company, even when the borrower bears the cost; on a private assignment it is whoever orders it.
Those roles are easy to blur, because the person who pays, the person who orders, the person who reads and the person who relies are often different people. This article separates them. Independence itself, the rules that keep any of them from steering the value, has its own article: what independence means under USPAP.
Client, payer, intended user, copy holder: four roles
- The client engages the appraiser and sets the assignment: the property, the intended use, what the report will be used for, and the effective date, the date the opinion of value applies to.
- The payer may or may not be the client. On a loan, Fannie Mae's Selling Guide makes the lender responsible for selecting the appraiser, and the lender may use a third party, such as an appraisal management company, to manage that selection.
- The intended users are the people the report names as entitled to rely on it. A trust's CPA or a family law attorney may be one, if the engagement says so.
- A copy holder has read the report but is not necessarily anyone it was written for. On a first-lien loan secured by a dwelling, Regulation B requires the lender to provide the borrower a copy promptly upon completion or three business days before closing, whichever is earlier, unless the borrower waives that timing.
The report states its client and intended users. Reading a copy does not add a name to that list.
Who is the client on a Claremont mortgage?
The lender. Fannie Mae's Selling Guide makes the lender responsible for selecting appraisers and for the quality of their work, and says the lender may not use appraisals ordered or received by borrowers or other parties with an interest in the transaction, such as the seller or a real estate agent. Lenders often use an appraisal management company, or AMC, a firm that recruits, selects and pays appraisers and manages orders on a creditor's behalf, as California's Business and Professions Code section 11302 describes. The AMC then acts for the lender in the assignment.
On a loan secured by a principal dwelling, Regulation Z at 12 CFR 1026.42 bars anyone preparing the valuation from having a direct or indirect interest, financial or otherwise, in the property or the transaction. For national banks, the federal rule at 12 CFR 34.45 says a fee appraiser must be engaged directly by the institution or its agent.
So on a refinance north of Foothill or a purchase in the Village, the borrower is usually a copy holder, not the client. Questions about the report go through the lender, and a request to reconsider runs through the lender too, as how a reconsideration of value works explains.
Who is the client on a private assignment?
Whoever engages the appraiser directly. These are the kinds of assignments that come in, and who usually sits where:
- Estate or trust. An executor or trustee orders a date-of-death appraisal of a long-held house near the Colleges. The fiduciary is the client; the estate's CPA or attorney may be named as an intended user.
- Divorce. Both spouses may engage the appraiser together, or one spouse's attorney may. What a joint engagement is covers the first arrangement.
- Property tax appeal. An owner in Claraboya orders a report for a Los Angeles County Assessment Appeals Board hearing. The owner is the client; the board reads the report and decides the appeal.
- Pre-listing or pre-purchase. An owner or a buyer orders a report for their own decision, with no lender involved.
Each of these is settled in an engagement letter, the written agreement that states the client, the intended use, the intended users, the effective date, the scope of work, meaning the type and extent of research and analysis, and the fee before any work begins. The fee is set by the scope of the assignment and does not depend on the value.
Why paying does not buy a direction
The client is owed a credible report, not a particular number. Fannie Mae's list of unacceptable appraisal practices includes developing or reporting an appraisal in a manner or direction that favors the cause of the client or any related party, the amount of the value or the attainment of a specific result, in order to receive pay, employment or future assignments. California's Business and Professions Code section 11323 bars a licensee from any appraisal activity where the pay depends on or is affected by the value conclusion. BREA's enforcement page lists client advocacy among the most common allegations it sees against non-residential appraisers.
That holds whoever the client is. The estate, the spouse, the owner and the lender each receive the same kind of opinion: one that would read the same if someone else had ordered it.
What can a client ask for?
A client defines the problem; it does not supply the answer.
- Can: set the intended use and effective date, describe the property, provide permits, records and sales it thinks compare, and ask for more explanation of the reasoning or the correction of factual errors. Regulation Z lists those requests among the actions it permits.
- Cannot: ask for a value or a range in advance, or tie the order or the fee to the result.
A value cannot be given before the work is done, for any client; why a Claremont appraiser cannot tell you the value before the inspection explains the rules behind that.
Can a private report be handed to a lender later?
Usually not for a loan. Because Fannie Mae lenders may not use appraisals ordered by borrowers, a report an owner orders for a trust, a divorce or a pre-listing decision does not become the lender's appraisal later; the lender orders its own. If a second party will need to rely on a private report, say so at engagement, so the intended users are stated before the work begins. Whether an appraiser needs to be on a lender panel for a private assignment covers the other side of that line.
Next step
The pillar for this series, how to check a Claremont appraiser, sets out license, competency and independence, and the Choosing an Appraiser in Claremont hub holds the rest. The appraisal independence statement applies to every client. Reports are prepared and signed by Gordon Hall, California Certified Residential Real Estate Appraiser, BREA No. AR003877, in Los Angeles and San Bernardino counties; the about page explains how assignments are accepted, and the Claremont area page describes the pockets. To name the client, the intended users and the scope before any work begins, request an appraisal or call (909) 324-6122.
Sources
- Consumer Financial Protection Bureau, Regulation Z, 12 CFR 1026.42, Valuation independence: https://www.consumerfinance.gov/rules-policy/regulations/1026/42/ (accessed November 6, 2026)
- Consumer Financial Protection Bureau, Regulation B, 12 CFR 1002.14, Rules on providing appraisals and other valuations: https://www.consumerfinance.gov/rules-policy/regulations/1002/14/ (accessed November 6, 2026)
- Fannie Mae Selling Guide B4-1.1-03, Appraiser Selection Criteria: https://selling-guide.fanniemae.com/sel/b4-1.1-03/appraiser-selection-criteria (accessed November 6, 2026)
- Fannie Mae Selling Guide B4-1.1-04, Unacceptable Appraisal Practices: https://selling-guide.fanniemae.com/sel/b4-1.1-04/unacceptable-appraisal-practices (accessed November 6, 2026)
- Office of the Comptroller of the Currency, 12 CFR 34.45, Appraiser independence (Code of Federal Regulations, 2025 edition, govinfo.gov): https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol1/xml/CFR-2025-title12-vol1-sec34-45.xml (accessed November 6, 2026)
- California Bureau of Real Estate Appraisers, Real Estate Appraisers' Licensing and Certification Law, Business and Professions Code sections 11300-11425 (as of January 1, 2026): https://www.brea.ca.gov/pdf/BP_Codes.pdf (accessed November 6, 2026)
- California Bureau of Real Estate Appraisers, Frequently Asked Questions: Enforcement: https://www.brea.ca.gov/html/EnforcementFAQs.html (accessed November 6, 2026)
- California Bureau of Real Estate Appraisers, license lookup (BREA No. AR003877): https://www2.brea.ca.gov/breasearch/faces/party/view.xhtml?id=23601 (accessed November 6, 2026)
Gordon Hall, California Certified Residential Real Estate Appraiser, BREA No. AR003877 (lookup: https://www2.brea.ca.gov/breasearch/faces/party/view.xhtml?id=23601). Reports are prepared in conformity with the Uniform Standards of Professional Appraisal Practice (USPAP). Nothing here is legal or tax advice; admissibility is always the court's decision.
Frequently asked questions
If I pay for my mortgage appraisal, am I the appraiser's client?
Usually not. Fannie Mae's Selling Guide makes the lender responsible for selecting the appraiser, directly or through a third party such as an appraisal management company, so the lender is the client. The borrower receives a copy of the report, which is not the same as being its client.
Can I call the appraiser about my lender's report?
Send questions through the lender, which is the client on a loan appraisal. Regulation Z permits asking for more explanation of the value conclusion or for errors to be corrected, and a reconsideration of value request also runs through the lender.
Is my CPA or attorney an intended user of the appraisal?
Only if the report names them. Intended users are the people the report identifies as entitled to rely on it, and they are settled in the engagement letter before the work begins, so tell the appraiser at the start who will need to rely on the report.
Does the client get to influence the value because it hired the appraiser?
No. Fannie Mae lists reporting an appraisal in a direction that favors the cause of the client, in order to receive pay or future assignments, as an unacceptable practice, and California Business and Professions Code section 11323 bars an appraiser's pay from depending on the value conclusion. The client is owed a credible report, not a particular number.
