On a mortgage or a refinance, the lender orders the appraisal, either directly or through an appraisal management company, a firm that keeps a panel of appraisers and places orders on the lender's behalf. The homeowner does not choose the appraiser and does not set the value. Fannie Mae's Selling Guide bars lenders from using appraisals ordered or received by borrowers or other interested parties, and federal Regulation Z prohibits anyone with a stake in the loan from pushing the appraiser toward a number.
Those two sources together are what people mean by appraiser independence: the rule that no party to the loan can choose, pressure or reward the appraiser for a result. This article explains who orders the report, what the rules forbid, what a lender is still allowed to ask, and what a Claremont owner can do while the appraisal is under way.
Who orders a mortgage appraisal?
The lender. On a loan that will be sold to Fannie Mae, the Selling Guide says the lender "may not use appraisals ordered or received by borrowers or other parties with an interest in the transaction." The same section allows lenders to use third-party vendors, such as appraisal management companies, to manage appraiser selection, and requires lenders to select appraisers in accordance with Fannie Mae's requirements, "including the Appraiser Independence Requirements."
That is why the report names the lender as the client. The engagement also sets the intended use, what the report will be used for, and the intended users, the people entitled to rely on it. On a mortgage the intended user is the lender; the borrower receives a copy, but the report is not written for the borrower's own use. The pillar guide to what the lender's form asks walks through what the report then contains.
What does Regulation Z forbid?
Regulation Z, section 1026.42, is titled "Valuation independence." It says no covered person "shall or shall attempt to directly or indirectly cause the value assigned" to the consumer's principal dwelling to be based on any factor other than the independent judgment of the person preparing the valuation. The methods it names are coercion, extortion, inducement, bribery, intimidation, compensation, instruction and collusion.
The rule lists examples of what crosses the line:
- Seeking to have the appraiser report a minimum or maximum value.
- Withholding or threatening to withhold payment because the value comes in below a set amount.
- Implying that future work depends on the value reported.
- Excluding an appraiser from future work for reporting a low value.
- Conditioning the appraiser's pay on the loan closing.
It also bars the appraiser from materially misrepresenting the value, bars anyone preparing the valuation or managing it from having a direct or indirect interest in the property or the transaction, and requires a covered person who reasonably believes an appraiser has materially failed to comply with the Uniform Standards of Professional Appraisal Practice (USPAP) to refer the matter to the appropriate state agency, which the rule defines as the state appraiser certifying and licensing agency for the state where the home is located. In California, appraisers are licensed by the Bureau of Real Estate Appraisers.
On this side, the same principle shows up as a fee that is set by the scope of the assignment and quoted before work begins, and that does not depend on the value or on whether the loan closes. The appraisal independence statement sets out the practice's policy.
What is a lender still allowed to ask?
Independence does not mean silence. Section 1026.42 lists actions that do not violate it, including:
- "Asking a person that prepares a valuation to consider additional, appropriate property information," including information about comparable properties.
- "Requesting that a person that prepares a valuation provide further detail, substantiation, or explanation" for the value conclusion.
- "Asking a person that prepares a valuation to correct errors in the valuation."
- Obtaining multiple valuations to select the most reliable one.
Those permitted requests are the legal footing for a reconsideration of value, the lender's request that the appraiser reassess the report based on factual errors or information that may affect the conclusion. A borrower who sees a problem asks the lender, and the lender decides whether to send it. How to challenge an appraisal through the lender's reconsideration of value covers the steps.
What can a Claremont owner do while the appraisal is under way?
Provide access and facts, through the lender. These are the kinds of assignments that come in, and what helps in each.
- A Village Craftsman near the Colleges. Porches and back rooms on the older blocks along Indian Hill Boulevard and College Avenue were often enclosed decades ago. Permits, plans or a dated list of that work help the appraiser describe gross living area, the finished, above-grade living space, as it actually exists rather than as public records list it.
- A postwar ranch. Garage conversions and additions are the recurring questions on the postwar tracts. Have the permits and final sign-offs out.
- A Claraboya hillside home. Tell the lender about gates, steep drives or a lower level reached from outside, so the inspection covers the whole property. Hillside and custom homes often need comparables from a wider foothill band, and the report explains why.
- An ADU behind an older house. Permit status decides how the second unit is described, so have the permit history ready.
What a homeowner should not do is call the appraiser to discuss value, send a target number, or pass along a list of asking prices. An automated estimate such as a Zestimate is not an appraisal, and neither is an agent's CMA or the county's assessed value; none of them measures what the lender's form asks. Closed sales you believe are comparable can go to the lender with a note on why each fits. The inspection itself runs 30 to 60 minutes for a standard single-family home, longer for hillside, custom, multi-family or homes with additions, and value is not discussed on site. The room-by-room guide to a Claremont refinance appraisal shows what is looked at.
What if a private lender asks me to supply the appraisal?
Some private and portfolio lenders accept a report the borrower orders. Before anything is ordered, confirm in writing who the client will be and who the intended users are, because a report written for one client is not automatically usable by another. The appraiser's independence is the same either way: the analysis comes from closed comparable sales and does not change based on who pays. What independence means under USPAP explains the professional side of the same rule.
Does the county line change who orders the appraisal?
No. Claremont is in Los Angeles County and Upland and Montclair are across the line in San Bernardino County, but the ordering rules come from federal law and the loan investor, not the county. What the line changes is the evidence: a Claremont house is appraised from Claremont sales first, and a sale from across the line is used only when it is genuinely better evidence, with the location difference explained. The Claremont area page describes the city's pockets.
Next step
Lenders, credit unions, mortgage brokers and private lenders can place an order through residential appraisal for lending and refinance or call (909) 324-6122. Reports are typically delivered three to five business days from the inspection. The full series is on the lending and refinance appraisals hub, including how a purchase appraisal differs from a refinance appraisal.
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)
- Fannie Mae Selling Guide B4-1.1-03, Appraiser Selection Criteria (06/04/2025), which requires selection in accordance with the Appraiser Independence Requirements: https://selling-guide.fanniemae.com/sel/b4-1.1-03/appraiser-selection-criteria (accessed November 6, 2026)
- Fannie Mae Selling Guide B4-1.3-12, Appraisal Quality Matters (09/03/2025), reconsideration of value: https://selling-guide.fanniemae.com/sel/b4-1.3-12/appraisal-quality-matters (accessed November 6, 2026)
- Board of Governors of the Federal Reserve System, SR 24-3 / CA 24-4, Interagency Guidance on Reconsiderations of Value of Residential Real Estate Valuations (July 18, 2024): https://www.federalreserve.gov/supervisionreg/srletters/SR2403.htm (accessed November 6, 2026)
- California Bureau of Real Estate Appraisers, license lookup for Gordon Hall, 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
Who orders the appraisal on a mortgage or refinance?
The lender, either directly or through an appraisal management company that places orders on its behalf. For loans sold to Fannie Mae, the Selling Guide says lenders may not use appraisals ordered or received by borrowers or other parties with an interest in the transaction.
Can I pick my own appraiser for a refinance?
Not for a conventional loan the lender will sell to Fannie Mae, because the lender must select the appraiser under Fannie Mae's requirements, including the Appraiser Independence Requirements. Some private or portfolio lenders accept a borrower-ordered report; ask the lender and confirm in writing who the client will be before anything is ordered.
Can I talk to the appraiser about the value?
Questions about a lender's report go through the lender, which is the appraiser's client. You can tell the lender about access, permits and closed sales you think are comparable. Regulation Z prohibits any covered person from trying to cause the value to rest on anything but the appraiser's independent judgment.
What can the lender ask the appraiser to do after the report is delivered?
Regulation Z section 1026.42 allows a lender to ask the appraiser to consider additional, appropriate property information, including comparable sales, to provide further detail or explanation for the value conclusion, and to correct errors. That is the basis for a reconsideration of value, which the borrower requests through the lender.
