When a Pomona building has more units on the lot than the assessor's record shows, or fewer, the appraisal does not pick the convenient number. It states the legal unit count it relied on, based on permits and city records, describes what is physically there, and explains how any unit it cannot support as legal was treated. The assessor's record is a property-tax record, not an appraisal, and it is one piece of evidence, not the answer.
Why the counts disagree in Pomona
Downtown Pomona, the blocks along Holt Avenue and the streets toward the Fairplex hold some of the oldest small income property in the coverage area: duplexes and fourplexes built as such, single-family houses later divided into units, and lots with a front house and a rear unit. Pomona is in Los Angeles County, so its property records are kept by the Los Angeles County Office of the Assessor, while building permits and land use are the City of Pomona's.
Those records were made for different purposes and at different times. A house split into two units decades ago may still appear as one unit on the tax roll. A garage converted to a rental may appear nowhere. A permitted second unit may be on the city's file and not yet reflected elsewhere. None of that is unusual, and none of it tells the appraiser on its own how many units are legal.
Three counts, kept apart
The report separates three numbers and names the source of each:
- The records count. What the assessor's roll and other public records show for the parcel.
- The on-site count. What the inspection finds: separate entrances, kitchens, baths, meters and addresses, unit by unit.
- The legal count. What the permits, final sign-offs and the city's records support under current zoning or as a legal nonconforming use.
Legal use, the use that zoning and the permit record allow on that parcel, governs the analysis. Fannie Mae's Selling Guide requires the appraisal to say whether the use is legal conforming, legal nonconforming (grandfathered), illegal, or has no local zoning, the same four boxes the legacy Small Residential Income Property Appraisal Report, Form 1025, carried. For a legal nonconforming use, the analysis must reflect any adverse effect on value and marketability. For Fannie Mae and Freddie Mac loans, Form 1025 is retired for reports submitted on or after November 2, 2026 and replaced by the redesigned Uniform Residential Appraisal Report. The guide to appraising a duplex to fourplex explains why legal use comes before either approach to value.
How the report states a unit it cannot support
An extra unit is described as found. Fannie Mae's Selling Guide says that when the appraiser identifies an addition without the required permit, the appraiser must comment on the quality and appearance of the work and its impact, if any, on market value. The same discipline applies to a whole unit.
Two terms carry most of the weight here, and the report defines them where they appear:
- An extraordinary assumption is an assumption about uncertain facts that, if false, could change the result. If the permit history is incomplete and the analysis treats a unit as legal anyway, the report says so and names the assumption.
- A hypothetical condition is a condition assumed for the analysis that is known to be contrary to fact. Valuing a building as if an unpermitted unit had already been legalized is a hypothetical condition, and the report labels it that way and explains why the intended user asked for it.
What the report never does is count a unit as legal in silence. Whether a lender will accept the result is the lender's decision, not the appraiser's.
Duplex, triplex, or house with a back unit
A rear unit raises a classification question before it raises a value question. Fannie Mae's Selling Guide allows one accessory dwelling unit per parcel, does not allow one with a two- to four-unit dwelling, and says the choice between a one-unit property with an ADU and a 2-4 unit property depends on characteristics such as separate utility meters, a unique postal address and whether the unit can be legally rented. The appraiser makes that determination in the highest and best use analysis.
So a Pomona house with a permitted back unit may be reported as a one-unit property with an ADU, and a lot with two separately metered, separately addressed homes may be a duplex. How the main house and the second unit are reported covers the ADU side of that line.
What the unit count does to comparables and income
The legal count decides which sales are comparable. A legal triplex is compared with other triplexes and with duplexes and fourplexes adjusted for the difference, not with a fourplex that only looks like one. Freddie Mac's guidance for the redesigned appraisal report says that when a comparable has a different number of units, the appraiser adds a "Total Units" row and makes the unit adjustment there, taking care not to adjust the same unit features twice.
The count also decides what income is analyzed. The Form 1025 rent schedule listed each unit's lease dates, its actual rent and the appraiser's opinion of market rent, the rent the unit would most likely command if offered for lease today. If a unit is not legal, its rent is reported as found, and the report explains whether and how the market pays for it, supported by comparable sales and leases rather than by the rent alone. That form also asked directly whether the property was subject to rent control, and the report answers it as a condition affecting income, not as legal advice. What a rent schedule documents covers the market rent side.
A building with five or more units on site is a different conversation. That is outside the one-to-four-unit residential scope, as where 2-4 units end and a commercial assignment begins explains, and the scope call settles it before any work starts.
What a Pomona owner should gather
- Every building permit and final sign-off for the structures on the lot, including any conversion.
- Any letter or record from the City of Pomona about the number of units or a past code case.
- The current leases or rent roll, unit by unit.
- How each unit is metered for gas, electric and water, and the address each unit uses.
- Access to every unit, with tenant notice arranged by the owner.
Missing paperwork does not stop the assignment; it changes what the report can say and which assumptions it has to state. The Pomona area page describes the city's pockets, and the full series is on the multi-family and market rent hub.
Timing and fees
The inspection is 30 to 60 minutes for a standard single-family home, longer for hillside, custom, multi-family or homes with additions, and every unit is seen. Reports are typically delivered three to five business days from the inspection. The fee is set by the scope of the assignment and quoted before work begins, and fees do not depend on the value.
To scope a Pomona duplex, triplex or fourplex, send the address, what you believe the unit count is, and the permits you have through the multi-family and 2-4 unit appraisal page, or call (909) 324-6122.
Sources
- Freddie Mac Form 72 / Fannie Mae Form 1025, Small Residential Income Property Appraisal Report (March 2005, legacy form), accessed November 6, 2026
- Fannie Mae Selling Guide B4-1.3-04, Site Section of the Appraisal Report (zoning and highest and best use), accessed November 6, 2026
- Fannie Mae Selling Guide B4-1.3-05, Improvements Section of the Appraisal Report, accessed November 6, 2026
- Fannie Mae Selling Guide B2-3-04, Special Property Eligibility Considerations (accessory dwelling units), accessed November 6, 2026
- Freddie Mac, UAD and Forms Redesign FAQs, accessed November 6, 2026
- California Bureau of Real Estate Appraisers, license lookup for Gordon Hall, AR003877, accessed November 6, 2026
- The Appraisal Foundation, Uniform Standards of Professional Appraisal Practice (USPAP), 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
Does the appraiser use the assessor's unit count?
The assessor's record is one piece of evidence. It is a property-tax record, not an appraisal. The report states the legal unit count it relied on, based on permits and city records, describes what is on site, and explains any difference.
Is an unpermitted unit counted in a Pomona multi-family appraisal?
It is described as found, with its condition and its rent reported. The report does not count it as a legal unit in silence: if the analysis treats it as legal anyway, that is stated as an extraordinary assumption, and how the market pays for such a unit is supported by comparable sales and leases.
Is a Pomona house with a back unit a duplex?
Not automatically. Fannie Mae's guide says the choice between a one-unit property with an accessory dwelling unit and a 2-4 unit property depends on characteristics such as separate meters, a unique postal address and whether the unit can be legally rented. The appraiser decides it in the highest and best use analysis.
What should a Pomona owner send before the appraisal?
Permits and final sign-offs for every structure, any city letter about the unit count, the current leases or rent roll, how each unit is metered and addressed, and arranged access to every unit with tenant notice given by the owner.
