Yes. In nearly every mortgage transaction, the lender orders the appraisal, and federal law requires it that way. You pay the fee, but the lender chooses the appraiser, receives the report, and controls the communication. The arrangement exists so the person valuing the property has no financial stake in whether the loan closes.
Why the Lender Orders It Instead of You
Under 15 U.S.C. ยง 1639e, no one with an interest in a real estate transaction may compensate, coerce, bribe, or otherwise influence an appraiser to hit a predetermined value.1GovInfo. 15 USC 1639e – Appraisal Independence Requirements That prohibition covers loan officers, real estate agents, sellers, and buyers. The appraiser also cannot have any direct or indirect financial interest in the property or the deal. Routing every order through the lender’s independent channels is the mechanism that enforces those rules.
Within the lender, the sales side and the valuation side must operate separately. A loan officer cannot tell the appraiser what number the deal needs, withhold payment to push a higher value, or steer work to appraisers known for generous conclusions. These requirements were written into federal law through the Dodd-Frank Act after inflated appraisals contributed to the 2008 financial crisis.
You are not banned from hiring your own appraiser for your own information. But the lender will not use that report for underwriting. It has to order one through its own process to satisfy the independence rules.
How the Order Actually Gets Placed
Most lenders do not keep appraisers on staff. They send the order to an appraisal management company, which maintains a panel of licensed appraisers and assigns the job to one qualified for the geography and property type.2eCFR. 12 CFR Part 34 Subpart H – Appraisal Management Company Minimum Requirements The AMC acts as a blind intermediary. The loan officer never speaks directly with the appraiser about the assignment, and the AMC portal logs every step so there is a documented trail that no prohibited contact occurred. When the report is finished, the appraiser uploads it through the same portal for underwriting review.
Intent to Proceed Comes First
The lender cannot order the appraisal the moment you fill out a loan application. After you receive your Loan Estimate, you have to tell the lender you want to move forward. Silence does not count as consent.3Consumer Financial Protection Bureau. My Loan Officer Said That I Need to Express My Intent to Proceed Once you express intent to proceed, the lender can collect the appraisal fee and place the order. The countdown to your closing date really begins here.
What the Lender Sends the Appraiser
Before the order goes out, the lender assembles a package that includes the fully executed sales contract with any seller concessions noted, the legal address and parcel number, and the loan type.4HUD. HUD 4155.1 Section B – Documentation Requirements Overview Loan type matters because FHA, VA, and conventional loans have different inspection standards. FHA appraisers, for instance, must evaluate health and safety conditions in addition to market value, checking structural soundness, hazards, and habitability items such as broken windows, missing handrails, and inadequate access.5HUD. HUD Handbook 4150.2 – Property Analysis – Section: General Acceptability Criteria The lender also passes along contact information for the listing agent or owner so the appraiser can schedule the inspection.
VA loans follow a separate path. Lenders submit requests through the VA’s WebLGY portal, and the VA sets its own regional fee schedule and timeliness expectations.6U.S. Department of Veterans Affairs. VA Appraisal Fee Schedules and Timeliness Requirements Turnaround in rural or high-demand areas can stretch to 14 to 20 business days.
What You Pay and When
You pay the fee even though the lender picks the appraiser. For a standard single-family home, expect roughly $300 to $600 on a conventional loan. Complex properties, rural locations, and certain loan programs cost more. VA appraisals follow a regional schedule that can run from about $525 to over $1,000 depending on the state and property type.
The fee appears on your Loan Estimate under “Services You Cannot Shop For,” which is the disclosure system’s way of telling you the lender chooses the vendor. The charge is typically collected after you express intent to proceed. If the deal falls apart after the appraisal is done, the money is generally gone. The appraiser did the work whether or not you close.
When You Receive the Report
Regulation B under the Equal Credit Opportunity Act requires the lender to give you a copy of every appraisal or written valuation tied to your loan application. The deadline is whichever comes first: promptly after completion, or three business days before closing.7Consumer Financial Protection Bureau. 12 CFR Part 1002 Regulation B – Section 1002.14 Rules on Providing Appraisals and Other Valuations Most lenders send it as soon as the appraiser uploads it, because underwriting needs time with the file anyway.
You get a copy whether the loan is approved, denied, or withdrawn. If closing is approaching and nothing has arrived, ask for it. Reading the report before closing gives you time to catch errors and decide whether to challenge the value if it came in low.
When the Lender May Not Order a Full Appraisal
Not every mortgage requires an appraiser to physically walk the property. Fannie Mae uses a tiered valuation system: on lower-risk purchases and refinances where enough property and market data already exists, a “value acceptance” option can confirm the price without an appraisal. A middle option pairs value acceptance with a property data collection visit by a trained third party who is not a licensed appraiser. Desktop appraisals, in which a licensed appraiser analyzes MLS records, tax data, and other sources without visiting, are also available for some purchases.8Fannie Mae. Property Valuation
Hybrid appraisals split the work: a third-party data collector visits the property, and a licensed appraiser completes the valuation from that data. Fannie Mae allows hybrids on existing one-unit properties, condos, PUD units, and even properties under construction, across purchases, limited cash-out refinances, and cash-out refinances.9Fannie Mae. Hybrid Appraisals Your lender’s automated underwriting system decides what’s available on your loan, so this is rarely a choice you make yourself.
Separately, banks and credit unions regulated by the FDIC, Federal Reserve, or OCC can skip a full appraisal on residential transactions below $400,000, though they still have to obtain a less formal evaluation of value.10FDIC. New Appraisal Threshold for Residential Real Estate Loans The threshold was raised from $250,000 to $400,000 in 2020. Note that this exemption applies to regulated depository institutions. Non-bank mortgage lenders follow the secondary-market rules from Fannie Mae, Freddie Mac, or government loan programs instead.
If the Appraisal Comes in Low
The lender bases your loan amount on the appraised value, not the contract price. Agree to pay $400,000, appraise at $380,000, and the lender will lend against $380,000. That $20,000 gap is yours to close. You generally have four options.
- Cover the gap in cash on top of your planned down payment.
- Redirect part of your down payment toward the gap and put less down. Dropping below 20% typically triggers private mortgage insurance.
- Ask the seller to lower the price to the appraised value. In a slower market this often works, because the next buyer will hit the same appraisal.
- Walk away, if your contract has an appraisal contingency. Without one, walking may mean losing your earnest money.
Some buyers add an appraisal gap clause to the original offer, committing upfront to cover a shortfall up to a set dollar amount. It makes the offer more competitive but puts the risk squarely on you if the number comes in short. Think through how much gap you can actually absorb before signing on to one.
Challenging the Value Through Your Lender
If the report contains errors or missed important information, you can ask for a reconsideration of value. You submit the request to your lender, not the appraiser. Contacting the appraiser directly would violate the same independence rules that put the lender in charge of ordering.
Fannie Mae formalized borrower-initiated ROV requirements in 2024, requiring lenders to create and provide the forms you use to submit a request. You get one ROV per appraisal, and it has to comply with appraiser independence rules.11Fannie Mae. Reconsideration of Value (ROV) If your submission is missing information, the lender should work with you to complete it before it goes to the appraiser.
ROVs succeed most often when you can point to specific problems:
- Wrong property details, such as square footage, bedroom count, or lot size.
- Improvements the appraiser missed, like a renovated kitchen, new roof, or finished basement.
- Comparable sales that are not truly comparable in location, condition, or timing, when better ones exist.
- Value adjustments to those comparables that do not track actual market conditions.
The statute itself preserves your right to ask the appraiser to consider additional comparables, provide further explanation, or correct errors.1GovInfo. 15 USC 1639e – Appraisal Independence Requirements What you cannot do is argue the value should be higher because you need it to be. Many ROV requests get denied. Come with data, not objections.