Property appraisals are performed by state-licensed or state-certified real estate appraisers, independent professionals whose credential tier must match the property type, complexity, and dollar amount of the transaction. Who does property appraisals in practice depends on the job: a routine single-family mortgage usually goes to a Licensed Residential Appraiser, a high-value or complex home requires a Certified Residential Appraiser, and commercial work falls to a Certified General Appraiser. A separate group of government officials, county tax assessors, handles valuations for property tax bills, but they are not the people a lender hires when you buy or refinance a home.
The Three Credential Tiers
Federal law requires appraisers performing work for federally related transactions to hold a state license or state certification meeting the minimum criteria set by the Appraiser Qualifications Board of The Appraisal Foundation.1Office of the Law Revision Counsel. 12 USC 3345 – Certification and Licensing Requirements Three tiers exist, and the one your transaction requires is set by federal banking regulations.2eCFR. 12 CFR 34.43 – Appraisals Required; Transactions Requiring a State Certified or Licensed Appraiser
A Licensed Residential Appraiser handles non-complex residential properties with one to four units when the transaction value stays below $1,000,000. If the appraisal involves a complex property above $400,000, a certified appraiser must step in instead.
A Certified Residential Appraiser can appraise any residential property regardless of value or complexity. This is the credential required for high-end homes and complicated ownership structures that push past what a licensed appraiser is allowed to handle.
A Certified General Appraiser holds the broadest credential. It is required for commercial real estate transactions above $500,000, all transactions at $1,000,000 or above, and any non-residential property type.
These thresholds matter to you as a borrower because if your lender orders an appraisal from someone who does not hold the right credential, the appraisal will not satisfy federal requirements. A typical single-family refinance or purchase under the thresholds can be done by any of the three tiers; a four-unit property near $1,000,000 or a working farm cannot.
Verifying an Appraiser Before They Show Up
Every appraiser eligible to perform work on federally related transactions is listed on a publicly searchable national registry maintained by the Appraisal Subcommittee, housed within the Federal Financial Institutions Examination Council.3ASC. Title XI of FIRREA Real Estate Appraisal Reform You can look up any appraiser at asc.gov and confirm their credential status, license type, and credentialing state.4ASC. Appraiser Registry If a state’s program falls below federal standards, appraisers credentialed in that state can lose eligibility for federally related work, which effectively bars them from most mortgage appraisals.
Some appraisers also carry voluntary designations that signal deeper expertise beyond the baseline license. The most recognized is the MAI designation from the Appraisal Institute, which focuses on commercial valuation. Earning it requires holding a Certified General credential, completing advanced coursework in income capitalization, market analysis, and quantitative methods, and passing exams.5Appraisal Institute. MAI Designation These designations are not legally required for any transaction. They indicate an appraiser who has gone well beyond the minimum.
Why You Don’t Pick Your Appraiser
When you apply for a mortgage, you almost never choose the person who appraises your home. Most lenders route the assignment through an Appraisal Management Company. The AMC receives the order from the lender, selects a qualified local appraiser from its panel, manages scheduling, reviews the completed report, and delivers it to the lender. The appraiser who shows up at your door is typically an independent contractor working through the AMC, not a lender employee.
This arm’s-length structure exists because of federal appraisal independence rules. Under the Truth in Lending Act, it is illegal for anyone with a financial interest in a loan to pressure, coerce, or instruct an appraiser to reach a targeted value.6GovInfo. 15 USC 1639e – Appraisal Independence Requirements Before the 2008 financial crisis, loan officers routinely steered work to appraisers willing to hit the numbers that made deals close. The Dodd-Frank Act’s strengthening of these independence provisions made AMCs the dominant model for separating the people who profit from a loan closing from the people who determine the property’s value.7eCFR. 12 CFR Part 225 Subpart M – Minimum Requirements for Appraisal Management Companies
AMCs themselves are not free from accountability. Federal regulations require each AMC to maintain processes ensuring compliance with appraisal independence rules, and states can discipline, suspend, or deny renewal to AMCs that violate appraisal-related laws.7eCFR. 12 CFR Part 225 Subpart M – Minimum Requirements for Appraisal Management Companies One common criticism is that AMCs compress appraiser pay: the borrower might pay $400 to $600 for the appraisal, but a meaningful share goes to the AMC’s administrative overhead rather than the appraiser performing the work. That squeeze has contributed to appraiser shortages in rural areas, where the remaining fee does not justify the travel time.
One category of transaction skips the full appraisal entirely. Fannie Mae offers a “value acceptance” option on certain loans where its automated underwriting system determines a traditional appraisal is not necessary. Eligible transactions include one-unit properties used as a principal residence or second home, certain investment property refinances, and loans that receive an automated approval. Two-to-four-unit properties, manufactured homes, co-ops, and construction loans are not eligible.8Fannie Mae. Value Acceptance When value acceptance applies, no appraiser is assigned at all. Separately, federal regulators have set de minimis thresholds below which a full appraisal is not mandatory, though lenders must still obtain a valuation of the property. For residential transactions, the current threshold is $400,000; for commercial, $500,000.2eCFR. 12 CFR 34.43 – Appraisals Required; Transactions Requiring a State Certified or Licensed Appraiser
The Rules Every Credentialed Appraiser Must Follow
Every state-licensed and state-certified appraiser working on federally related transactions must follow the Uniform Standards of Professional Appraisal Practice, known as USPAP. These standards govern both the ethical obligations and the technical performance requirements for real estate, personal property, business valuation, and mass appraisal work.9The Appraisal Foundation. USPAP – Uniform Standards of Professional Appraisal Practice Federal banking regulators reference USPAP’s real property development and reporting rules when implementing FIRREA’s Title XI requirements.
The practical effect of USPAP is straightforward. The appraiser works for the truth, not for you, your lender, or the seller. They cannot advocate for any party’s desired outcome. Their job is to analyze the data and reach a supportable conclusion about value, even if that conclusion kills your deal. Violating these standards can result in discipline from the appraiser’s state board, ranging from mandatory retraining to permanent loss of credentials.
Who Regulates Appraisers and Where to Complain
Appraiser oversight runs on two levels. State boards handle day-to-day licensing and discipline. Federal entities set the floor for qualifications nationwide.
State Appraisal Boards
Every state and territory maintains an appraisal board or commission responsible for issuing licenses, processing renewals, and investigating complaints. These boards can impose fines, require additional education, suspend credentials, or permanently revoke an appraiser’s ability to practice. If you believe an appraiser acted unethically or produced a fraudulent report, the state board is where you file a complaint.
Federal Oversight
At the national level, two organizations create the framework state boards must meet. The Appraisal Foundation, a congressionally authorized nonprofit, houses the Appraiser Qualifications Board, which sets the minimum education, experience, and examination requirements for each license tier.9The Appraisal Foundation. USPAP – Uniform Standards of Professional Appraisal Practice The Foundation also publishes USPAP through its Appraisal Standards Board.
The Appraisal Subcommittee monitors whether state programs meet federal minimums and maintains the national registry of appraisers eligible to work on federally related transactions.3ASC. Title XI of FIRREA Real Estate Appraisal Reform
Who Does FHA and VA Appraisals
Government-backed loans draw from a narrower pool. The appraiser must be an FHA Roster appraiser for FHA loans, or a VA Panel appraiser for VA loans, and both roles require certification by the respective agency on top of the underlying state credential. These appraisers are not just estimating market value; they are also certifying that the property meets specific health and safety standards.
FHA appraisers must verify that the home meets HUD’s Minimum Property Requirements. The appraiser checks for a sound roof, a stable foundation, functional plumbing and electrical systems, adequate heating, and the absence of environmental hazards like lead paint or contaminated soil.10HUD. Appraisal Report and Data Delivery Guide Deficiencies that affect safety, soundness, or livability must be identified and often repaired before the loan can close. A conventional appraiser might note peeling paint and move on, while an FHA appraiser must flag it because of lead paint regulations in pre-1978 homes. FHA appraisals also stay attached to the property, not the borrower. If a deal falls through and a new buyer makes an offer on the same home, the original FHA appraisal typically transfers. Standard FHA appraisals remain valid for 180 days from the effective date of the report.
VA appraisals share the health-and-safety inspection layer and add a buyer-protection step called the Tidewater process. When a VA appraiser believes the property’s value will come in below the purchase price, they notify the lender before finalizing the report. The lender then has two business days to submit additional comparable sales data or other evidence supporting a higher value. The appraiser reviews that information and either adjusts the conclusion or explains why the new data did not change it.
Tax Assessors Are a Different Job
If you are reading your property tax bill rather than a mortgage document, the person who set that value is not a licensed appraiser. County tax assessors are government officials responsible for valuing properties to calculate local property taxes. Their work funds schools, roads, fire departments, and other public services. The resulting tax is ad valorem, meaning “according to value,” so your tax bill rises and falls with the assessor’s opinion of what your property is worth.
Assessors operate differently from private appraisers. Rather than visiting individual homes and analyzing specific comparable sales, most assessors use mass appraisal techniques that value thousands of properties at once based on statistical models, neighborhood data, and property characteristics from public records. The result is a broad estimate meant to distribute the tax burden equitably across a jurisdiction, not a precise market-value opinion for a single transaction. That is why your assessed value and a private appraisal ordered for a mortgage can differ by tens of thousands of dollars without either number being wrong. They are answering different questions using different methods.
If your assessment notice shows a value you believe is too high, you have the right to appeal. Every jurisdiction provides a process, though the specifics vary widely. Most require you to file with a local review or equalization board within a set window after receiving the notice. That window ranges from about 30 days to several months depending on where you live, and some jurisdictions use fixed calendar deadlines rather than rolling timelines. Missing the deadline almost always means waiting until the next assessment cycle. The appeal goes to the assessor’s office, not to a state appraiser board, because the two systems are separate.