Have Selling Questions? Ask Poli


Fannie Mae customers! Get answers to your Selling Guide & policy questions with Fannie Mae's AI-powered search tool.

Launch Ask Poli for Sellers  

Guide Resources

Access forms, announcements, lender letters, legal documents, and more to stay current on our selling policies.

View Resources  

FAQs: Appraiser Independence (AIR) (Aug. 2023)

Appraiser Independence Requirements (AIR)

Frequently Asked Questions

Updated Aug. 02, 2023

Fannie Mae and Freddie Mac (government sponsored enterprises or GSEs) published their Appraiser Independence Requirements in October 2010. Updates to AIR and these FAQs were published in August 2023. The requirements provide important protections for mortgage investors, home buyers, and the housing market. The updates do not change the intent or principles of the requirements. The removal of previous FAQs does not mean the question and answers are no longer applicable or relevant, but rather the FAQs were redundant or the edits to AIR have clarified those topics so they would no longer be frequently asked questions.

These FAQs provide additional information in response to common questions about the Appraiser Independence Requirements. The AIR document should always be referenced for clarity as it is our official statement of policy.

Note: Changes since the last update are marked either NEW or UPDATED. Minor (non-substantive) wording, number, and heading changes are not marked.



Scope of Coverage

  1. Does AIR specifically prohibit communication with an appraiser by a real estate agent?

No. Real estate agents and other third parties can be valuable sources of information. Conversations in which real estate agents or other third parties on behalf of the lender attempt to influence the development, reporting, result, or review of an appraisal are prohibited.

  1. Does AIR apply to servicing activities, e.g., loss mitigation, MI removal, pre-foreclosure transactions, etc.? NEW

No. AIR is specific to a "mortgage origination transaction,” and servicing or portfolio management activities are not "mortgage origination transactions." However, the basic principles should be applied to protect the process and mitigate risk.

  1. How do the GSEs audit compliance with AIR? NEW

Compliance with AIR is part of each GSE’s operational review of the lender. By selling the loan to a GSE, the lender represents and warrants compliance with that respective GSE’s selling requirements, including compliance with AIR.

Back to Top

Selection of an Appraiser

  1. When selecting an appraiser, may lenders use a pre-approved appraiser list or panel? UPDATED

Yes. Lenders may use a pre-approved list or panel to select a residential appraiser, provided that:

(1) any employees of the lender tasked with selecting appraisers for the list are independent of the loan production staff; and

(2) the loan production staff is not involved in selecting an appraiser off the list for a particular appraisal assignment. See AIR section IV.D

  1. How does Section I.B.(8) impact how lenders may remove appraisers from a list of qualified appraisers? UPDATED

AIR section I.B. (9) addresses the removal of an appraiser from a list of qualified appraisers in connection with influencing or attempting to influence the outcome of an appraisal. Also see sections IV.A.(2), IV.D., and VIII.

  1. Some lenders have proprietary automated origination systems that include a process for ordering appraisals. How does AIR impact those systems?

The lender must review its systems to ensure that the appraiser selection process complies with AIR.

  1. Who should be considered the “restricted parties” for purposes of achieving appraiser independence? UPDATED

The term “restricted parties” refers to the loan production staff who are responsible for generating loan volume or approving loans, as well as their subordinates. This would include an employee whose compensation is based on loan volume or the closing of a loan transaction. Employees responsible for the credit administration function or credit risk management are not considered loan production staff. See AIR section IV.A.(1)

  1. Can a restricted party participate in the onboarding, selection, or offboarding of an Independent Party? NEW

No. Restricted parties cannot participate at any level. These actions have to be completed by parties that are independent of loan production. See section IV.A.(2).

  1. Are employees of the lender, such as processors, closers, or underwriters, that do not receive commissions or incentives for the closing of a loan permitted to order appraisals? NEW

Yes, if their immediate supervisor is not a member of the mortgage production staff or otherwise participates in the lender’s mortgage production process and is not considered a restricted party. See AIR sections IV. and VIII.

  1. May a representative of the lender provide an appraisal management company a list or a panel of appraisers to use for loans involving a specified mortgage broker, real estate agent, or loan officer? UPDATED

No. No one is allowed to provide a list or a panel of appraisers to use for loans involving a specified mortgage broker, real estate agent, or loan officer? See AIR sections I.B.(9) and IV.A.

Back to Top

In-House Appraisers

  1. Are lenders and correspondent lenders permitted to use in-house appraisers to obtain appraisals? NEW

Yes. In-house appraisers may be used in accordance with AIR, section V.

Back to Top

Appraisal Management Companies (AMCs)

  1. Is a lender required to use an AMC for ordering appraisals? UPDATED

No. A lender may order appraisals directly from an individual appraiser, appraisal company, or an AMC.

  1. May a lender order an appraisal by directing a mortgage broker to select an AMC from among a group of specifically authorized AMCs, one of which would receive information from the mortgage broker about the loan application and begin the appraisal process? NEW

No. A mortgage broker may not have any involvement in selecting a protected party. See section IV.A.(2).

  1. If a lender has an approved group of AMCs, is it acceptable for a mortgage broker to independently select from that group if it’s done on an established timetable or eligibility window, and not on an individual loan basis? For example, every 120 days the mortgage broker has the opportunity to switch to a different approved AMC. NEW

No. A mortgage broker may not have any involvement in selecting a protected party. See section IV.A.(2).

  1. May a lender direct a mortgage broker to use a web portal set up either by the lender, or by the lender’s authorized agent, through which the mortgage broker inputs a request for an appraisal that triggers the lender’s system to order an appraisal? UPDATED

Yes. A lender may direct a mortgage broker to use a web portal in this manner so long as the web portal does not allow the mortgage broker to have control of picking the AMC as noted in AIR sections I.B.(10) and IV.A.

Back to Top

Mortgage Brokers

  1. May brokers select a specific AMC if the lender works with more than one AMC? UPDATED

No. If the lender works with more than one AMC, the lender must select the AMC. The mortgage broker cannot select from a list of approved AMCs. See section IV.A. (2).

  1. May a lender accept an appraisal that was ordered by a mortgage broker? UPDATED

No. AIR does not allow a lender to accept an appraisal that was ordered by a mortgage broker, loan officer, or real estate agent as noted in AIR section IV.A.(2).

  1. May a lender accept a mortgage broker’s recommended list of independent parties? NEW

No. The lender may not use a list provided by a mortgage broker or any other restricted party. See sections I.B.9 and IV.A.(2)..

  1. May a mortgage broker order an appraisal directly from an AMC that was specifically authorized by the lender? UPDATED

No. AIR prohibits mortgage brokers from ordering appraisal services. See section IV.A.(2).

  1. Does AIR permit a mortgage broker to select an appraiser from the lender’s list of approved appraisers if the lender is responsible for the relationship with the appraiser, including compensation? UPDATED

No. AIR prohibits lenders from relying on an appraisal if the mortgage broker had a role in selecting, retaining, or compensating the appraiser. See section IV.A.(2).

Back to Top

Transfer of the Appraisal

  1. Can a lender use an appraisal that was obtained by another lender in connection with a loan that was originated and submitted by a mortgage broker when the mortgage broker was not involved in the ordering of, or managing the process for, the appraisal? UPDATED

Yes. A lender may accept an appraisal transfer from a different lender in accordance with the requirements of AIR sections VI. and VIII., all Fannie Mae Selling Guide requirements, and related documents.

  1. Lender A (an approved GSE Seller/Servicer) originates and closes a loan in its name but sells it to lender B (also an approved GSE Seller/Servicer), which in turn sells that loan to that GSE. Is lender B under any obligation to obtain a new appraisal? UPDATED

No. Lender B may buy a closed loan from Lender A and sell the loan to the GSE without a new appraisal if Lender B can represent and warrant that any appraisal conducted in connection with the loan conforms to AIR sections VI. and VIII., all Fannie Mae Selling Guide requirements, and related documents.

Back to Top

Payment of the Appraisal

  1. If the appraisal is ordered by the lender in a manner compliant with AIR, are there any specific requirements  about payments to the appraiser? UPDATED

Yes. the lender or any third party specifically authorized by the lender shall be responsible for providing for payment of all compensation to the appraiser. See AIR section IV.B.

  1. Are borrowers precluded from providing payment for an appraisal to an AMC? UPDATED

No. AIR does not prohibit a borrower from providing payment to an AMC acting as an agent of the Seller; however, the borrower may not pay the appraiser directly for an appraisal.

Back to Top

Appraisal Report

  1. How is “closing” of the loan defined? Is closing the date the documents are executed or the date the funds are disbursed?

We define “closing” as the date the borrower executes the loan documents.

Back to Top

Appraisal Reviews

  1. Does AIR prohibit members of a lender’s staff, or the staff of an authorized third party, from communicating with an appraiser for corrections of factual errors in the appraisal report? UPDATED

No. Communications with an appraiser regarding corrections of factual errors may be made by anyone on the staff of the lender, or on the staff of an authorized third party. See AIR, section IV.A.

  1. Who on the lender's staff, or on the staff of an authorized third party, may have communications with an appraiser relating to or having an impact on valuation, including ordering, or managing an appraisal assignment? UPDATED

Anyone who is not part of loan production staff or who is not compensated on a commission basis upon successful completion of a loan or anyone who does not report, ultimately, to any officer of the lender not independent of the loan production staff or process, may have communications with an appraiser relating to or having an impact on valuation, including ordering or managing an appraisal
assignment. See AIR, section IV.A.(2).(c).

Back to Top


  1. Is a loan eligible for sale to the GSEs if the lender purchased the loan from a correspondent that did not comply with AIR in originating that loan? UPDATED

No. It is the lender’s responsibility to ensure that loans it purchases with intent to deliver to the GSEs comply with AIR and all of our Fannie Mae Selling Guide requirements.

  1. Do sellers need to adopt policies to address potential misconduct such as bribery or intimidation of appraisers? UPDATED

Yes. A seller must have in place policies and procedures to ensure-compliance with AIR. See AIR 
section VIII.


View Appraiser Independence Requirements.

Back to Top

Have You Tried Ask Poli?

Poli knows. Just ask.

Ask Poli features exclusive Q&As and
more—plus official Selling & Servicing

Try Ask Poli

Related Articles


Customers Recommend Ask Poli

If you have additional questions, Fannie Mae customers can visit Ask Poli to get information from other Fannie Mae published sources.

Guide Resources

For a comprehensive list of resources such as access forms, announcements, lender letters, notices and more.

Visit Selling and Servicing Guide Communications and Forms

Having Issues with Seeing this Page Correctly?

Use Firefox or Chrome   How to do a hard refresh in Internet Explorer
We recommend that you use the latest version of FireFox or Chrome.

Download Firefox
Download Chrome
  A hard refresh will clear the browsers cache for a specific page and force the most recent version of a page.
    Hold the Ctrl key and press the F5 key.

Email Us
If you still have Technical Support questions, feel free to emailAsk_Poli@fanniemae.com.