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Can a Lender Require Repairs With an Appraisal Waiver?

By The Housing Current Editorial TeamOctober 27, 20264 min read

An appraisal waiver can still leave repairs to resolve. See Fannie Mae’s property-data rules, completion evidence, and deadlines to confirm with your lender.

A lender can require repairs even when your loan receives an appraisal waiver. Under Fannie Mae’s value acceptance + property data option, acceptance of the submitted value leaves the lender responsible for property eligibility and condition. A collection visit can therefore lead to an inspection or repair requirement even though no appraiser is developing a value opinion. Fannie Mae’s lender-responsibility rules

The rules below apply to that Fannie Mae conventional-loan workflow as of October 27, 2026. FHA, VA, and Freddie Mac have separate requirements.

Identify which valuation option you have

Ask the loan officer for the exact option shown in Desktop Underwriter, or DU, Fannie Mae’s automated underwriting system. The distinction determines whether the loan requires property-data collection, an appraisal, or neither.

Process What it provides
Ordinary value acceptance Acceptance of the lender-submitted value without an appraisal or the additional collection required by the property-data option.
Value acceptance + property data Acceptance without an appraisal, plus a trained collector’s interior and exterior observations for property-eligibility review.
Hybrid appraisal An appraiser’s value opinion using collected property data and other sources. Collection and appraisal are separate assignments.
Independent home inspection An assessment of physical condition by an inspector accountable to the buyer.

With the property-data option, the lender orders collection after receiving the DU offer. The collector records observations; the lender reviews eligibility. Even if the collector is an appraiser, the collection assignment does not develop a value opinion. Fannie Mae’s workflow

That visit does not replace an independent home inspection. The CFPB recommends an inspector accountable to you. Your ability to negotiate repairs or cancel depends on your purchase contract; consult your real estate attorney about contractual rights and deadlines. CFPB guidance

When a finding leads to an inspection or repair

The lender reviews descriptions and photos for property eligibility and may need a qualified professional’s report to resolve a concern. A report about a roof, foundation, or electrical system may establish that the property is eligible or that repairs are necessary. Selling Guide B4-1.4-11

Minor conditions or deferred maintenance do not automatically require repairs. Fannie Mae’s FAQ permits proceeding without further action when they do not affect safety, soundness, or structural integrity, there is no significant unfinished construction or renovation, and the property type is eligible. Property-valuation FAQ

In a hypothetical transaction, a worn-looking roof could prompt a roofing inspection. A satisfactory report might clear the concern; a documented defect might require repair. Confirm whether the lender is waiting for an assessment or proof of completed work.

Document completion when no appraisal exists

Fannie Mae directs lenders to a borrower attestation letter for repair completion in this workflow. Form 1004D applies to an underlying appraisal and cannot verify completion here. Property-valuation FAQ

The completion-documentation rules require:

  • The borrower’s name and the home’s address.
  • A signed, dated statement confirming satisfactory completion.
  • Visual evidence showing the finished work.
  • At least one additional item: a qualified professional’s signature, a professional report, or paid repair invoices.

A report identifying a defect does not establish that subsequent repairs were completed. Ask whether the lender needs a follow-up report after the work.

Digital exhibits must remain unaltered and permit authentication through metadata and the property’s geocode. The lender retains the letter and supporting documents; linked digital exhibits must remain accessible to Fannie Mae for the loan’s life. Completion-documentation requirements

Fannie Mae’s UAD 3.6 supplement, published September 2, 2026, retains this attestation route. If the loan instead proceeds with an appraisal, see the completion-report workflow when an appraisal exists.

Separate the note date, closing, and loan sale

Collection and repair requirements attach to different milestones:

  • Before the note date: The property-data collection must be completed and successfully submitted to Fannie Mae’s system. The offer must be no more than four months old on the date of the note and mortgage. Program requirements
  • Before closing: Fannie Mae’s FAQ requires the lender to order, review, and successfully submit the collection. Separately, confirm the lender’s deadline for clearing each repair condition. Property-valuation FAQ
  • Before sale to Fannie Mae: Repairs necessary to meet property-eligibility requirements must be completed, with satisfactory evidence that the condition was corrected. Selling Guide B4-1.4-11

The loan-sale deadline does not give a buyer permission to defer work until after closing. A lender can require repairs before closing; confirm its deadline before negotiating a repair schedule with the seller. CFPB guidance on repair conditions

Can the waiver option disappear?

Yes. The final DU submission must still offer the option. Changes in qualifying loan characteristics can remove it; in some cases, the existing collection can support a hybrid appraisal instead. Fannie Mae’s eligibility rules

New property information can also require a different approach. Fannie Mae’s value acceptance rules require an appraisal when the lender believes additional information or subsequent events warrant one. Once an appraisal is obtained for the transaction, the lender cannot exercise value acceptance. Selling Guide B4-1.4-10

That helps explain why an early automated underwriting approval can still leave closing conditions.

Get a condition you can act on

Ask the lender to put five points in writing:

  1. The unresolved issue: Which observation or photograph raised the concern, and what property requirement applies?
  2. The requested action: Is this a specialist inspection, a repair, or completion of unfinished work? Is the condition required by Fannie Mae or the lender’s own policy?
  3. Acceptable proof: Who qualifies to inspect or sign, which images and documents are needed, and who will approve them?
  4. Additional charges: What will collection, specialist reports, verification, and any replacement appraisal cost, and who is expected to pay?
  5. The deadline: Must each item be cleared before signing, funding, or loan sale, and how much review time should the parties allow?

Share those written requirements with the seller and contractor before they agree on the work and schedule, so the plan includes both the repair and the evidence needed to clear the condition.

Written by

The Housing Current Editorial Team

Editorial Team

Reporting, analysis, and practical explainers across housing markets, mortgage finance, real estate business, investing, policy, and homebuilding.

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