The short version for whoever has to clear the condition.
- Fannie Mae permits three ways to verify completion: an appraiser on site, an appraiser working from a virtual inspection or site video, or an attestation letter. Most desks only ever use the first one.
- Whichever route you pick, the exhibit has to be unaltered and authenticatable from its metadata and the subject property's geocode, and a linked exhibit has to stay reachable for the life of the loan.
- Written for the funding manager, appraisal desk manager or construction lending ops lead who has a "subject to" item outstanding and a closing date that is not moving.
The closing is Thursday and the condition says the work has to be finished. The appraisal came in subject to a finished deck, a repaired roof, or a renovation that was still drywall when the appraiser walked it. Somebody now has to confirm the work is done before the money moves.
In most shops that means ordering a 1004D, waiting for an appraiser to drive back out, and hoping the answer is yes. That is one route out of three, and it is the slowest and most expensive of them.
This is the lender-side version of that decision. What the certificate of completion inspection actually certifies, which of the three permitted routes fits which loan, what the evidence in the file has to carry, and the four places this reliably stalls a closing.
If you run completion verification at a bank, credit union, mortgage lender or AMC, the recurring cost here is the second trip to a property somebody already visited. Venta Capture, VentaVid's guided capture platform, is one way to get the exhibit back without that trip, and you can see it on a short Capture demo against one of your own open files.
In this post:
What a completion inspection actually certifies
Form 1004D is two documents sharing one jacket. Part A is the Appraisal Update Report. Part B is the Completion Report, and Part B is the one people mean when they say "certificate of completion".
Fannie Mae's own description of the purpose is narrow on purpose. Per Selling Guide B4-1.2-05, updated 10 December 2025, the form exists to "provide confirmation that the requirements or conditions in an appraisal report have been met".
The scope of a completion inspection is the "subject to" list and nothing else, which is why a 1004D that answers questions nobody asked is as much of a problem as one that answers too few. The appraiser confirms the specific conditions came true. They are not re-valuing the house, and a completion report is not an independent opinion of value.
Three things follow from that, and they matter for how you staff this:
- The condition list is written at origination, not at completion. A vague condition ("complete all repairs") produces a vague answer and a second round of questions. A specific condition list ("install the HVAC condenser, finish the kitchen cabinetry, repair the north-facing roof slope") produces a clearable file.
- Completion is a factual question, value is not. If the finished work differs from what was appraised, you have left completion territory and entered value territory, which is a different form and a different conversation.
- The form is changing underneath you. Under the redesigned Uniform Appraisal Dataset, the legacy 1004D and Freddie Mac 442 survive only where the original appraisal was written on a legacy form. Appraisals on the new URAR use a separate Completion Report. The GSEs' joint timeline puts the hard mandate at 2 November 2026, after which only UAD 3.6 submissions are accepted, with the old pipeline clearing in May 2027.
That last point is worth flagging to your appraisal desk now rather than in November. National Mortgage News reported that lenders are already planning to lean harder on waivers and automated underwriting to absorb any UAD 3.6 crunch, which tells you how much slack the appraisal panel has to give.
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The three routes Fannie Mae allows, and when each applies
I read B4-1.2-05 and B5-3.2-05 side by side to write this section, and the thing that jumps out is what the guide does not do. It lists three acceptable ways to verify completion and never tells you which one to use.
Then the renovation chapter quietly takes two of them away, in a different part of the guide, where nobody reading about completion methods would think to look.
So here is the route table that the guide does not publish. The failure modes in column four come from a practitioner thread rather than from a vendor's marketing page, and the cost of route one comes from a published 2026 fee schedule, both cited further down.
Route 1: the appraiser goes back out
The original route and still the default. Per B4-1.2-05, the appraiser completes the form "based on an on-site visual inspection of the property". Nobody argues with it, every investor accepts it, and it costs a trip fee plus however long the appraiser's calendar takes.
Route 2: the appraiser completes the form remotely
The same guide names the alternatives explicitly: "such as virtual inspections, digital photos, site videos, or other technological solutions". The appraiser still signs. What changes is that they are working from evidence captured at the property by somebody else, instead of standing there themselves.
This is the route most desks under-use, usually because nobody has decided internally what evidence is good enough. That question has an answer, and it is in the next section.
Route 3: the attestation letter
The most overlooked of the three, and for new construction it can replace the 1004D entirely.
- New or proposed construction. A letter signed by the borrower and the builder can confirm the property "was completed and constructed in conformity with the plans and specifications". The guide then adds the sentence that matters: "If a letter signed by both parties is not obtainable, then a Form 1004D completed by the appraiser is required." The 1004D is the fallback, not the first step.
- Existing construction. A borrower letter can confirm completion of certain alterations or repairs, but it has to arrive with a qualified professional's signature, a professionally prepared report, or paid invoices.
Two neighbouring decisions use the same muscle. If you are choosing between a full appraisal and a lighter product in the first place, that sits in choosing a hybrid appraisal over a full appraisal, and the collection standard behind the data itself sits in property data collection and value acceptance. The term itself is defined in our hybrid appraisal glossary entry.
What counts as acceptable evidence
This is the sentence in B4-1.2-05 that decides whether route two works in your shop: "All completion documentation must include one or more visually verifiable exhibits." And then the test: exhibits "must be unaltered and able to be authenticated using metadata and the geocode for the subject property."
A selling guide quietly wrote a provenance requirement into completion verification, which means the question is not whether photos are allowed but whether your photos can still be defended two years after the loan closed. Read the clause as four separate requirements, because that is how a post-close reviewer will read it.
- Visually verifiable. Somebody looking at the exhibit can see the completed item. A photo of a finished bathroom, not a text message saying the bathroom is finished.
- Unaltered. Not re-encoded, not cropped past recognition, not run through a filter. In practice this rules out a photo that has been forwarded through three messaging apps before it reached the file.
- Authenticatable using metadata and the geocode. The exhibit has to carry enough context to tie it to this property. A bare JPEG stripped of its metadata by a chat app fails this, even if the picture is perfectly honest.
- Retrievable for the life of the loan. The guide allows links to digital exhibits, but they "must be accessible by Fannie Mae for the life of the loan". A link that expires in 90 days is not an exhibit.
Here is the honest limit of all of this, and it is worth saying out loud before anyone oversells it internally. Provenance establishes what was received, from where, and when it arrived.
It does not establish that the work meets code, that the right materials were used, or that the item behind the camera is the item on the condition list. That judgement stays with the appraiser or the qualified professional who signs.
We have written the general version of that problem twice: how to verify a customer-submitted photo covers the checks, and what makes a photo or video hold up in a dispute covers what survives when somebody pushes back.
Where the alternatives are off the table
Before anyone builds a remote completion workflow, three exclusions need to be on the policy page.
HomeStyle Renovation. B4-1.2-05 is blunt: the alternative Form 1004D completion method and attestation letters "are not permitted for verifying completion for HomeStyle Renovation transactions". Selling Guide B5-3.2-05, updated 5 August 2026, then sets the rest of the bar: the certification "must be documented on the Appraisal Update and/or Completion Report", it must confirm all "subject to" items were completed, the lender must obtain a certificate of occupancy where local authorities require one for that type of work, and the last disbursement needs a title update confirming first-lien priority and "the absence of any mechanic's or materialmen's liens".
Anything standing between the property and an occupancy permit. The postponed-improvement rules let a lender deliver a loan with work outstanding, but only on conditions. Items must be in the sales contract, postponed for a real reason "such as inclement weather or a shortage of building materials", must not affect the ability to obtain an occupancy permit, must cost no more than 10% of the as-completed appraised value, and must finish within 180 days of the note date. The lender withholds "120% of the estimated cost for completing the improvements", or the full contract price where the builder gave a guaranteed fixed-price contract.
FHA and VA, which run their own forms. FHA repairs are certified on Form HUD-92051, the Compliance Inspection Report, and repairs needing architectural expertise have to be inspected by an inspector rather than the appraiser. Open items go on Form HUD-92300, the Mortgagee's Assurance of Completion. On the VA side, a fee appraiser may certify repairs on 1004D Part B, Freddie Mac Form 442, or their own letterhead, but Part A is not acceptable for VA use. None of these permit a borrower-captured exhibit in place of the inspection, and no HUD source we could find says otherwise.
If your completion problem is actually a staged-disbursement problem, that is a different animal with a different cadence, and it lives in the lender's guide to construction draw inspections. Insurance-funded repairs run on their own track too, covered in loss draft inspections.
Four ways a completion inspection stalls a closing
Every desk has seen these. Three of them are solvable with policy. The fourth only shows up later.
The 1004D comes back "No" over landscaping
The most common version, and it is almost always sod or paint. An appraiser answers no to whether improvements were completed per the original report, because one contract item is outstanding and the ground is too wet to lay turf.
What happens next is lender-dependent, which is why this question keeps circling appraiser forums with no settled answer. In one widely-read thread about exactly this case, appraisers split between "a no means a reinspection" and "it depends on the bank", and several reported lenders closing with a holdback and never sending anyone back out.
Worth correcting while we are here. That thread repeats the figure that lenders escrow "about 150%" of the estimated cost to complete. Fannie's actual number in B4-1.2-05 is 120%, or the full contract price where the builder gave a guaranteed fixed-price contract. If your policy document says 150 because somebody remembered it that way, the policy document is wrong.
Two rules worth writing down:
- Holdback-eligible. Items in the sales contract, postponed for weather or material shortage, that do not block the occupancy permit. MassHousing's published holdback guidelines take exactly this shape, and require the lender to collect and review a 1004D when a holdback is used.
- Never holdback-eligible. Structural work, foundations, septic, roofs, and anything required to meet minimum property standards. FHA guidance is explicit that painting and landscaping can be escrowed and the structural list cannot.
The work does not match the plans
A deviation is not an incomplete item, and treating it as one wastes a week. If the builder swapped the specified windows, moved a wall, or finished a basement that was not in the plans, the question stops being "is it done" and becomes "what is it worth now".
The completion report asks the appraiser to say whether the improvements were completed per the original appraisal's requirements and, if not, to address the effect on market value. That is a value question routed through a completion form, and it needs the appraiser either way. Route two does not save you here.
No final inspection, so no certificate of occupancy
This one cannot be escrowed around. HomeStyle Renovation requires the certificate of occupancy where local authorities require it, and the postponed-improvement rules specifically exclude anything affecting the ability to obtain an occupancy permit.
It also reaches past your file. On financed construction, retainage of 5 to 10% typically does not release until both the certificate of substantial completion and the certificate of occupancy are issued, which means the subcontractors chasing the builder are now part of your timeline.
The exhibit cannot be authenticated later
The quiet one. The condition cleared, the loan funded, and eighteen months later a post-close review asks what the completion documentation consists of. The answer is four photos a loan officer forwarded from a text message, with no metadata, no geocode, and no record of who took them or when.
Nothing went wrong at the time. The file simply cannot satisfy a rule it was always subject to. This is the same exposure pattern as the fabricated and recycled photo problem in draw inspection fraud, and the same reason portfolio-level collateral monitoring keeps drifting toward verifiable capture.
What the second trip costs you
Illustrative numbers, with one real input. Swap in your own volumes.
The $225 is not invented: a published 2026 appraisal fee schedule lists a 1004D reinspection at $225, a recertification at $225, and both together at $350, on top of the base appraisal fee. The volume and the 70% are examples. Your figures will differ.
The fee is the visible half. The invisible half is calendar time on a shrinking panel: the mortgage appraiser population fell from roughly 55,000 in 2015 to 37,000 in 2025 according to data firm MtgeFi, which projects another 10,000 leaving by 2030, and Working RE's 2026 survey of the profession put around 57% of active appraisers over the age of 60. Every condition you can clear without a trip is a trip the panel can spend on an appraisal only an appraiser can do.
If that is the line you are trying to move, you can start a free Venta Capture account and build a completion flow against a real condition list this afternoon.
How the exhibit gets into the file without a second trip
Venta Capture is VentaVid's guided capture platform. You send a secure, personal capture link by SMS, WhatsApp or email, or show a QR code on a portal page or a completion notice.
The borrower, the builder, or the contractor who is already standing at the property opens it in the phone browser. No app, no account, no login.
What makes the submission usable is not the link. It is that your team builds the steps.
- The flow is the condition list. Each "subject to" item becomes its own photo slot or video step, with a label, an instruction in plain language, and an example photo showing what the frame should contain. A retake always asks why, and the answer is stored.
- Scan steps pin the identity of things. A QR or barcode step with a frame and a torch captures a serial plate, a permit placard or an equipment tag, with manual entry as the fallback.
- Conditional questions route the file. A yes or no answer can open the next step, so a deviation gets described and photographed at the property instead of surfacing three days later in an email.
- Everything arrives as one case. The capture, the answers, the transcript of anything said out loud, the timestamps, the device context, the integrity information and the full audit history, filed under your own reference format plus a separate field for the number your origination system already uses.
On the provenance side, the product is specific about what it records. Each submission carries 28 control points: 10 automatic signals, 21 recorded session events, and one signed seal, with a SHA-256 fingerprint and a downloadable manifest so a third party can verify the package without an account.
Every photo and video also carries its own verdict. Something captured in the session reads as taken via Venta Capture with a server-verified receipt time, while something pulled from the gallery is labelled as not verified for provenance, with the caveats shown next to it.
And the framing stays honest, because with a risk committee it has to:
- Signals, not verdicts. A flag is a reason for a human to look, never a finding, and every signal in the interface carries its own caveat.
- The receipt time proves receipt. It records when the submission arrived, not when the work was finished.
- A declined location stays neutral. If the submitter declines, the case says so plainly and nothing is inferred from it.
- It runs in 15 languages, which matters more than it sounds when the person holding the phone is a subcontractor.
The limit is the important part: Venta Capture does not replace a licensed appraiser's signature or their opinion of value, and it does not decide whether a condition is met. The appraiser or the qualified professional still signs the form. This is how their exhibit reaches the file, in a shape that survives being looked at again.
There are no bank, lender or servicer customers to point at here. Venta Capture is young in this sector, the mechanism is what is on offer, and every number in this post comes from somebody else's published source.
The adjacent lending work is further along. See collateral verification for the pillar, site inspection software for lenders for the tooling comparison, business loan site inspections for the commercial side, and the draw inspection glossary entry for the term. The product pages are Venta Capture product and guided video capture.
Frequently asked questions
Is a certificate of completion the same thing as Form 1004D?
Close, but not identical. The "certificate of completion" people order is Part B of Form 1004D, the Completion Report; Part A of the same form is an appraisal update, which is a different job. Under the redesigned UAD, appraisals written on the new URAR use a separate Completion Report instead.
Can the borrower take the completion photos themselves?
For route two, yes, as long as the exhibit meets Fannie's test: visually verifiable, unaltered, authenticatable from metadata and the subject geocode, and reachable for the life of the loan. The appraiser still completes and signs the form. For HomeStyle Renovation, no, because the alternative method is not permitted there.
Does a virtual completion inspection work for HomeStyle Renovation?
No. B4-1.2-05 states that the alternative Form 1004D completion method and attestation letters are not permitted for HomeStyle Renovation transactions, and B5-3.2-05 requires the certification on the 1004D itself. Plan for an on-site inspection on those files.
What happens if the 1004D comes back "No"?
It depends on your own policy and the investor, which is exactly why having a written one helps. If the outstanding item is in the contract, postponed for weather or materials, and does not block the occupancy permit, a holdback at 120% of the estimated completion cost is the usual path; structural items are not eligible and need finishing first.
Who can sign the completion certification?
The appraiser on Form 1004D, or under the attestation route the borrower plus the builder for new construction, or the borrower plus a qualified professional's signature, report or paid invoices for existing construction. FHA repairs needing architectural expertise have to go to an inspector on Form HUD-92051 rather than the appraiser.
Does Form 1004D still exist after the UAD 3.6 mandate?
Yes, but only where the original appraisal was written on a legacy form. From 2 November 2026 only UAD 3.6 submissions are accepted, and appraisals on the new URAR use the redesigned Completion Report, with the legacy pipeline clearing in May 2027.
Does ordering a 1004D trigger the valuation-delivery rules?
Ask your own compliance team, because the answer turns on how your institution treats the document. The usual argument is that a completion report states the state of completion and does not derive an independent value, but that is a compliance judgement and not something a blog post should settle for you.
Talk to us
If completion verification is holding up funding more often than it should, the fastest way to see the difference is on one of your own open files. Bring a real condition list and we will build the capture flow around it on the call, including the items where you will still want an appraiser on site.
What it takes to start.
- A free plan, no credit card, and you can be live in 10 minutes.
- Nothing to install. The person at the property opens a link in their phone browser.
- Stuck? Book a free setup call and we will build your first flow together.
The VentaVid team builds Venta Capture for teams who have to decide something about a place they are not standing in.