Can a Florida real estate agent charge for a valuation?

Yes. Under Florida Statute 475.612(2), a licensed broker, broker associate, or sales associate who is not a certified or licensed appraiser may provide valuation services for compensation, as long as they do not represent themselves as a certified, licensed, or registered appraiser. The statute permits payment but sets no fee and no cap, and the opinion may never be called an appraisal.

Does my lender always need a full appraisal?

Not always. For residential transactions covered by the Federal Reserve, FDIC and OCC appraisal rules, a transaction value of 400,000 dollars or less qualifies for a threshold exemption from the appraisal requirement. An institution using that exemption must still obtain an appropriate evaluation of the real property collateral. Other exemptions and lender requirements still matter, and a lender may require an appraisal even when an evaluation is permitted. Ask your lender which valuation product your transaction requires.

Which statute governs broker price opinions in Florida?

Section 475.612. It permits brokers and sales associates to perform comparative market analyses, broker price opinions, and other opinions of value in the ordinary course of business. Section 475.628 is a different provision covering professional standards for registered, licensed, and certified appraisers in federally related transactions, and it is not the source of broker price opinion authority.

Private Valuation vs Appraisal In Florida

Key facts

Appraiser licensing authority: Florida Statutes Chapter 475, Part II, sections 475.610 through 475.631, governs licensing, standards, and discipline for state-licensed and state-certified real estate appraisers in Florida.^[1]
Statute permitting a broker price opinion: Section 475.612 permits real estate brokers and sales associates to perform comparative market analyses, broker price opinions, and other opinions of value in the ordinary course of business, and states that such an opinion may never be referred to or construed as an appraisal.^[2]
Compensation for a non-appraiser licensee: Under section 475.612(2), a Florida-licensed broker, broker associate, or sales associate who is not a certified or licensed appraiser may provide valuation services for compensation, provided they do not hold themselves out as a certified, licensed, or registered appraiser.^[2]
Federal residential appraisal threshold: The 2019 federal rule raised the threshold from 250,000 dollars to 400,000 dollars for covered residential transactions. Transactions at or below the threshold can use an evaluation; other exemptions and lender requirements still matter.^[4]
How long the prior threshold stood: The residential appraisal threshold had not been changed since 1994 before the 2019 rule.^[8]
Which section is not the BPO authority: Section 475.628 addresses professional standards for registered, licensed, and certified appraisers, requiring compliance with Appraisal Standards Board standards for federally related transactions. It is not the section permitting a broker price opinion or comparative market analysis.^[3]

What makes a document an appraisal in Florida

Section 475.612(1) generally reserves issuing an appraisal report and receiving direct compensation to certified or licensed appraisers. Work may be performed by others when a certified or licensed appraiser supervises and approves it, signs the report and takes responsibility. Registered trainees receive appraisal compensation through their authorized certified appraiser. Subsections (4) through (6) include limited provisions for expert witnesses, supervised graduate students and government employees acting within their employment. These exceptions do not establish that an ordinary buyer can substitute an exempt report for the appraisal a lender requires.

For a buyer commissioning an appraisal, verify the appraiser's credential, the report's intended use and the standards the recipient requires. Section 475.628 governs professional standards for registered, licensed and certified appraisers. It also permits board rules for alternate standards in nonfederally related work, subject to the Ethics and Competency Rules and other board requirements. The statutory framework therefore needs more care than a blanket statement that every appraisal has the same licensing and standards requirements. Confirm the intended recipient's requirements before ordering a report.

What a broker price opinion or comparative market analysis actually is

Section 475.612 is the operative provision. It permits real estate brokers and sales associates to perform comparative market analyses, broker price opinions, and other opinions of value in the ordinary course of business, and it expressly states that such an opinion may never be referred to or construed as an appraisal. Under section 475.612(2), a Florida-licensed broker, broker associate, or sales associate who is not a certified or licensed appraiser may provide valuation services for compensation, provided they do not represent themselves as a certified, licensed, or registered appraiser.

Two practical consequences follow. First, paying for a broker price opinion is lawful in Florida; the statute permits compensation and sets no fee or cap. Second, the resulting document cannot be relabeled. A private valuation, however it is packaged, whether as a desktop review, an automated model output, or a written opinion of value, sits outside the Chapter 475 Part II licensing and discipline framework, and lenders and regulators do not treat it as equivalent to a licensed appraisal in a federally related transaction above the applicable threshold.

It is worth being precise about the citation, because it is commonly misstated. The authority for a broker price opinion is section 475.612, not section 475.628. Section 475.628 covers appraiser professional standards.

When a lender is required to order an appraisal

In 2019 the Federal Reserve Board, FDIC and OCC adopted a rule raising the appraisal threshold for covered residential real estate transactions from 250,000 dollars to 400,000 dollars. The threshold had last changed in 1994. This is a rule for transactions subject to the federal agency appraisal regulations, not a universal promise that every loan above that amount requires an appraisal or that every smaller loan avoids one. Other exemptions and the lender requirements still need review.

For transactions exempted by this threshold, institutions must obtain an evaluation of market value. A buyer should ask the lender which valuation product is required for the actual transaction before ordering a separate report. If an appraisal is used, the agencies require review for compliance with professional appraisal standards. A personal pricing analysis does not replace the valuation the lender requires, and an exemption from a particular appraisal rule does not remove the need to evaluate the collateral.

Choosing between the 2, and what each one is good for

Use an appraisal when the number has to survive scrutiny by a third party: mortgage underwriting, an estate filing, a property tax appeal, a divorce or partnership dissolution, or litigation. In those settings the value of the document lies in the credential and the standards behind it, and a broker opinion will be given little weight.

Use a private valuation when the number is for your own decision making: setting a bid, testing whether an asking price is defensible, screening a portfolio, or deciding whether to pursue a property at all. It is faster and cheaper, and on an off-market or pre-listing decision it is often the only analysis available in the time you have. Just keep the labeling honest, which is what the statute requires anyway. Valuation requests are not appraisals and should not be used for lending, legal, or tax purposes.

What the records cannot show

No public record shows the fee paid for a broker price opinion, because section 475.612 permits compensation without setting or capping a rate.
A private valuation carries no state disciplinary file, so there is no public record of a complaint history the way there is for a licensed appraiser.
Public records do not show whether a lender obtained a full appraisal or a written evaluation on a given loan.
Neither product records the interior condition assumptions it relied on unless the report itself states them.

FAQ

Frequently asked questions

Can a Florida real estate agent charge for a valuation?: Yes. Under Florida Statute 475.612(2), a licensed broker, broker associate, or sales associate who is not a certified or licensed appraiser may provide valuation services for compensation, as long as they do not represent themselves as a certified, licensed, or registered appraiser. The statute permits payment but sets no fee and no cap, and the opinion may never be called an appraisal.
Does my lender always need a full appraisal?: Not always. For residential transactions covered by the Federal Reserve, FDIC and OCC appraisal rules, a transaction value of 400,000 dollars or less qualifies for a threshold exemption from the appraisal requirement. An institution using that exemption must still obtain an appropriate evaluation of the real property collateral. Other exemptions and lender requirements still matter, and a lender may require an appraisal even when an evaluation is permitted. Ask your lender which valuation product your transaction requires.
Is a broker price opinion the same as an appraisal?: No. Section 475.612 prevents a comparative market analysis or broker price opinion from being called or construed as an appraisal. The general appraisal report rule reserves issuance and direct compensation to certified or licensed appraisers, with specific statutory exceptions. Registered trainees work under supervision. Confirm the recipient's required report, credentials and standards before relying on a valuation.
Which statute governs broker price opinions in Florida?: Section 475.612. It permits brokers and sales associates to perform comparative market analyses, broker price opinions, and other opinions of value in the ordinary course of business. Section 475.628 is a different provision covering professional standards for registered, licensed, and certified appraisers in federally related transactions, and it is not the source of broker price opinion authority.

Sources & citations

Factual claims on this page are attributed to the sources below. Public records may lag current market activity. See methodology for the full data-use disclosure.

Florida Senate. 2026 Florida Statutes, Chapter 475. Accessed 2026-10-01. Primary public record, confidence: high.
Claim supported: Chapter 475, Part II, sections 475.610 through 475.631, governs licensing, standards, and discipline for state-licensed and state-certified real estate appraisers in Florida.
Florida Legislature. Florida Statute 475.612, Certification, licensure, or registration required. Accessed 2026-10-23. Primary public record, confidence: high.
Claim supported: Section 475.612 sets the general appraisal report issuance, direct compensation and trainee supervision rules, includes limited expert witness, graduate student and government employee exceptions, and permits eligible real estate licensees to provide valuation services without calling a broker price opinion or comparative market analysis an appraisal.
Florida Legislature. Florida Statute 475.628, Professional standards for appraisers. Accessed 2026-10-23. Primary public record, confidence: high.
Claim supported: Section 475.628 governs appraiser professional standards and permits board rules for alternate standards in nonfederally related transactions, subject to Ethics and Competency Rules and other board requirements. It is not the provision permitting broker price opinions.
Board of Governors of the Federal Reserve System. Agencies raise the threshold for residential real estate transactions requiring an appraisal. Published 2019-09-27. Accessed 2026-10-23. Primary public record, confidence: high.
Claim supported: The September 27, 2019 release confirms a 400,000 dollar threshold, up from 250,000, and evaluations for covered exempt transactions. The prior threshold dated to 1994.
Board of Governors of the Federal Reserve System. 12 CFR 225.63, Appraisals required and evaluations required. Accessed 2026-10-23. Primary public record, confidence: high.
Claim supported: Section 225.63(a)(1) exempts covered residential real estate transactions with a transaction value of 400,000 dollars or less from the appraisal requirement. Section 225.63(b) requires an appropriate evaluation for that exemption. Other exemptions and the agency's authority to require an appraisal for safety and soundness also apply.
Board of Governors of the Federal Reserve System. Interagency Appraisal and Evaluation Guidelines. Accessed 2026-10-23. Primary public record, confidence: high.
Claim supported: Section XI says an institution should establish policies for when to obtain an appraisal even where the regulations permit an evaluation, including consideration of higher risk transactions. This supports checking the lender's actual requirements rather than promising that a loan below the threshold will avoid an appraisal.
Federal Register. Real Estate Appraisals, final rule. Published 2019-10-08. Accessed 2026-10-01. Primary public record, confidence: high.
Claim supported: Institutions must still obtain a written evaluation of market value for transactions exempted by the residential appraisal threshold, and must review any appraisal used for USPAP compliance.
Office of the Comptroller of the Currency. OCC news release on the residential real estate appraisal threshold. Published 2019. Accessed 2026-09-16. Primary public record, confidence: medium.
Claim supported: The residential appraisal threshold had not been changed since 1994 prior to the 2019 rule.

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Advisory content is educational only. PALMBEACHREAL.ESTATE does not rank, endorse, or guarantee specific real estate professionals. Buyers and sellers should independently evaluate representation and seek appropriate legal, tax, insurance, and financial advice.

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