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Low Appraisals, Reviews and Second OpinionsBy Gordon Hall6 min read

How to Challenge a Home Appraisal Through the Lender: Reconsideration of Value Step by Step

Challenge a home appraisal through the lender with a reconsideration of value: get the report, find specific errors, write them up, submit via the lender.

Empty bedroom with wood-look plank flooring, white sliding closet doors, a black ceiling fan and a window looking out to trees

To challenge a home appraisal through the lender, you ask the lender, not the appraiser, for a reconsideration of value: a request from the lender to the appraiser to reassess the report based on potential deficiencies or other information that may affect the value conclusion. The steps are to get the full report, read the lender's ROV disclosure, find specific errors or missed closed sales, put them in writing with the evidence, and submit them through your loan officer. The lender decides whether to send the request on, and the appraiser decides whether the evidence changes the report.

This walk-through is for borrowers, and for the agents and loan officers helping them, in Claremont, Upland and the neighboring cities on both sides of the county line. The other routes after a questioned report are collected in the low appraisals, reviews and second opinions hub.

Step 1: Get the complete report

For a loan secured by a first lien on a dwelling, federal rules at 12 CFR 1002.14 require the lender to give the applicant a copy of every appraisal and written valuation developed for the application. Ask for the whole report: the sketch, the photographs, the comparable sales grid, the addenda and the appraiser's comments. A summary page is not enough to find an error.

Step 2: Read the lender's ROV disclosure

For loans sold to Fannie Mae, the lender must give the borrower a disclosure explaining its ROV process when the report is provided. That disclosure tells you what form to use, where to send it and any deadline that applies. Fannie Mae's Selling Guide permits one borrower-initiated ROV per appraisal and does not allow a borrower to submit one after the loan has closed. Other loan programs and lenders set their own policies, so confirm the current process with your lender rather than relying on a general rule.

Step 3: Read the report in the order a reviewer would

Start with the scope: the intended use, what the report will be used for; the effective date, the date the opinion of value applies to; and the scope of work, the type and extent of research and analysis. Then the facts of the house, then the comparable sales, then the adjustments, then the reasoning that ties them together. What a reviewer checks first on an appraisal report covers that order and the local patterns in detail.

Step 4: Sort what you find

Everything you find belongs in one of four groups, and only three of them go to the lender.

  • Factual errors. Gross living area, the finished, heated space above grade, measured or copied wrong; a bedroom or bath missed; the wrong lot size; a permitted addition or ADU left out; a condition rating that ignores documented work.
  • Closed sales the report did not use. Sales similar in size, age, condition and location that closed within the report's time frame. Fannie Mae caps the comparable sales a borrower may submit at five.
  • Choices the report does not explain. A comparable from across the county line, or across the 10 or the 210, with no stated reason and no location adjustment.
  • What stays out. Disagreement with the number, active or pending listings, the price you need for the loan, an automated estimate such as a Zestimate, which is not an appraisal, an agent's CMA, which is not an appraisal, and the county's assessed value, which is not an appraisal either.

Step 5: Write the request

A rebuttal, a written response that disputes specific facts or analysis in an appraisal, takes the form of the ROV inside a loan file. Fannie Mae asks that it identify and describe the unsupported, inaccurate or deficient areas of the report and explain why the new data supports reconsideration. Keep it to facts and closed sales, one point at a time. The format, and what the lender weighs, are covered in what a lender considers in a reconsideration of value.

In Upland, the kinds of points that come up are specific. A west Upland house valued with Claremont Village sales and no location adjustment across the county line. A house in the Euclid Avenue District valued with postwar tracts south of the 210. A San Antonio Heights horse-keeping lot valued with a city tract because the tract sale was closer. Each of those is a question the report can answer or fail to answer, and the Upland area page explains why the pockets sell differently.

Step 6: Submit through the loan officer, not the appraiser

Send the request to your loan officer on the lender's form. Do not call or write to the appraiser; Chase's borrower guidance says the same. Appraiser independence, the rule that a valuation must rest on the appraiser's own judgment and not on pressure from anyone with an interest in the loan, is written into federal lending rules at 12 CFR 1026.42. That rule prohibits trying to influence a value through coercion, inducement or instruction, and it expressly permits asking the appraiser to consider additional property information, including comparable sales, to explain a conclusion, or to correct errors. A well-built ROV does exactly those things and nothing more.

Step 7: Wait for the lender's answer

Fannie Mae requires the lender to complete its own appraisal review before starting the ROV process, so the lender reads the report too. Lender explanations such as Chase's describe three outcomes: the original appraisal stands, the appraiser issues a revised report, or the lender orders a new appraisal. Which one happens is the lender's and the appraiser's decision, and no request can promise a change. If the report stands, the purchase and refinance options in what happens if the appraisal is low are still open.

Where does an independent review fit?

Some borrowers want a second appraiser to read the report before they write the request. An appraisal review, an assignment in which one appraiser develops an opinion about the quality of another's work under USPAP Standard 3, can document factual errors and comparable problems against the data so the borrower can submit them. The reviewer is independent of every party, including the one who orders the review, and may find the original report supported. The pillar, how to challenge a low appraisal: review vs. new appraisal, explains when a review fits and when a new appraisal does.

If you want the report examined before you submit an ROV, send it through appraisal review and second opinion or call (909) 324-6122. The fee is set by the scope of the assignment and quoted before work begins, and it does not depend on the value.

Sources

Gordon Hall, California Certified Residential Real Estate Appraiser, BREA No. AR003877 (lookup: https://www2.brea.ca.gov/breasearch/faces/party/view.xhtml?id=23601). Reports are prepared in conformity with the Uniform Standards of Professional Appraisal Practice (USPAP). Nothing here is legal or tax advice; admissibility is always the court's decision.

Frequently asked questions

How do I challenge a home appraisal ordered by my lender?

Ask the lender for a reconsideration of value. Get the full report, read the lender's ROV disclosure, identify specific factual errors or closed sales the report missed, write them up with evidence, and submit the request through your loan officer. The lender decides whether to forward it to the appraiser.

How many times can I request a reconsideration of value?

For loans sold to Fannie Mae, one borrower-initiated reconsideration of value is permitted per appraisal, and none after the loan has closed. Other loan programs and lenders set their own policies, so confirm the current process with your lender.

Should I contact the appraiser directly to dispute the value?

No. For a lender appraisal, the lender is the appraiser's client and federal rules protect appraiser independence. Send the request through your loan officer, who can ask the appraiser to consider additional information, explain a conclusion or correct errors.

What happens after I submit a reconsideration of value?

The lender reviews the report and the request. Lender explanations describe three possible results: the original appraisal stands, the appraiser issues a revised report, or the lender orders a new appraisal. No request can promise a change in value.

Gordon Hall

Mr. Cali Appraisals

Call (909) 324-6122Contact