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Low Appraisals, Reviews and Second OpinionsBy Gordon Hall7 min read

Reconsideration of Value: What a Lender Considers and How to Write the Request

A reconsideration of value asks the appraiser, through the lender, to reassess the report. What a lender weighs, what it sets aside, and how to write it.

Staged living room with gray sofas, a patterned tile fireplace surround, a wall-mounted television and a black ceiling fan

A reconsideration of value, or ROV, is 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 lender considers whether the request names specific unsupported, inaccurate or deficient parts of the report and explains why the new data supports a second look; for loans sold to Fannie Mae, it may include no more than five comparable sales, and one borrower-initiated request is allowed per appraisal. Write it as a short, factual document: identify the report, list each issue with its evidence, and leave out any figure you were hoping for.

This article covers what the lender weighs, what it sets aside, and a structure for the request that keeps it on evidence. The step-by-step route through the lender is in how to challenge a home appraisal through the lender, and every option after a questioned report is collected in the low appraisals, reviews and second opinions hub.

What does a lender consider in an ROV?

Fannie Mae's Selling Guide, topic B4-1.3-12, is the most detailed public statement of what a borrower's request must contain. For loans sold to Fannie Mae, it lists:

  • The borrower's name, the property address, the appraiser's name and the date of the request.
  • The effective date of the appraisal, the date the opinion of value applies to.
  • An identification and description of the unsupported, inaccurate or deficient areas of the report.
  • An explanation of why the new data supports the request.
  • Comparable sales, if any are submitted, not to exceed five.

The same topic describes the grounds: a value that is not supported, a report that may be deficient because of unacceptable appraisal practices, or a value that reflects prohibited discriminatory practices. Fannie Mae's list of unacceptable appraisal practices includes misrepresenting physical characteristics, using inappropriate comparable sales, and adjustments that do not reflect market reaction, so a request that ties each point to one of those categories is speaking the lender's language. The lender must also complete its own appraisal review before starting the ROV process, so it reads the report alongside your request.

What does a lender set aside?

Requests fail most often on what they include, not what they leave out. These do not support an ROV:

  • An automated estimate such as a Zestimate, which is a statistical figure and not an appraisal.
  • An agent's CMA, an opinion of likely list or sale price, which is not an appraisal.
  • The county's assessed value, the taxable value under California's assessment rules, which is not an appraisal.
  • Active and pending listings, asking prices, and improvements described without dates or documents.
  • Any statement of the value the loan needs, any reference to the contract price as a reason, and any comment on the appraiser's competence.

The last group matters for a second reason. Federal lending rules at 12 CFR 1026.42 prohibit trying to influence a value through coercion, inducement or instruction, and expressly permit asking the appraiser to consider additional property information, to explain a conclusion, or to correct errors. 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 the line the request has to stay behind.

How should the request be written?

Use the lender's form if it has one. Whether it does or not, this order keeps the request readable by an underwriter who has never seen the house.

  1. Identification. The five items Fannie Mae lists: borrower, address, effective date, appraiser and request date.
  2. A one-line summary. For example: "This request identifies [number] factual corrections and [number] closed sales the report did not consider."
  3. Factual corrections, one per paragraph. State what the report says, what the record shows and which document proves it. For example: "The report lists gross living area of [figure] square feet. The rear room was enclosed under a permit finaled on [date]; the permit and a measured sketch are attached."
  4. Comparable sales, five at most. Closed sales only, within the report's time frame, each with one sentence on why a buyer of this house would have weighed it.
  5. Unexplained choices, as questions. For example: "Comparable 2 is across the county line. Could the report explain the location adjustment, or its absence?"
  6. Attachments. Permits, sketches, survey or plot plan, dated invoices for documented work, and the sale records.

A blank grid for the sales keeps the comparison easy to follow:

SaleClose dateGross living areaLotYear builtWhy it is comparable

1

-

-

-

-

-

2

-

-

-

-

-

3

-

-

-

-

-

Gross living area here means the finished, heated space above grade, measured the way the report measures it, so the comparison is like for like.

Choosing the sales: a Rancho Cucamonga example

A request to dispute a home appraisal in Rancho Cucamonga shows why the sales matter more than the argument. The city joined older foothill communities, Alta Loma and Etiwanda, where many lots are larger, some are zoned for horses and trails run through the neighborhoods, with planned villages such as Victoria and Terra Vista, where floor plans repeat. The kinds of points that come in are specific: an Alta Loma horse lot valued with a planned-village tract house because the tract sale was closer, or a planned-village home compared with a different builder's plan series with no size or quality adjustment. The useful submission is the closed horse-lot sale, or the same-plan sale, with the reason it fits. The Rancho Cucamonga area page describes these pockets.

The same logic applies around Claremont: a Claraboya hillside home is answered with foothill sales from a wider band, not flat lots below Foothill Boulevard. What a reviewer checks first on an appraisal report lists the local patterns.

What happens after the request is sent?

The lender decides whether to forward it. 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. Fannie Mae does not allow a borrower to submit an ROV after the loan has closed, and lenders set their own process, so confirm the current steps with yours. No request can promise a change in value.

Some borrowers want an independent appraiser to read the report first. 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 the errors and comparable problems in a form a borrower can submit, and it may find the original report supported. The pillar, how to challenge a low appraisal: review vs. new appraisal, explains when a review fits. To have a report examined before you write the request, use 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

What is a reconsideration of value?

A reconsideration of value, or ROV, is a request from a lender to the appraiser to reassess an appraisal report based on potential deficiencies or other information that may affect the value conclusion. The borrower asks the lender, and the lender decides whether to send the request to the appraiser.

What should a reconsideration of value request include?

For loans sold to Fannie Mae, the request includes the borrower's name, the property address, the appraisal's effective date, the appraiser's name and the request date, a description of the unsupported, inaccurate or deficient areas of the report, an explanation of why the new data supports reconsideration, and no more than five comparable sales.

Can I use a Zestimate or my agent's CMA in a reconsideration of value?

They do not support the request. An automated estimate such as a Zestimate and an agent's comparative market analysis are not appraisals. A lender weighs documented factual corrections and closed comparable sales, each with a reason it is similar to the property.

Will a reconsideration of value change my appraisal?

It may or may not. The appraiser considers the evidence and either revises the report with an explanation or explains why it stands, and the lender may also order a new appraisal. No request can promise a change in value.

Gordon Hall

Mr. Cali Appraisals

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