Reconsideration of Value 2026: How to Submit an ROV That Actually Works

A Reconsideration of Value is a formal process for requesting an appraiser to reconsider the appraised value based on specific, documented evidence of error or omission. It is not a complaint that the number was too low. Done correctly, an ROV can increase value; done incorrectly, it creates a paper trail of improper pressure and generates regulatory risk.

Valid Grounds for an ROV

• ✦Factual errors in the appraisal: incorrect square footage, wrong bedroom count, wrong lot size, incorrect condition rating
• ✦Superior comparable sales not considered: more recent, more proximate, or more similar sales the appraiser overlooked
• ✦Distressed sales used as comparables when non-distressed sales were available in the same market
• ✦Adjustments that are inconsistent with paired sales data in the subject market

What Cannot Be in an ROV

An ROV cannot include transaction details: purchase price, loan amount, the buyer's financial need, or how many points above asking the offer was. Including transaction information in an ROV is a USPAP violation and a regulatory risk to the lender. Do not reference the contract price. Do not tell the appraiser what value is needed.

The Submission Process

Submit the ROV in writing to the lender. The lender forwards it to the AMC, which forwards it to the appraiser. FHFA guidance from 2024 strengthened borrower ROV rights and requires appraisers to provide a written response to each point raised. The appraiser must either address the evidence provided (accepting or explaining why a comparable was not used) or revise the value.

Timeline and Escalation

Most AMCs turn around ROV responses within three to seven business days. If the ROV is rejected and the value is still demonstrably incorrect based on objective evidence, a second appraisal may be ordered by the lender in limited circumstances. This is uncommon and requires lender management approval. In most cases, the first appraisal stands unless the ROV succeeds.