How to Dispute a Home Appraisal
If you believe your home appraisal is inaccurate or based on flawed comparable sales, you have the right to request a Reconsideration of Value (ROV) from your lender. This guide explains the ROV process, what evidence to submit, what appraisers must consider, and what to do if the ROV is denied — including ordering a second appraisal or switching lenders.
Appraisals are opinions of value — and opinions can be wrong. Factual errors, missed improvements, and poorly chosen comparable sales all happen. If your appraisal came in below expectations, the Reconsideration of Value (ROV) process is your formal right to challenge it with evidence. This guide walks through every step, from what to look for in the report to escalation options when the ROV is denied.
Grounds for disputing an appraisal
| Type of error | Example | Evidence to submit | Strength of challenge |
|---|---|---|---|
| Factual property error | Wrong square footage, missing bedroom | Permit records, prior appraisal, floor plan | Very strong |
| Missing improvements | Renovated kitchen not reflected | Contractor invoices, photos, permits | Strong |
| Inferior comparable sales used | Comps outside neighborhood, older sales | Better MLS comps with detailed comparison | Strong |
| Distressed comps included | Foreclosure sale used as market comp | Public records confirming distressed sale | Moderate–strong |
| Adjustment errors | Under-adjustment for lot size or condition | Market-supported adjustment data from agent | Moderate |
Step-by-step: the ROV dispute process
- 1 Review the appraisal report carefully before disputing
Before filing a dispute, read the appraisal report in full. Request a copy from your lender — you are entitled to receive it. Look for: (1) Incorrect property facts (wrong square footage, bedroom count, bathroom count, lot size); (2) Missing improvements (additions, renovations, upgraded kitchen or baths not noted); (3) Comparable sales (comps) that are in a clearly inferior location, smaller, in worse condition, or sold under distressed conditions (foreclosure, estate sale); (4) Comps selected from outside the subject property's neighborhood when better matches exist inside it; (5) Time adjustments not applied to older comps in a rising market. Document each specific error with evidence before submitting.
- 2 Submit a Reconsideration of Value (ROV) request
A Reconsideration of Value (ROV) is a formal request to the appraiser (through your lender) to review their opinion of value in light of new information or identified errors. Under Fannie Mae and FHA guidelines, lenders must have a process for accepting and forwarding ROV requests. Your lender submits the ROV to the appraiser through the Appraisal Management Company (AMC) — you cannot contact the appraiser directly. Include in your ROV: (1) A written explanation of each specific error or omission; (2) Supporting documentation (MLS data, permit records, photos of improvements); (3) Better comparable sales — include at least 3 comps with full address, sale date, price, size, and condition that support a higher value.
- 3 Research and submit better comparable sales
Comparable sales are the most powerful ROV evidence. A comparable sale must be: (1) Similar in size (within ±20% of GLA is common practice); (2) Similar location (same neighborhood or market area); (3) Recent (within 6–12 months preferred; within 90 days is strongest); (4) Similar condition, style, and features; (5) Arms-length transaction (not a foreclosure, auction, or related-party sale). Find comps through your real estate agent's MLS access, Zillow, Redfin, or county recorder records. For each comp, note: why it is more comparable than the comps the appraiser used, and what adjustment logic supports a higher value.
- 4 Understand what appraisers can and cannot change
After receiving the ROV, the appraiser must review it and respond. The appraiser's obligation: (1) Consider new information and correct factual errors; (2) Review alternative comps and provide a written explanation if they decline to use them; (3) Update the report if errors materially affected value. The appraiser is not obligated to change the value — they may respond that the submitted comps are less comparable than the ones selected. Appraisers are prohibited from being pressured to hit a target value — the ROV process is about correcting errors, not bullying the appraiser. USPAP (Uniform Standards of Professional Appraisal Practice) governs appraiser conduct. See <a href="https://www.appraisalfoundation.org/imis/USPAP" target="_blank" rel="noopener noreferrer">The Appraisal Foundation — USPAP standards</a>.
- 5 Escalate to a second appraisal or lender change if the ROV is denied
If the ROV does not result in an upward revision: (1) Request a second appraisal from a different appraiser through your lender — most lenders will allow this for an additional fee ($400–$700); the lender will use the lower of the two values for underwriting purposes unless there are clear errors; (2) Consider switching lenders — a different lender orders a new appraisal from their own AMC, which may result in a different appraiser and a fresh independent assessment; (3) Renegotiate the purchase price with the seller based on the appraisal result — the seller may accept a lower price rather than lose the deal; (4) Exercise the appraisal contingency to cancel the contract and receive your earnest money back. Review all options in the <a href="/guides/how-to-handle-a-low-appraisal" target="_blank" rel="noopener noreferrer">low appraisal guide</a>.
- 6 File a complaint for appraiser misconduct if warranted
If you believe the appraisal reflects discriminatory valuation, gross negligence, or a violation of USPAP standards, you can file a complaint with your state's appraisal regulatory board. Every state has an appraisal regulatory authority that licenses appraisers and investigates complaints. The complaint process: (1) Obtain the appraiser's license number from the appraisal report; (2) File a written complaint with your state board (list is maintained by The Appraisal Foundation at appraisalfoundation.org); (3) The board investigates and may discipline, suspend, or revoke the appraiser's license. Separately, if you believe the low value reflects racial or ethnic bias, file a fair housing complaint with HUD at <a href="https://www.hud.gov/fairhousing/complaint" target="_blank" rel="noopener noreferrer">HUD.gov/fairhousing/complaint</a>.
External references
- FHFA — Reconsideration of Value policy guidance
- CFPB — What is a home appraisal?
- The Appraisal Foundation — USPAP standards
- HUD — File a fair housing complaint
Common questions
What is a Reconsideration of Value (ROV) and do I have the right to request one?
A Reconsideration of Value (ROV) is a formal process in which a borrower asks the lender to send additional information to the appraiser for review — specifically, evidence of factual errors or better comparable sales that may warrant a higher value conclusion. Under Fannie Mae Selling Guide B4-1.3-12 and FHA guidelines, lenders must have a written ROV policy and process. As of 2024–2025, FHFA also issued updated ROV guidance requiring lenders to have accessible, standardized ROV processes and to share the outcome with borrowers. You do not have an absolute right to a value change — but you have the right to have your evidence considered by the appraiser. See the FHFA ROV policy guidance.
How long does the ROV process take?
The ROV process typically takes 5–10 business days from submission to appraiser response: (1) Your lender reviews the ROV request (1–2 business days); (2) The lender forwards it to the Appraisal Management Company (AMC) (1 business day); (3) The AMC sends it to the original appraiser (1 business day); (4) The appraiser reviews and responds (3–5 business days); (5) The AMC and lender review the appraiser's response and notify you. If your purchase contract has an appraisal contingency, make sure the ROV timeline fits within your contingency period — otherwise you may need to request a contract extension from the seller while the ROV is pending. The CFPB closing process guide explains appraisal contingency timelines.
Can I pick my own appraiser for a second opinion?
No — for a federally backed mortgage (conventional/Fannie/Freddie, FHA, VA), you cannot use an appraiser you hired independently. The lender must order the appraisal through an approved AMC to ensure independence. If you pay for an independent appraisal yourself, the lender is not required to use or consider it. However: (1) You can ask your lender to order a second appraisal from their own AMC — this is at the lender's discretion and usually requires additional payment; (2) For jumbo or portfolio loans, some lenders have more flexibility; (3) You can share your independent appraisal data with the lender as supporting evidence in the ROV, even if the lender won't officially use it for underwriting. The goal of lender-ordered appraisals is independence — see CFPB appraisal basics.
What evidence is most persuasive in an appraisal ROV?
In order of persuasiveness: (1) Factual corrections — documented errors (wrong square footage confirmed by permit records or prior appraisal; uncredited bathroom, bedroom, or garage) are the strongest ground because they are objective; (2) Superior comparable sales — MLS records of recent, similar, arm's-length sales in the same neighborhood that the appraiser did not use, with a clear explanation of why they are more comparable; (3) Adjustment errors — demonstrating that the appraiser under-adjusted for a feature your property has (e.g., a renovated kitchen vs original) using market-supported adjustment data; (4) Distressed comp disqualification — evidence that a comp used was a foreclosure, short sale, or estate sale that should not be treated as a market sale. Avoid emotional arguments ("we paid more" or "we love this house") — appraisers are data-driven. See the appraisal glossary entry.
Does the ROV process differ for FHA vs conventional loans?
Yes — there are important differences: Conventional (Fannie/Freddie): Fannie Mae's 2024 ROV guidance requires lenders to have a formal ROV process accessible at application. Borrowers may submit ROV requests including alternative comps and factual corrections. The appraiser's response is documented. FHA: FHA has a similar ROV process but also maintains an appraisal log — if a property receives a low appraisal from one FHA appraiser, a different FHA lender ordering a new appraisal on the same property within 180 days must use the original appraiser's value unless there is a valid reason not to. This "appraisal portability" rule can limit the benefit of switching FHA lenders. VA: VA uses its own Tidewater Initiative — if an appraiser believes the sales price may exceed market value, they can request additional comps from the lender before finalizing the value. See VA appraisal process.
Can a low appraisal lead to fair housing or discrimination complaints?
Yes — appraisal bias against properties in communities of color has been documented in academic research and HUD investigations. If you believe your property received a lower value because of the racial composition of your neighborhood or the race of the occupants (rather than objective market data), you can: (1) File a fair housing complaint with HUD (free, no attorney required) at HUD.gov/fairhousing/complaint; (2) File a complaint with your state's appraisal board for USPAP violations; (3) Consult a fair housing attorney. The Biden and Biden-era PAVE (Property Appraisal and Valuation Equity) Action Plan introduced government-wide actions to address appraisal bias — check pave.hud.gov for current status of these initiatives.
See all options in the low appraisal guide, understand the appraisal process, or model your purchase on the mortgage calculator.