The Appraisal Blog

The CFPB is implementing procedures to allow borrowers to request a Reconsideration of Value (ROV) if they believe their appraisal is inaccurate.  I agree with the rational and intent behind the policy, however, I also believe this will open a can or worms creating excessive complaints and work with little to no gain for borrowers.  Appraisals are not conducted in a vacuum.  There is a layered review process in which multiple people must agree with the appraisal report before a loan is finalized.  For most conventional and FHA loans there is the Appraisal Management Company (AMC) who reviews the appraisal and submits questions/corrections,  Then the appraisal is given to the lender who also reviews the file and can also submit questions/reviews.  Typically somewhere in the process an AVM (automated valuation model) is run and compared to the appraisal.  So after all this ... the homeowner is going to have the ability to challenge the appraisal?  They will provide "comparable" sales that they want to be included in the report that just closed a little while ago.  Typically a little while ago to a borrower will have occurred 12+ months ago.  Or just down the street ... 3 miles away.

This is not good policy.  It will further erode public trust in appraisals and drive appraisers out of an already thinning workforce.


https://www.consumerfinance.gov/about-us/blog/mortgage-borrowers-can-challenge-inaccurate-appraisals-through-the-reconsideration-of-value-process/