You can challenge a low appraisal on a Richmond-area purchase, but only through your lender, usually only once per appraisal, and only with specific evidence: sales the appraiser missed or facts the report got wrong. A disagreement about price is not enough, and the request has to be resolved before closing, so it competes with the clock in your contract.
This process is called a reconsideration of value, or ROV. Below is how it works step by step, what the federal agencies and the loan programs actually require, and how to keep it from wrecking your closing date. Mission Realty is a brokerage, not a lender, so we explain the process but do not quote rates or make credit decisions.
What a reconsideration of value is, in plain terms
An ROV is a request from the lender to the appraiser to take a second look at the report. In July 2024, five federal agencies, including the CFPB and the Federal Reserve Board, finalized interagency guidance on reconsiderations of value. It describes how lenders can let consumers submit information the appraiser may not have considered, or point out deficiencies in the report. The guidance offers examples rather than new rules, but the big loan programs have since written their own firm requirements.
Three points shape everything else:
- You file through the lender. The request goes from you to your loan officer, then to an underwriter or appraisal reviewer, then to the appraiser. Your agent does not send it to the appraiser directly.
- It is evidence-based. Fannie Mae says any request for a change in value must rest on material and substantive issues, not simply on the value failing to support the loan amount.
- It ends at closing. Both Fannie Mae and Freddie Mac say an ROV request is no longer allowed once the loan closes.
The ROV process, step by step
- Read the disclosure you receive with the appraisal. Fannie Mae’s Selling Guide section B4-1.3-12 requires lenders to give you a written description of the ROV process when they deliver the appraisal. It must say that only one borrower-initiated ROV is allowed per appraisal. That single shot is why the next steps matter.
- Find the specific problems. Go line by line through the report with your agent. Check the square footage, bedroom and bath count, lot size, garage, basement, condition rating and the comparable sales grid.
- Build the evidence package. Fannie Mae lists what the request must contain: your name, the property address, the effective date of the appraisal, the appraiser’s name, the date of the request, a description of the unsupported or inaccurate areas, up to five additional comparable sales with their data sources such as the MLS number, and an explanation of why the new data supports a different value.
- Submit it to your loan officer in writing. The lender must finish its own appraisal review first, then have an underwriter or other appraisal expert check that your request has enough detail before it goes to the appraiser. If something is unclear, the lender comes back to you for more.
- Wait for the revised report. Freddie Mac’s Seller/Servicer Guide section 5604.4 says the appraiser must deliver a revised report with commentary explaining the conclusion, even if nothing changes. The lender sets its own turn-time expectations, so ask for them on day one.
- Decide your next move. With the answer in hand, you and the seller work out price, cash or exit under your contract terms.
For FHA loans, HUD’s Mortgagee Letter 2024-07 (May 1, 2024) sets a parallel process: one borrower-initiated ROV per appraisal, up to five alternative comparable sales, a disclosure at application and again when the appraisal is delivered, written status updates, resolution before closing, and no ROV costs charged to the borrower.
Evidence that counts, and evidence that does not
Usually worth submitting:
- Closed sales the appraiser did not use that are closer in location, size, age or style, with MLS numbers and an explanation of why each is a better match.
- Factual errors: wrong gross living area, a missed bedroom or bath, a finished basement recorded as unfinished, the wrong lot size, a missing garage.
- Condition facts the appraiser could not see or got wrong, such as a roof or HVAC system replaced recently, backed by permits or invoices.
- Concerns that the valuation reflects discriminatory practices. Fannie Mae and Freddie Mac both list this as a basis for an ROV.
Usually not persuasive:
- The contract price itself, or the fact that several buyers offered more.
- Online automated estimates.
- Active or pending listings in place of closed sales, unless the appraiser’s grid has a clear gap they help explain.
- Asking the appraiser to “hit the number.” The interagency guidance points out that federal lending rules prohibit coercing or pressuring an appraiser.
Comparable sales need to be truly comparable. A renovated row house in the Fan is not a fair match for a dated one two blocks over, and a sale in Short Pump does not help a home in Midlothian. Your agent can pull closed sales from the MLS and from our recently sold properties, but the case works best when each comp comes with a short, factual reason it belongs.
Keep the ROV from costing you your closing date
Our Richmond closing-timeline checklist lines up your appraisal deadline, ROV turn time and loan commitment date in one place, so you know which date gives out first.
Realistic outcomes
An ROV is not a guaranteed raise. The appraiser reviews your data and writes back. Three results are common:
- Value unchanged. The revised report explains why your comps or corrections did not move the number. This is a frequent result when the original comps were sound.
- Value increased. Most likely when there was a clear factual error, such as missing square footage, or a much better comp the appraiser did not have.
- Further review. If the lender finds the report deficient and the appraiser does not fix it, Fannie Mae allows a desk review, field review or new appraisal. The lender must pick the most reliable appraisal, not the highest one.
If the value does not move enough, you are back to the standard choices: renegotiate with the seller, bring cash to cover the gap, use any appraisal gap coverage you offered, or exit if your contract allows it. Our guide to what happens when a home appraises below the offer price walks through each one.
Timing an ROV against your contract deadlines
Most Richmond-area purchase contracts tie the appraisal to a deadline, through an appraisal contingency, a financing contingency, or both. The exact wording varies by form and by what you negotiated. Read yours with your agent the day the appraisal arrives. Questions to answer right away:
- What date does your appraisal or financing contingency end, and what notice must you give before it does?
- What turn time does your lender expect for the ROV?
- If the ROV answer will arrive after your deadline, will the seller sign a written extension?
- Does your rate lock expire before the new closing date? See how rate lock extensions work.
Do not assume filing an ROV pauses your contract clock. In most contracts it does not. An extension has to be agreed in writing. This is also where underwriting conditions after contract can stack up, so keep your document responses fast while the ROV is pending.
What sellers can do on their side
Sellers do not file the ROV, but they can help the buyer’s case. A list of upgrades with dates and costs, permits, and a survey or floor plan gives the buyer’s lender real facts to send. Our guide to getting a Richmond home ready for the buyer’s appraisal covers what to hand over before the appraiser arrives, which can prevent the low value in the first place.
Where an appraisal is not ordered at all
Some conventional purchases close with no appraisal, using Fannie Mae value acceptance or Freddie Mac’s automated collateral evaluation. With no appraisal there is nothing to reconsider. Our companion guide explains appraisal waivers and what you give up when a lender skips the appraisal.
Buying in the City of Richmond, Henrico County or Chesterfield County and want an agent who builds this evidence file with you? Learn how we work with buyers, or browse homes for sale now.
Questions buyers ask about challenging an appraisal
Can my real estate agent call the appraiser to dispute the value?
Not to argue the number. The ROV goes through your lender, and federal rules bar pressuring an appraiser. Your agent’s job is to find comparable sales and errors and help you put them in writing for the loan officer.
How many times can I request a reconsideration of value?
For loans sold to Fannie Mae or Freddie Mac and for FHA loans, the rules allow one borrower-initiated ROV per appraisal. Put your strongest evidence in that one request rather than sending pieces over several days.
How many comparable sales can I submit?
Fannie Mae, Freddie Mac and HUD each cap alternative comparables at five. Fewer, better-matched sales with clear reasons usually beat a long list.
Do I pay a fee for an ROV?
For FHA loans, HUD Mortgagee Letter 2024-07 says no ROV costs may be charged to the borrower. For other loans, ask your lender in writing before you file. A new appraisal, if one is ordered, is a separate question.
Can I request an ROV after closing?
No. Fannie Mae and Freddie Mac both say an ROV request is not allowed once the loan has closed. If you plan to challenge, do it while the contract is still open.
What if the appraiser fixes a mistake but the value barely moves?
That is a real possibility. Correcting a bedroom count may change the value less than you expect if the comps already reflected it. Have your next step, such as a renegotiation proposal, ready before the answer arrives.
Can I just get a second appraisal from another lender?
Switching lenders can mean a new appraisal, but it also means a new application, new disclosures and new timing, which can collide with your contract dates. Weigh that with your agent and loan officer before you move.
Does a low appraisal mean I overpaid?
Not necessarily. It means the lender’s appraiser did not find enough sales support for the price on that date. Many buyers still close by negotiating or covering a gap. Talk it through with your agent and lender before you decide.
Get the Richmond closing-timeline checklist
Put your appraisal contingency, ROV turn time, rate lock and closing date on one page before the appraisal comes back. If the value comes in low, you will already know how many days you have.
