With rapid price growth and price bidding wars in hot real estate markets, an increase in appraisal appeal requests is likely. No matter how meticulous you are or how good your appraisal reports are, inevitably, you’ll receive complaints about some of your appraisals. To help you out, we’ve put together some practical information to strengthen your responses to a mortgage lender’s appraisal appeal, called a reconsideration of value (ROV).
While the ROV process is an appeal process, it is not to be used for changing the value or altering other assignment results simply because someone is dissatisfied with the outcome. Similar to performing an appraisal assignment, your role as an appraiser is to respond impartially, objectively, and without bias to an ROV request.
When you receive a reconsideration of value request, there are proven ways to handle these requests, adhere to USPAP and applicable regulatory requirements, and preserve a rock-solid relationship with your client. Best practice is to respond in a professional manner, remain positive, respond accurately and timely, and always operate ethically. Below are twelve tips for responding to an ROV request.
When you receive an ROV, the first thing you should do is to make sure that the request was forwarded by your client or parties designated by the client, such as an AMC or an agent of the client. USPAP prohibits an appraiser from discussing the results of an appraisal with anyone other than the client or parties designated by the client. Never respond to a complaint or an ROV that is forwarded to you directly by a real estate agent, the borrower, the seller, or any other party that is not the client or the client’s designated agent.
2. Pause before responding
As with any complaint or negative feedback, it is best to pause and not respond with your first reaction, which is likely to be a defensive and unprofessional response. Value reconsideration requests seem to surface at the most inconvenient times, typically when you are busy and stressed with other deadlines and commitments, so pausing before responding is highly recommended.
With that being said, it is good customer service to immediately acknowledge receipt and inform your client of an estimated time of when you’ll be able to respond to the ROV. For example, you might respond, “I’ve received your reconsideration of value request and will take a look at the concern cited and get back to you within one day.”
3. Meet deadlines, if attainable
Often, an ROV has a deadline for responding to it. If the ROV has a deadline that is unattainable, you should inform the client immediately. Perhaps you respond by saying, “I’ve received your reconsideration of value request, and unfortunately due to the amount of time involved to research and thoroughly complete this request, I’ll need two business days to respond.”
If possible, make an effort to meet the client’s requested deadline, as the client may be up against a hard deadline for loan approval. This is especially critical if you missed a deadline when you completed the original appraisal assignment. However, you must be honest with yourself with an attainable timeframe and not add unnecessary pressure to respond to the ROV, thereby completing it hastily and recklessly.
4. Take the ROV seriously
Some appraisers respond rudely, sarcastically, or jokingly to an ROV. Responding to a request to consider alternative sales with a curt reply (e.g., “Clearly, I used the best comparable sales available if these are the only sales you could locate to dispute my appraisal…” or “If these sales were better, I would have used them…”) is not helpful and tells the complainant that they are uninformed and that you don’t value their opinion.
5. Start with a positive
As inconvenient as it is to respond to a value reconsideration, you should start positively by recognizing and acknowledging the time and effort it took to file the complaint or by acknowledging the specific complaint cited. You may state something along the lines of:
- “I appreciate your having taken the time to voice your concerns about the appraisal completed for the property located at 123 Anywhere Street, Any State.”
- “I understand how disappointing it can be when the borrower’s expectations are not met, and below is my response to the value reconsideration request.”
- “I am responding to your concern that…”
As difficult as it may be, especially when you feel the complaint wasn’t justified, you should always respond in a sincere and respectful manner.
6. Assess the problem and research facts
Assess the problem and research facts related to the subject matter of the complaint, such as a review of the MLS listings of any sales forwarded for consideration. If the complaint is that your living area calculation is inaccurate, you should review your sketch and possibly compare it to other sources such as a public property record or a blueprint, if available. The scope of research required will vary depending on the particulars of the value reconsideration.
7. Respond to all points and sales forwarded for consideration
An appraisal appeal may bring up multiple concerns. Be sure to respond to each and every one. If the ROV forwards three sales to consider as comparable sales, provide a specific reason(s) for why each one is not considered comparable to the subject. To simply state that the sales forwarded are “dissimilar” or are “superior” to the subject property is an inadequate response.
For example, if the ROV includes a sale that is dissimilar in age and type, you may state, “The property located at 444 Mulberry was not considered comparable because it is 20 years younger than the subject and is a detached single family home while the subject property is an attached townhouse.”
8. Rectify an error
Avoid taking an explicit position that everything was accurately done and the best sales were used in the appraisal. It is always possible that a real estate agent did not correctly enter an MLS listing such as the geocode or the name of the subdivision and subsequently the sale did not populate during your search for comparable properties. If a sale has been forwarded that is comparable, it should be added to the grid to determine if it results in a different outcome.
Likewise, if you made a negative instead of a positive adjustment, made a mathematical error, or were not aware of the specifics about a comparable that you used, you should acknowledge it and remedy the error or omission whether it impacts the valuation outcome or not.
If the error does impact on your opinion of value, acknowledge and revise your appraisal accordingly, as you want your appraisal to be credible. Remember to update your report date and note any changes and the reasons for it in your appraisal report.
9. Use understandable language
There are appraisal terms and concepts that even individuals in the lending industry sometimes have a difficult time understanding. For example, some lending professionals do not understand why a property must be appraised to its “highest and best use” when appraising a property’s market value for lending purposes. If possible, your response should be detailed, but use simple language. In instances where it’s impossible to avoid appraisal jargon, try to put layman’s terms in parentheses to enhance clarity.
10. Do not strike back
The complaints cited in the ROV may be full of anger and unprofessional comments about your appraisal abilities. Don’t take it personally, and whatever you do, do not strike back. While it may be difficult, remain calm and respond systematically and logically to the complaint. Be respectful and constructive in your response.
11. Ask questions
If the complaint is too difficult to follow, reach out to the client/AMC and ask questions for clarity. It is best to ask open-ended questions in a neutral and non-accusatory manner. Make it clear that you are simply seeking to gain clarification so you better understand the complaint before responding to it. You might say, “I think I need more information because I don’t fully understand the part about …”
12. Include it in your appraisal
If the appraisal needs to be revised, such as including information forwarded to you as part of the ROV or correcting an error, you’ll need to summarize the change(s) in the appraisal report and update the date of the report to comply with USPAP. Even if you are not changing the appraisal report, it is strongly recommended that you include an outline of the complaint and a summary of your response, including the decision reached and the reasons for it, and add it to your appraisal report and update the report’s date. At a minimum, the ROV and your written response should be saved in your workfile if the appraisal is not modified at all.
In the end, if the information provided justifies a reconsideration of value, then revise the appraisal report accordingly. However, never change your report simply because you felt pressured by the AMC, the lender, or any of the parties involved with the transaction.