An appraisal that comes in lower than expected can feel like the end of the road for a Minnesota home purchase or refinance. It does not have to be. If you believe the appraiser missed something, used the wrong comparable sales, or made a factual error, there is a formal way to ask for a second look, called a reconsideration of value, or ROV. The rules depend on the loan program, and they have changed in the last two years, so it helps to know what applies before you need it. This guide covers your right to see the appraisal, how the ROV process works for conventional loans backed by Fannie Mae, how FHA handles reconsiderations, and how to put together a request that has a fair chance of being considered.
What a reconsideration of value is
The Federal Housing Finance Agency describes a reconsideration of value as a request to an appraiser to re-assess the appraised value of a property due to potential appraisal reporting deficiencies, inappropriate selection of comparable properties, or additional information the appraiser should consider.
Notice who the request goes through. You do not contact the appraiser directly. Appraisals for mortgages are ordered by the lender, and appraiser independence rules govern who can communicate with the appraiser. An ROV request is submitted to the lender, which reviews it and decides whether and how to send it to the appraiser.
An ROV is not a way to argue for a number you would prefer. It is a way to point out specific, supportable problems or missing information in the report.
Your right to a copy of the appraisal
You cannot question an appraisal you have not seen. Federal law addresses this directly. Under Regulation B, section 1002.14, published by the Consumer Financial Protection Bureau, a creditor must give you a copy of all appraisals and other written valuations developed in connection with an application for a loan secured by a first lien on a dwelling.
The same section sets the timing. The creditor must provide each copy promptly upon completion, or three business days before consummation of the loan, whichever is earlier. You may waive that timing and agree to receive the copy at or before closing, but the regulation says any such waiver must be obtained at least three business days before consummation, with a narrow exception for copies that contain only clerical changes.
Section 1002.14 also requires the creditor to send you a written notice of your right to receive a copy of the appraisal no later than the third business day after it receives your application. And the regulation says the creditor may not charge you for providing the copy, although it may require a reasonable fee to cover the cost of the appraisal itself.
When the appraisal arrives, read it right away. The sooner you spot a concern, the more time there is to raise it.
How the ROV process works for Fannie Mae loans
Fannie Mae's Selling Guide, section B4-1.3-12, requires lenders to have policies and procedures in place for a borrower-initiated reconsideration of value on loans that require an appraisal. According to that section, the process must include steps for borrowers to appeal an appraisal when they believe the opinion of value is unsupported, may be deficient due to unacceptable appraisal practices, or reflects prohibited discriminatory practices.
Fannie Mae requires the lender to provide a disclosure outlining the ROV process when the appraisal report is provided to you. In September 2025, Fannie Mae's Selling Guide Announcement SEL-2025-07 removed an earlier requirement to also give that disclosure at loan application, so the disclosure that comes with the appraisal is the one to watch for.
Under section B4-1.3-12, a borrower-initiated ROV must include:
- the borrower names, property address, effective date of the appraisal, appraiser name, and date of the request;
- identification and description of the unsupported, inaccurate, or deficient areas in the appraisal report;
- additional data, information, or comparable properties, not to exceed five, with the related data sources, such as the MLS listing number; and
- an explanation of why the new data supports the ROV.
Fannie Mae also sets limits. The disclosure must make clear that only one borrower-initiated ROV is permitted per appraisal, and the Selling Guide notes that after a loan has closed, a borrower can no longer submit an ROV request.
What the lender does with your request
Section B4-1.3-12 says the lender must complete its own appraisal review before starting the ROV process, designate an underwriter or other appraisal expert to review the request, and confirm the request has enough detail before sending it to the appraiser. If the request is unclear or incomplete, the lender must obtain the needed information from you.
Fannie Mae's ROV FAQs add a few useful points. You may cancel a borrower-initiated ROV request. For each borrower-initiated ROV, the appraiser must update the report to correct any errors and comment on the changes, even if an error does not affect value. And if the ROV ends with no change in value, Fannie Mae says the borrower may not request a new appraisal, because the decision whether to accept the appraiser's conclusions belongs to the lender.
How FHA handles reconsiderations
FHA's rules took a different path. In 2024, HUD's Mortgagee Letter 2024-07 added a formal borrower-initiated ROV process for FHA loans. On March 19, 2025, HUD issued Mortgagee Letter 2025-08, which rescinded those changes and restored FHA's previous policy, effective immediately.
Under the restored language in HUD Handbook 4000.1, as quoted in Mortgagee Letter 2025-08, the underwriter may request a reconsideration of value when the appraiser did not consider information that was relevant on the effective date of the appraisal, and must give the appraiser all relevant data needed. The effective date is the date the appraiser inspected the property.
The same restored text addresses cost. The appraiser may charge an additional fee if the relevant data was not available on the effective date of the appraisal. If that unavailability is not the borrower's fault, HUD says the borrower must not be held responsible for the additional cost.
For FHA loans, then, there is no FHA-mandated borrower form. The practical path is to give your loan contact clear, specific information that the underwriter can evaluate and, if appropriate, send to the appraiser.
Building a strong request
Whichever program applies, a focused, well-documented request gives the reviewer something concrete to work with. Consider these steps:
- Read the full appraisal, including the comparable sales grid, the property description, and the appraiser's comments.
- Check the facts about your property, such as square footage, bedroom and bathroom counts, lot size, and listed features.
- Look for comparable sales the appraiser may have missed. They should be relevant as of the appraisal's effective date.
- Gather data sources for each comparable, such as MLS listing numbers.
- Write a short, factual explanation of why the information matters to the value conclusion.
- Keep the request respectful and specific, and avoid pressuring language about a target value.
If you are working with a real estate agent, they may be able to help identify relevant recent sales. In rural parts of central Minnesota, where truly similar properties can be spread out, explaining why a comparable is a good match, such as similar acreage, outbuildings, or well and septic setup, can make the information easier to evaluate.
If the value does not change
An ROV may or may not change the appraised value. If it does not, you still have choices to discuss with your agent and loan contact, such as renegotiating the price with the seller, adjusting your plans, or reviewing your purchase agreement for any appraisal-related terms. Fannie Mae's FAQs are clear that an unchanged ROV result does not entitle the borrower to a new appraisal, so knowing your options ahead of time can keep the timeline on track.
Timing matters, too. Fannie Mae's Selling Guide says a borrower can no longer submit an ROV after the loan has closed. Raising concerns as soon as you receive the appraisal gives everyone the most room to respond before your closing date.
Frequently asked questions
Can I contact the appraiser directly about a low value?
An ROV request goes through the lender. Under Fannie Mae's Selling Guide B4-1.3-12, the lender reviews the request and sends a standardized communication to the appraiser, consistent with appraiser independence requirements.
How many comparable sales can I submit?
For Fannie Mae loans, section B4-1.3-12 allows additional comparable properties not to exceed five, along with their data sources.
How many ROV requests can I make?
Fannie Mae permits only one borrower-initiated ROV per appraisal, and the lender's disclosure must make that clear.
Will I pay for the reconsideration?
For FHA loans, HUD's restored policy says the appraiser may charge an additional fee if relevant data was not available on the effective date, but the borrower must not be held responsible if that unavailability was not the borrower's fault. Ask your loan contact how fees would be handled on your loan.
Do I have to pay for a copy of my appraisal?
No. Regulation B section 1002.14 says the creditor may not charge you for providing the copy, though it may charge a reasonable fee for the cost of the appraisal itself.
Questions about your appraisal?
If your appraisal raised questions, Davis Monroe Financial LLC can walk through the report with you and explain how the reconsideration process works for your loan program. Call (320) 200-5126 or email support@mydmf.com, with no pressure and no obligation.