How to submit a Reconsideration of Value, Appraisal Appeal to a lender - Mary Cummins, Real Estate Appraiser Los Angeles, California

Mary Cummins, Real Estate Appraiser, Los Angeles, California, Reconsideration of Value ROV Appraisal Appeal, rebuttal, request for rebuttal

I've seen some recent posts about real estate agents offering to help people get their home appraisal value changed. 99.999% of these are scams. Anyone can submit a Reconsideration Of Value (ROV), Request for Rebuttal or Appraisal Appeal at no cost. This is how you do it.

If you think the value should be different, find one to three nearby homes which were recently sold (not just listed for sale) that are VERY similar to the subject which weren't used in the appraisal. These must be recorded sales within about 1/2 to 1 mile radius, last three months to six months max and +/- 15% difference in legal gross living area. They must have similar views, amenities, upgrades, condition, parking, bedroom/bathroom count...

They can't just be listed as sales on the MLS as many of those are fake. You need the deed record number and when it was recorded. You also need the "legal" gross living area. You can't include patios,  basements, garages, unpermitted addition...what is listed in the MLS. You need what is on the legal tax record for size. The reason is unpermitted additions could be ordered removed by Building and Safety.

Submit those sales to the lender along with a note stating why you feel they are better comparables than the ones used in the report. For instance, the subject has a new kitchen, bathroom, full ocean view and a pool while the comps used in the report do not or were not adjusted for the differences. 

The lender will give that to the Appraisal Management Company (AMC) who will give it to the appraiser to reconsider the value. The appraiser will include those comparables in an updated report if the AMC or appraiser believe they are more comparable to the subject. If they are not comparable, the appraiser will specifically state why they aren't comparable, i.e. comp more than two miles from subject, comp 30% larger than subject, comp has full view and pool while subject does not. 

The AMC will also review the ROV. If there is a legitimate discrepancy and the appraiser won't adjust, a new appraisal or a review appraisal may be ordered. 

You don't need a form but below are some forms people have used for the request. 

https://www.dartappraisal.com/wp-content/uploads/2019/11/Dart-Appraisal-Residential-Appraisal-Appeal-Form.pdf

https://www.accusured.com/images/Accusured%20Management%20Reconsideration%20of%20Value%20Form.pdf

https://www.375loan.com/Documents%20and%20Settings/31/Site%20Documents/Forms/ReconsiderationofValueRequestv-3.pdf

There are some agents out there illegally offering to increase the appraised value by sending a threatening letter to the appraiser. They are requesting 20% of the increase in the appraised value as their fee. This is illegal as it's based on value. It's also illegal as the agent isn't an appraiser, AMC  or the lender. Sending a meritless threatening legal letter is also illegal. Threatening an appraiser or trying to pressure one to increase the value for no legitimate reason is actually coercion, attempted bank fraud, violation of appraiser/appraisal independence and a violation of the Truth in Lending Act. Getting involved with an unethical agent like that will not get you the house. The seller will most likely just sell it to someone else. 

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Mary Cummins of Animal Advocates is a wildlife rehabilitator licensed by the California Department of Fish and Game and the USDA. Mary Cummins is also a licensed real estate appraiser in Los Angeles, California.

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