Atlantic Coast Mortgage, LLC (“ACM”) provides the Reconsideration of Value (“ROV”) Request Form below to borrowers who request that the appraiser reevaluate the analysis and conclusion provided in the appraisal report based on additional information.
Please be sure to fully read and understand the ROV Request form before submitting to ACM.
What is an Appraisal of your property?
An appraisal is a professional opinion of property value determined by a state licensed or certified real estate appraiser. The appraisal provides your lender an opinion of how much your property is worth in your market (fair market value). Lenders require an appraisal to confirm that the subject property offered as collateral for your mortgage loan has sufficient value to support the requested loan amount. Appraisers must follow systematic procedures as defined by the Uniform Standards of Professional Appraisal Practice (“USPAP”). These rules govern things like the selection of comparable properties, acceptable methods for making adjustments, along with standards for professionalism and ethics. The appraisal must effectively communicate the data and analysis required to support the opinion of value.
What is a Reconsideration of Value?
An ROV is a request made by the borrower for the appraiser to re-evaluate the analysis and conclusions of the initial appraisal report using additional information provided by the borrower that the borrower believes to be relevant to the appraiser’s value determination.
ACM requires the borrower to complete a ROV Request Form which includes the additional information, data, or comparable sales that the borrower believes will impact the appraised value conclusion.
Keep in mind, just because your appraised value came in lower than you expected, this does not necessarily mean your appraisal is flawed or that another appraisal would yield a higher appraised value. Appraisal reports capture the appraiser’s opinion of value in a snapshot in time, meaning an appraisal report performed even six months prior—or six months from now—may yield a different opinion of value.
If the appraiser does not adjust the value in response to a borrower’s ROV Request, this also doesn’t necessarily mean the appraiser is wrong; the appraiser is required to meet the standards provided under USPAP, which may limit their ability to consider certain facts or information you provide.
In all instances, if you believe your appraisal is inaccurate, incorrect, or deficient, we strongly encourage you to submit an ROV request to help us ensure that your appraisal report accurately reflects the value of the property. You may, but are not obligated to, consult with your Loan Originator or Real Estate Agent to assist in completing the ROV form and to ascertain other values and information on comparable properties. The ROV form requests you to include additional comparable sales and/or additional information that you believe impact the appraisal valuation. The ROV form permits you to request clarifications or corrections unrelated to the value concluded in the appraisal report (i.e. factual errors). Only one ROV request is permitted per appraisal and a borrower may submit no more than five (5) alternative comparable sales for consideration.
You will not incur any fees or costs in connection with a ROV request.
Concerns About Appraisal Bias or Discrimination
ACM takes its role in ensuring fair and responsible lending very seriously and does not tolerate bias or discrimination in any aspect of the loan origination process – including in the appraisal process. The Fair Housing Act prohibits any form of discrimination on the basis of the applicant’s race, color, national origin, religion, sex (including gender identity or sexual orientation), marital status, military status, or disability. In addition, the Equal Credit Opportunity Act further protects applicants on the basis of their age, or receipt of public assistance. Should you have any concerns that the value conclusion in your appraisal was in any way impacted by bias or discrimination, or concerns regarding the conduct of the appraiser, please include those details in the “Comment” field of the ROV form below.
How the ROV Process Works
- You may complete the ROV Request Form (the “Form”) below on your own or consult with your real estate agent or loan officer for their input as to which comparables or other relevant information may be beneficial to include with your request. Even if your real estate agent or loan officer does not believe that submitting a ROV Request will result in a change in the value conclusion, you are still entitled to do so.
- You may use the Form to indicate the purpose of the ROV:
- To correct factual errors in the report (e.g. report indicates your property has 3 bedrooms, but it actually has 4; the gross living area is understated; the age of the home is misstated).
- To request consideration of what you believe to be better comparable sales. (Note: comparable sales should share similar attributes, including home style, lot size, gross living area, room/bedroom/bathroom count, age, condition, and construction quality); and/or
- To report concerns of bias or discrimination in the appraisal process.
- You must complete, sign, and submit the form below to Atlantic Coast Mortgage, LLC. You have not made a ROV request until you have competed and submitted the Form to Atlantic Coast Mortgage, LLC.
- The completed Form will then be reviewed by ACM within two (2) business days Appraisal Desk to ensure it is completed correctly, provides sufficient information for the appraiser to consider, and the request does not violate Appraiser Independence Requirements. Upon review, you will be contacted if further information is required, or the request is unclear or otherwise deficient.
- Provided that the completed Form is acceptable, the Company’s Appraisal Desk will submit the ROV request to the appraiser.
- The appraiser will consider each element of the request and may agree or disagree that an adjustment or correction to the report is appropriate. The appraiser is an independent valuation professional who will determine whether or not the appraisal report warrants a change and cannot be directed by you or ACM in accordance with Appraisal Independence Requirements.
- Your loan officer will communicate the outcome of the ROV request to you which usually occurs within seven (7) business days of submission of the ROV request to the appraiser.
How to Complete the ROV Request Form
Please be as detailed as possible in providing information for the appraiser to consider. If you are working with a real estate agent, they may be able to provide you with comparable sales in the market. If this is a refinance transaction, you may use tools such as Redfin or Zillow to find recent sales activity in your area not exceeding 12 months prior to the effective date of the appraisal– but keep in mind, listings or contingent sales are not eligible for consideration. For factual errors, please provide which data points are inaccurate (number of bedrooms, number of bathrooms, GLA errors, age of home errors, presence or absence of a fireplace, parking garage, swimming pool, etc.).
General Guidance on Comparable Sales Selections
Comparable sales often play a significant role in determining the appraised value. The appraiser is responsible for determining which comparables are relevant for the appraisal report based upon a variety of factors. Here are a few general guidelines the appraiser must consider that should guide you in this Reconsideration of Value process:
- The comparable must be for a closed sale, meaning an appraiser cannot utilize a property listing or contingent sale as a comparable. The closed date of the comparable must be prior to the appraisal report completion date (effective date). The appraiser must utilize at least three (3) closed sales. You may submit no more than five (5).
- Comparables should represent recent sales in the market. Generally speaking, the comparable sale must have sold within the last 6 to 12 months. The most relevant comparable sales may not be the most recent. An appraiser may have to use a time adjustment depending on when the sale took place relative to changes to the market.
- Comparable sales should be proximate to the subject property and ideally located in the same geographic neighborhood. For instance, if the property is located in a sub-division, the best comparables are the recent sales of similar homes in the same subdivision. If proximate comparables are not available due to a shortage of truly comparable sales, the appraiser may select comparables from competitive neighborhoods provided that the appraiser provides an analysis and commentary on why comparable sales in a competitive neighborhood were most appropriate.
- Comparable sales should have similar physical characteristics (e.g., similar room count, gross living area (GLA), style (e.g. ranch, split level), and condition). This does not mean the comparable must be identical to the subject property, rather it should appeal to the same market participants who would also consider purchasing the subject property. The appraiser may make adjustments for dissimilar characteristics such as GLA, room or bathroom count, condition, etc.
Appraiser Independence Requirements
The Appraiser Independence Requirements prohibit anyone from influencing or trying to influence an appraiser’s value conclusion through coercion, collusion, compensation or intimidation. To avoid any appearance of influence please:
- Do not give your value conclusion or mention the final market value or range of values you desire.
- Please do not provide a prior appraisal report; however, you may include comparables from that report should they still be timely.
- Please be respectful in providing your narrative about your concerns with the appraisal.
- We may ask you to resubmit the ROV Request Form if these guidelines are not followed.