Charging Veteran for second appraisal

Charging Veteran for second appraisal

Charging Veteran for Second Appraisal: What VA Guidelines Allow

Charging Veteran for second appraisal is strictly regulated under VA loan guidelines to protect borrowers from unnecessary costs. In most cases, Veterans are not permitted to pay for an additional appraisal unless specific VA-approved circumstances apply. Understanding when a second appraisal is allowed—and who is responsible for the cost—helps ensure compliance, prevents improper fees, and keeps the VA loan process fair and transparent.

The Department of Veterans Affairs (VA) maintains strict regulations regarding the fees and charges that a Veteran-borrower can pay during the home loan process. These rules are designed to ensure that the VA home loan benefit remains accessible and that Veterans are protected from unnecessary financial burdens. While the Veteran is generally responsible for the initial appraisal fee, charging a Veteran for a second or additional appraisal is only permitted under very specific circumstances.

Reconsideration of Value (ROV) Protocols

One of the most common reasons a second appraisal might be discussed is a Reconsideration of Value. If the initial appraisal results in a value lower than the sales price, several parties may seek a new assessment. The VA defines specific rules for who bears the cost:

  • Veteran-Initiated Requests: The Veteran can pay for a second appraisal if they are the party requesting the reconsideration of value.
  • Lender or Seller Requests: The Veteran cannot be charged for an appraisal or second assessment if it is requested by the lender or the seller for reconsideration purposes.
  • Third-Party Requests: Veterans are also protected from paying for appraisals requested by any other parties to the transaction besides themselves or the lender.
initial appraisal

Contractual and Title-Related "New Assignments"

Under certain conditions, a change in the transaction’s status may lead an appraiser to deem further work a “new assignment” under the Uniform Standards of Professional Appraisal Practice (USPAP).

In these instances, the Veteran may face additional costs:

  • Amended Sales Contracts: If a sales contract is amended after the effective date of the initial appraisal, the lender must determine if the changes affect the value. If the appraiser determines the extent of the change constitutes a new assignment, they may charge an additional fee to the Veteran, which can range up to the full amount of a new appraisal.
  • Title Limitations: If a title limitation or condition is discovered after the effective date of the appraisal, the appraiser may consider the necessary review to be a new assignment, and an additional fee may be charged to the Veteran.

Prohibitions and Lender Liability

The VA explicitly prohibits certain practices to prevent Veterans from being double-charged or penalized for administrative errors:

  • Duplicate Requests: Once an appraisal is requested, no duplicate requests are authorized. If a lender accidentally orders multiple appraisals for the same Veteran and property, the lender is responsible for all duplicate fees, and the Veteran cannot be charged for the error.
  • Successive Purchasers: If a Veteran applies for a loan on a property where an appraisal was already completed and paid for by a previous prospective purchaser (and the Notice of Value is still valid), the lender may not charge the second purchaser an appraisal fee if no new appraisal is ordered.
  • Validity Period: No duplicate appraisals may be requested for the same Veteran and property during the six-month validity period of an existing Notice of Value (NOV).

Administrative and Disaster-Related Scenarios

Other situational rules apply to cancellations and unforeseen events:

  • Cancellations: If an appraisal request is canceled after work has begun but before completion, the appraiser may charge a fee for the work performed, which is chargeable to the Veteran.
  • Natural Disasters: If a natural disaster occurs before the loan closes and there is an indication that property value has declined, a new appraisal must be performed. In this case, the payment for the appraiser’s fee is considered a contractual matter to be negotiated between the buyer and the seller.
loan process
effective date

Fee Collection Compliance

It is critical to note that appraisers are not authorized to collect appraisal fees directly from Veterans. All fees must be paid by the requester (the lender or servicer) who placed the order. Furthermore, regardless of whether it is a first or second appraisal, the appraiser must not charge a Veteran more than they charge other clients for similar services in that vicinity. These safeguards ensure the integrity of the VA’s fee panel and protect the Veteran from predatory billing practices.

FAQ's

An appraisal request can be canceled before completion if the lender determines the borrower will not qualify or if other valid reasons arise. In such cases, the appraiser must be notified immediately. If the appraiser has already begun work on the assignment, they are permitted to charge a fee for the work performed prior to the notification. This partial fee is chargeable to the Veteran. To finalize the cancellation, the lender must email the Regional Loan Center with the case details and a confirmation that the earned portion of the appraisal fee will be paid.

Generally, once a Notice of Value (NOV) has been issued, it remains valid for six months. During this validity period, no duplicate appraisals may be requested for the same Veteran on the same property. This restriction ensures the integrity of the original valuation and prevents “appraisal shopping.” If a Veteran decides to change lenders during this period, the original lender is expected to transfer the case to the new lender upon written request. The new lender’s Staff Appraisal Reviewer (SAR) must then review the existing appraisal and issue a new NOV to the Veteran.

Under no circumstances are appraisers authorized to collect appraisal fees directly from Veterans. All appraisal fees, whether for an initial assessment or a justified second appraisal, must be paid by the requester who placed the order through the VA’s web-based systems. This safeguard prevents potential predatory practices and ensures that all fees are properly documented in the loan’s closing disclosure. Additionally, the maximum fees allowed by the VA are based on customary charges for similar services in the vicinity, and appraisers must not charge Veterans more than they charge other clients for similar work.

If a property is appraised but a natural disaster occurs before the loan closes, and there is evidence that the property value may have declined despite repairs, a new appraisal must be performed. In this specific circumstance, the Department of Veterans Affairs does not mandate who pays the fee. Instead, the payment for the appraiser’s fee for this second assessment is considered a contractual matter to be negotiated between the buyer and the seller. The lender must ensure the property has been restored to its pre-disaster condition or better before the loan can be guaranteed.

If a title limitation or condition is discovered prior to the loan closing that was not considered in the original appraisal, the lender must contact the appraiser to see if the property remains eligible security for a VA loan. If this condition is identified after the effective date of the initial appraisal, the appraiser may consider the necessary evaluation to be a new assignment. Consequently, an additional fee may be charged to the Veteran for this service. This ensures the appraiser is compensated for the additional work required to determine the impact of the newly found limitation on the property’s value.

If a sales contract is amended after the effective date of the initial appraisal but before the loan closes, the lender must determine if the changes affect the property’s value. If the changes are significant, the lender must forward the amended contract to the appraiser. Depending on the extent of these changes, the appraiser may deem the review a “new assignment” under Uniform Standards of Professional Appraisal Practice (USPAP) guidelines. In this specific scenario, the appraiser is entitled to an additional fee, which is chargeable to the Veteran, ranging up to the full cost of a new appraisal.

No. Once an initial appraisal has been requested, the VA does not authorize duplicate requests for the same transaction. If a lender inadvertently requests more than one appraisal for the same Veteran on the same property, the lender is required to immediately cancel the redundant order. If the lender fails to cancel the duplicate and multiple appraisals are completed, the lender is held responsible for the fees of all duplicate appraisals. The Veteran cannot be charged for these administrative errors, and the final NOV will be based on the first appraisal requested.

In cases where an appraisal was already completed and paid for by a previous prospective purchaser, but the sale was not completed, a second purchaser may apply for a loan on the same property. If the existing Notice of Value (NOV) is still within its validity period and the lender elects to use it, the lender may not charge the second purchaser an appraisal fee. This rule prevents redundant charges for a single valuation service. However, no duplicate appraisals may be requested for the same Veteran and property during the six-month validity period of an existing NOV.

The Veteran-borrower is strictly protected from being charged for any appraisal or second assessment if the request originates from the lender or the seller for the purposes of a reconsideration of value. In these instances, the financial responsibility for the additional appraisal must be borne by the requesting party, not the Veteran. This regulation ensures that the Veteran is not penalized financially for a valuation dispute they did not initiate. Furthermore, appraisers are not authorized to collect any appraisal fees directly from Veterans; all payments must be processed through the party that placed the order.

Yes, a Veteran-borrower is permitted to pay for a second appraisal if they are the party specifically requesting a Reconsideration of Value (ROV). This situation typically arises when the initial appraisal results in a “reasonable value” lower than the contract sales price. While the Veteran provides the written request for reconsideration to the Regional Loan Center (RLC), they may also elect to fund a new assessment to provide updated market data. It is important to note that Veterans are also protected from paying for appraisals requested by any parties to the transaction other than themselves or the lender.

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