Reconsideration of value process

Reconsideration of value process

Reconsideration of Value Process: Challenging a VA Appraisal

The reconsideration of value process allows borrowers, lenders, or real estate agents to request a review of a VA appraisal when there is evidence the appraised value may be inaccurate. By submitting additional comparable sales or relevant market data, this process provides a structured way to address valuation concerns without ordering a new appraisal. Understanding how the reconsideration process works can help resolve appraisal issues, support fair property values, and keep VA loan transactions on track.

The Department of Veterans Affairs (VA) provides a formal Reconsideration of Value (ROV) process to address instances where the appraised “reasonable value” of a property—as established in a Notice of Value (NOV)—is lower than the contract sales price. This process ensures that the property’s valuation is accurate and supported by the most current and relevant market data, protecting the interests of the Veteran, the lender, and the government.

Pre-NOV Protocol: The Tidewater Procedure

Before a formal ROV is initiated, the VA employs a preliminary mechanism known as the Tidewater Procedure. This occurs during the appraisal process if the fee appraiser determines that the estimated market value will likely fall below the sales price. The appraiser is required to notify the lender, who then has two business days to submit additional sales data to be considered before the appraisal report is finalized. This data typically includes comparable sales with information on street addresses, sales prices, dates of sale, and gross living area (GLA). The appraiser must note in the final report that this procedure was followed and explain whether the data influenced the final opinion of value.

Initiating a Formal Reconsideration of Value

Initiating a Formal Reconsideration of Value

If the NOV is issued and the value is still deemed insufficient, a formal ROV may be requested. The Veteran must submit a written request for reconsideration to the Regional Loan Center (RLC) of jurisdiction. While interested parties like lenders or realtors may facilitate the request, the primary right to appeal rests with the Veteran.

When the request is submitted through the lender, the Staff Appraisal Reviewer (SAR) is encouraged to research market data and provide a formal recommendation to the RLC alongside the Veteran’s written request. Although providing a specific market data grid is not mandatory for the request, submitting comparable sales data that supports a higher value is highly encouraged to aid VA staff in their review.

VA Review and Timeliness Standards

Once a formal ROV request is received, authorized VA staff perform an administrative review of the appraisal report and the newly submitted data. This review also incorporates data available through the VA’s Appraisal Management System (AMS).
The VA adheres to the following processing timelines for ROVs:

  • Desk Review: VA staff aim to complete the review of the appraisal and additional data within five business days.
  • Field Review: In more complex cases where staff determine that a physical inspection of the property or comparables is necessary, a field review will be completed within 20 business days.

If the review determines that an increase in value is appropriate based on the evidence provided, the VA will issue an amended NOV reflecting the new reasonable value.

Financial Responsibility for Additional Appraisals

In some instances, a second appraisal may be deemed necessary to resolve the valuation dispute. The VA has strict rules regarding who bears the cost of this service. The Veteran can pay for a second appraisal only if they are the party specifically requesting the reconsideration of value. Conversely, the Veteran cannot be charged for an appraisal or second assessment if it is requested by the lender or the seller. Furthermore, appraisers are not authorized to collect these fees directly from Veterans; all fees must be paid by the requester who placed the order.

Financial Responsibility for Additional Appraisals

The ROV process is a vital safety net in the VA Home Loan program, ensuring that Veterans have a clear path to appeal valuations that may not fully reflect market conditions. By combining the Tidewater Procedure for immediate data sharing with a formal RLC-led appeal process, the VA maintains a rigorous standard for establishing reasonable market value while providing flexibility for unique market circumstances.

FAQ's

If VA staff completes a review of the appraisal and the newly submitted market data and determines an increase is appropriate, they will issue an amended NOV. This amended document becomes the official record of the property’s reasonable value for the loan transaction. Lenders and servicers must then refer to this amended NOV, rather than the original appraisal, for all related loan conditions and requirements. This ensures the Veteran’s loan is guaranteed based on the most accurate and supportable market data available to the Department of Veterans Affairs.

Yes, because VA appraisals are often prepared “subject to” the completion of repairs needed to meet Minimum Property Requirements (MPRs). The estimate of reasonable value includes the contributory value of these completed repairs. If a Veteran requests a waiver of MPR repairs after the NOV is issued, VA staff may approve the waiver but might also reduce the value on an amended NOV to reflect the “as-is” condition. Therefore, the property’s condition and any required remediation are integral factors that VA staff consider when reviewing any reconsideration of value request.

If a Veteran decides to change lenders during the process, the original lender is required to transfer the case to the new lender in WebLGY. However, a Notice of Value issued by a previous lender’s SAR is not transferable. The new lender’s SAR must conduct their own review of the appraisal and issue a new NOV to the Veteran. If the new lender does not have LAPP authority, the request must be sent to the RLC for VA staff to issue the NOV, which may then trigger a new opportunity for reconsideration.

Yes, real estate agents and other interested parties are encouraged to participate in the data-sharing process. During the Tidewater Procedure, the lender may contact any party to the transaction to gather additional sales data for the appraiser’s consideration. This collaborative approach allows agents to provide their professional insight into the local market through the submission of comparable sales. While the agent can provide the data, the formal ROV request post-NOV issuance is a right that primarily rests with the Veteran and is submitted to the Regional Loan Center.

The SAR performs a due diligence function by reviewing the appraisal for completeness, consistency, and accuracy before issuing the initial NOV. When a reconsideration is requested, the SAR is encouraged to conduct additional market research to support the Veteran’s appeal. However, the SAR must not act as a cosigner of the report or exert undue influence on the appraiser to meet a specific sales price. If the SAR disagrees with the appraiser’s conclusions, they must provide a full explanation in the WebLGY notes associated with the loan file.

Under VA regulations, a Veteran may only be charged for a second appraisal if they are the party specifically requesting the reconsideration of value. Conversely, the Veteran cannot be charged for an appraisal or second assessment if it is requested by the lender or the seller for their own reconsideration purposes. Furthermore, the Veteran is protected from paying for appraisals requested by any other third parties involved in the transaction. It is important to note that appraisers are never authorized to collect these fees directly from the Veteran; payments must go through the requester.

The timeline for a Reconsideration of Value depends on the depth of the review required by VA staff. Once the RLC receives the request and supporting data, they perform an administrative review of the appraisal report. A standard desk review is typically completed within five business days. However, if the circumstances are complex and require a physical field review of the property or the comparables, the process may take up to 20 business days. If the review justifies an increase, VA will issue an amended Notice of Value reflecting the update.

When submitting sales data for a reconsideration, the information must be detailed enough for the appraiser or VA staff to analyze effectively. Each potential comparable sale must include the street address, sales price, and date of sale. Additionally, the gross living area (GLA) and a copy of the property listing with descriptive details should be provided. It is the responsibility of the requester to ensure this data is sufficient for the appraiser to determine if the sale truly serves as a valid comparable property. This rigorous documentation helps ensure the accuracy of the market value estimate.

A formal Reconsideration of Value (ROV) is requested after the Notice of Value (NOV) has been issued by the reviewer. The Veteran must submit a written request to the Regional Loan Center (RLC) of jurisdiction. While the request is often facilitated through the lender, the Staff Appraisal Reviewer (SAR) is encouraged to research market data and provide a formal recommendation to the RLC alongside the Veteran’s request. Submitting a specific market data grid is not mandatory for the Veteran, but providing comparable sales data is highly encouraged to aid the VA’s review.

The Tidewater Procedure is a preliminary step that occurs before an appraisal report is finalized when it appears the value will fall below the sales price. The fee appraiser is required to notify the lender, who then has two business days to submit additional market data. This data typically consists of comparable sales that may support a higher valuation. The appraiser must note in the final report that this procedure was followed and explain whether the new data influenced the final estimate of reasonable value. If no data is submitted, the appraiser completes the report as planned.

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