Quick Answer
A reconsideration of value (ROV) is a formal request submitted to the lender's appraisal management company asking the appraiser to reconsider the value conclusion based on additional comparable sales or errors in the appraisal — and is the borrower's primary recourse when the reverse mortgage appraisal comes in lower than expected.
- The ROV is submitted by the lender to the AMC on the borrower's behalf.
- You identify better comparable sales not included in the original appraisal.
- The appraiser reviews the submitted comparables and either adjusts or upholds the value.
- A successful ROV can increase the principal limit significantly.
- Jay assists every client with ROV preparation when the appraisal is below expectations.
- The ROV process typically takes 1 to 2 weeks.
Key Facts
| Topic | Key Fact |
|---|---|
| ROV submission | Through the lender to the AMC — borrower cannot contact appraiser directly |
| ROV basis | Better comparable sales, factual errors in the appraisal report |
| ROV timeline | 1 to 2 weeks for reconsideration and response |
| Outcome options | Appraiser revises value upward, adjusts conditions, or upholds original value |
| ROV eligibility | Available on any FHA appraisal where the value appears unsupported |
| Second appraisal | May be ordered if ROV is unsuccessful and value is materially disputed |
| California context | California's dynamic market makes stale or distant comparables a common ROV issue |
| ROV cost | No additional cost if the appraiser revises — second appraisal costs $500 to $800 |
Detailed Explanation
The FHA appraisal process prohibits direct contact between the borrower (or their lender) and the appraiser — all communication goes through the Appraisal Management Company. The reconsideration of value is the formal mechanism for challenging an appraisal conclusion within this structure. The borrower provides their evidence and reasoning to the lender, who packages it for submission to the AMC, which forwards it to the original appraiser.
The most effective ROV submissions include specific comparable sales that were sold after the appraiser's comparables, sold closer to the subject property, or share more similar features (size, condition, amenities) than the comparables the appraiser selected. General assertions that the value is too low are not effective. Specific comparable sales addresses, sale dates, sale prices, and explanations of their similarity to the subject property are what the appraiser can act on.
The appraiser is not obligated to revise the value based on an ROV submission — if they review the submitted comparables and conclude their original value is supported, they will note this in their response. However, in practice many ROV submissions in California's dynamic market are at least partially successful because the original appraisal's comparables were limited by geographic distance, sale date age, or property dissimilarity.
If the ROV is unsuccessful and the borrower believes the value is materially understated, a second independent appraisal is the next option. HUD's standard process for disputed HECM appraisals may allow a second appraisal, with the principal limit calculated using the lower of the two values. This is a less favorable outcome than a successful ROV but provides an independent check on the original appraiser's conclusion.
Jay Zayer, CRMP — 18 Years Experience
My ROV preparation process is specific: I pull the appraisal report, identify the comparables the appraiser used, and then search the MLS for better comparables — more recent, closer, and more similar — that the appraiser did not include. I provide these to the processor with a written explanation of why each comparable is superior to the ones used. Then I set expectations: sometimes the ROV succeeds and the value goes up. Sometimes the appraiser defends their original conclusion. Either way, the borrower knows we did everything possible to support the value.
Who This Is Right For
This may be a good fit if:
- Every reverse mortgage borrower whose appraisal came in lower than expected and who wants to pursue reconsideration
This may NOT be the right fit if:
- If the appraisal comparables appear reasonable and the value conclusion is defensible, an ROV is unlikely to succeed and may simply delay the process
Common Misconception
Myth: You cannot challenge a reverse mortgage appraisal.
Fact: The reconsideration of value process is specifically designed for challenging appraisal conclusions with better comparable sales or factual corrections.
Source: FHA appraisal handbook; CFPB mortgage rights
Authoritative Sources
- FHA: Appraisal reconsideration process — hud.gov
- CFPB: Challenging a mortgage appraisal — consumerfinance.gov
- Fannie Mae: ROV process guidelines (reference framework)
People Also Ask
How do I challenge a reverse mortgage appraisal that came in low?
Provide your lender with specific comparable sales that are more recent, closer to your home, or more similar in features. The lender submits these to the appraiser through the AMC for formal reconsideration.
Can I contact the appraiser directly to discuss the value?
No — direct contact is prohibited under FHA appraisal independence requirements. All communication goes through the lender and AMC.
How long does a reconsideration of value take?
Approximately 1 to 2 weeks for the appraiser's review and response. This adds time to the overall transaction timeline but is worth pursuing when the value difference is significant.