How to Dispute an Appraisal: Valid Grounds, Evidence, and Steps

To dispute a home appraisal, you submit a reconsideration of value (ROV) request to your lender, backed by concrete evidence that the appraiser made a factual mistake about your property or overlooked better comparable sales. In 2024, federal banking regulators issued joint guidance formalizing how lenders should handle these requests, giving borrowers a clearer path when they believe a report contains errors or omissions.¹ Disagreeing with the number is not enough. What works is documented proof of something the appraiser got wrong.

Get Your Appraisal Report First

You cannot dispute what you have not read. Federal law requires your lender to provide a free copy of every appraisal developed for your loan application, delivered promptly after completion or at least three business days before closing, whichever comes first.² If it hasn’t arrived, ask your loan officer. You’re entitled to the copy whether the loan is approved, denied, or withdrawn.

Read it carefully. Focus on the physical description of the property, the comparable sales the appraiser chose, and the adjustments made between those comps and your home. Most successful disputes start with a specific error someone caught on a close read.

What Counts as a Valid Ground for Dispute

Not every low appraisal contains an error. Sometimes the market simply doesn’t support the price you agreed to pay. But appraisers make documentable mistakes regularly, and the strongest ROV requests fall into two categories: factual errors about the property, and problems with the comparable sales.

Factual Errors About the Property

The most straightforward disputes involve basic facts. Miscounted bedrooms or bathrooms. Wrong square footage. A finished basement or garage that went unrecorded. A new roof, HVAC replacement, or kitchen renovation that isn’t reflected in the condition rating. An appraiser who walked through after a $25,000 kitchen remodel but rated the kitchen as “average” made an error you can document with receipts and photos.

Lot facts count too. If the report says your property backs up to a highway when it actually backs up to a park, or the lot size is wrong, that’s grounds for a request. Any physical characteristic that affects value and was recorded incorrectly is fair game.

Problems With Comparable Sales

The appraiser’s choice of comps drives the final number more than almost anything else. If the report leans on sales that were too far away, too different in size, or in visibly worse condition than your home, while ignoring closer and more similar properties that sold for more, that’s a legitimate basis for dispute. This is where most ROV requests focus, and where the strongest ones succeed.

Fannie Mae’s guidelines call for comparable sales that closed within the last 12 months, with more recent sales generally carrying more weight.³ Proximity matters. Comps from the same neighborhood or subdivision are almost always stronger than ones from across town, even when the distant property looks similar on paper. Search public property records and real estate databases for homes that match your property’s style, age, size, and features. Three or four strong comps the appraiser overlooked can make a compelling case.

Missing Time Adjustments

In a rising market, watch for stale comps used without adjustment. If the report leans on a sale from eight months ago and makes no upward adjustment for price appreciation since then, the resulting value will understate current conditions. Fannie Mae now treats the failure to make time adjustments, when market data clearly supports them, as an unacceptable appraisal practice. The appraiser must analyze market trends and explain whether a time adjustment was warranted, using home price indices, paired sales analysis, or similar methods.⁴ Federal Housing Finance Agency research has found appraisers routinely underuse time adjustments even in rapidly appreciating markets, which pulls values below where they should land.⁵

Build Your Evidence Package

Your lender may hand you a standardized ROV form, or you may need to submit a written request. Either way, include your loan number, the property address, the original appraised value, and a clear explanation of what you believe went wrong.

For each comparable sale you’re proposing, list the address, sale price, closing date, square footage, and a brief note on why it’s a better comp than what the appraiser used. If you’re flagging factual errors about your property, attach documentation. Receipts or permits for renovations. A floor plan showing the correct square footage. Photos of features the appraiser missed. A map showing the location of your proposed comps relative to the subject property can be especially effective when the appraiser reached for distant sales.

Keep the tone factual. “The appraiser used a comp 3.2 miles away in a different school district while ignoring a sale 0.4 miles away with identical features” is far more persuasive than “the appraiser did a terrible job.” Lenders review hundreds of these requests, and the data-backed ones get the attention.

How to Submit and What to Expect

You don’t contact the appraiser yourself. You submit your evidence to your loan officer or the lender’s appraisal management company, and they relay it to the appraiser for review.¹ Federal law prohibits anyone with a financial interest in the transaction from pressuring an appraiser’s independent judgment, but the same statute explicitly allows you, the lender, and other parties to ask an appraiser to consider additional comparable sales, provide further explanation, or correct errors.⁶ Saying “raise the value” is prohibited. Saying “you missed this comparable sale two blocks away” is not.

There is no federally mandated timeline for how quickly a lender must resolve an ROV. The 2024 interagency guidance deliberately left this flexible but instructs lenders to establish internal timelines and communicate status updates to borrowers.¹ Most lenders resolve requests within one to three weeks. If your closing date is approaching, tell your loan officer immediately so they can expedite the review or adjust the timeline.

Outcomes typically fall into three categories:

Revised value. The appraiser agrees the evidence supports a higher number and issues an updated report. This happens more often than people expect when the evidence is strong.
Partial adjustment. The appraiser revises upward but not all the way to the purchase price. You’re in a better position but may still have a gap to address.
Denial. The appraiser stands by the original value. The lender may order a second appraisal if the evidence is compelling, though this depends on the lender’s own policies.

If the Reconsideration Is Denied

A denied ROV isn’t the end of the road, but your remaining options involve either money or renegotiation. Which path fits depends on the size of the gap and how badly you want the house.

Renegotiate the purchase price. Ask the seller to lower the price to the appraised value, or meet somewhere in the middle. In a balanced market, sellers often agree to split the difference rather than lose the deal.
Cover the gap with cash. If the gap is small and you have savings beyond your down payment and closing costs, you can pay the difference out of pocket. The lender will still base its loan amount on the appraised value.
Walk away. If your purchase contract includes an appraisal contingency, you can cancel the deal and get your earnest money back. This is why real estate agents strongly recommend including that contingency, especially in competitive markets where offers sometimes stretch above what comparable sales support.
Request a second appraisal. Some lenders will order a new appraisal from a different appraiser when your evidence was strong but the original appraiser wouldn’t move. A standard single-family appraisal typically costs $350 to $600, though prices vary by location and property complexity. The 2024 interagency guidance encourages lenders to establish guidelines for when a second appraisal can be ordered and who pays for it.¹

When to Escalate Beyond the Lender

If you believe the appraiser committed serious professional errors or violated appraisal standards, you can file a complaint with your state appraisal licensing board. The Appraisal Subcommittee of the Federal Financial Institutions Examination Council operates a national hotline that helps you identify which state and federal agencies have jurisdiction over your specific complaint.⁷ Complaints can involve violations of appraisal standards, negligent work, or false statements in the report.

If your issue is with the lender rather than the appraiser, the Consumer Financial Protection Bureau accepts mortgage-related complaints. Filing through the CFPB triggers a formal response from the lender and creates a record that feeds into the agency’s enforcement activities.⁸ Consider this route when a lender refuses to process your ROV request or fails to follow its own stated procedures.

If You Suspect Discrimination

If you believe your property was undervalued because of your race, national origin, religion, sex, disability, or familial status, that’s a potential Fair Housing Act violation. You can report housing discrimination to HUD’s Office of Fair Housing and Equal Opportunity online, by phone at 1-800-669-9777, or by mail.⁹ The filing deadline is one year from the date of the alleged violation.¹⁰ The 2024 interagency ROV guidance also instructs lenders to develop processes that identify and address valuations involving prohibited discrimination.¹ If bias is a factor, file both an ROV with your lender and a separate discrimination complaint with HUD. The two processes run independently, and using both gives you the best chance of a meaningful result.

1
Federal Register. Interagency Guidance on Reconsiderations of Value of Residential Real Estate Valuations
2
Consumer Financial Protection Bureau. 12 CFR 1002.14 – Rules on Providing Appraisals and Other Valuations
3
Fannie Mae. Comparable Sales
4
Fannie Mae. Appraiser Update April 2025
5
U.S. Federal Housing Finance Agency. Underutilization of Appraisal Time Adjustments
6
Office of the Law Revision Counsel. 15 USC 1639e – Appraisal Independence Requirements
7
Appraisal Subcommittee. Appraisal Complaint National Hotline
8
Consumer Financial Protection Bureau. Submit a Complaint
9
U.S. Department of Housing and Urban Development. Report Housing Discrimination
10
eCFR. 24 CFR Part 103 – Fair Housing Complaint Processing