What can I do if I think my appraisal was biased or discriminatory?

Appraisal discrimination is illegal

The Fair Housing Act of 1968 bars discrimination in housing, and that includes appraisals. An appraiser can't let race, color, religion, national origin, sex, familial status or disability influence a value. Neither can the lender who relies on the appraisal.

This isn't a theoretical concern. In June 2021, the federal government created an interagency task force on Property Appraisal and Valuation Equity, called PAVE, specifically to address racial and ethnic bias in home valuations. HUD ended the PAVE task force policies in July 2025, but the fair housing laws behind them did not change. Its action plan committed agencies to make it easier for consumers to request a reconsideration of a low value, to improve federal appraisal data and research, to strengthen enforcement, and to expand anti-bias training for appraisers.

If you suspect bias, you're not being difficult by raising it. The system now has specific channels built for exactly this.

What bias can look like in a report

Most valuation disputes are about comps and adjustments. A bias concern is different, though it can show up in the same places. Things worth a careful look:

• Language about people instead of property. Comments about the neighborhood's residents, "pride of ownership" in a way that points at who lives there, or coded descriptions of an area. Value should be about houses, sales and market data. A sentence describing who lives somewhere has no business in a value opinion.
• Comps that skip the obvious. Better-matched sales close by were passed over for lower sales from a different area, with no explanation.
• Inconsistent treatment. Adjustments on your house that don't match how the same features were treated on the comps.
• A second opinion that swings for no reason. If another appraisal of the same house, close in time, came in very differently and nothing about the house changed except cosmetic or personal items, keep both reports. That's not proof by itself, but it's worth documenting.

Facts over feelings works in both directions here. Specific, written facts give your concern the most weight.

Step by step: what to do

1. Get the full report. On a first-lien mortgage, federal rules enforced by the CFPB entitle you to a free copy promptly once it's done, or at least three business days before closing, whichever comes first.
2. Mark specific concerns. Note the page, the comment or comp, and why it worries you. Add better comparable sales if you have them.
3. Send a written reconsideration of value (ROV) to your lender. Not to the appraiser, because on a loan the appraiser works for the lender. Say plainly if you believe the appraisal reflects discrimination.
4. Do it before closing. Under Fannie Mae and Freddie Mac policies, a borrower's ROV has to be raised before the loan closes, and you get one borrower-initiated ROV per appraisal. FHA's uniform ROV rules were rescinded on March 19, 2025, so on an FHA loan, ask the lender for its process and timeline. Either way, make it count, and put everything in one request.
5. Ask about a second appraisal. Freddie Mac's Guide lets a lender get a subsequent appraisal when the original shows indicators of a violation of nondiscrimination standards, and those indicators are documented in the file.
6. File complaints if needed (see below). You can do this alongside the ROV.

Where to file a complaint

• HUD: You can file a fair housing complaint with HUD's Office of Fair Housing and Equal Opportunity.
• CFPB: If you think a lender discriminated against you, you can file a complaint with the Consumer Financial Protection Bureau.
• A local fair housing center: Many are funded through HUD and can help with a preliminary investigation and the complaint process.
• Your state appraiser board: In California, that's the Bureau of Real Estate Appraisers (BREA), which investigates complaints about USPAP and regulation violations and can discipline licenses.

These are different tools. A regulator complaint can lead to discipline or enforcement, but it won't by itself change the value on your loan. The ROV and a possible second appraisal are what address the loan. If you're weighing legal action, talk to a fair housing attorney.

Lenders now have to take ROVs seriously

On July 18, 2024, five federal regulators (the CFPB, FDIC, Federal Reserve, NCUA and OCC) finalized joint guidance on reconsiderations of value. It describes how lenders can build ROV processes that let consumers submit information the appraiser may not have considered, and it includes sample policies for spotting and reducing discrimination risk.

Separately, Fannie Mae and Freddie Mac rolled out ROV policies in 2024 that require lenders to tell borrowers how the process works, standardize how requests go to appraisers, and refer appraisers to the right agencies when there are possible anti-discrimination violations. Exact steps vary by lender and loan type, so ask your loan officer for their written ROV process.

What I see in the field

A good appraisal describes the property and the market, not the people. Every comp should be explained, every adjustment measured from real sales, and every comment should be something you could read aloud to the homeowner without anyone wincing.

If a report can't pass that test, raise it. You don't have to prove intent to ask for a second look. You just have to point to the facts that don't add up. The fastest way to be taken seriously is a calm letter with page numbers, not a long one with adjectives.

One more thing. Keep copies of everything: the report, your letter, the lender's answer and the dates of each. If the issue goes to a regulator or an attorney later, a clean paper trail does a lot of the work for you. Paperwork is boring. Paperwork also wins.