Low Appraisals & Disputes

Can my real estate agent talk to the appraiser or give them comps?

Cartoon of a grinning agent beside the appraiser, who happily reads a folder labeled Sales, while Comps the basset hound lies on a coral sticky note with a circled dollar figure.
Comps are welcome. The circled number stays under the dog.
The short answer

Yes. No federal rule or USPAP bars an appraiser from talking with agents during the appraisal, and agents can share property facts, comparable sales and the purchase contract. What agents cannot do is pressure, bribe or intimidate the appraiser toward a value. After the report is delivered, questions and corrections go through the lender.

Yes, you can talk to the appraiser

A lot of agents think the appraiser is behind a velvet rope. Some appraisers act like it. But the rules do not say that.

The National Association of REALTORS sums up the federal picture this way: none of the appraiser independence rules prohibit appraisers from speaking with real estate agents during the appraisal process. Agents may talk with appraisers, provide additional property information and give them a copy of the sales contract on a purchase.

Regulation Z, the federal rule behind appraiser independence on most home loans, goes a step further. It lists things that do not count as improper influence, including asking the appraiser to consider additional, appropriate property information, including comparable properties, and asking the appraiser to correct errors.

So when I show up at a listing and the agent is standing at the door with a folder, that is not a red flag. That is a professional doing their job. The red flag is when the folder has a sticky note on it with a number circled three times.

Where the line is

Talking is fine. Steering is not.

Regulation Z gives examples of what crosses the line. The first one on the list is seeking to influence the appraiser to report a minimum or maximum value. Others include threatening to withhold payment, hinting that future work depends on the number, and tying the appraiser's pay to the deal closing. NAR adds the plain version: an agent may not intimidate or bribe an appraiser.

Here is how that plays out at the front door:

  • Fine: "The kitchen and both baths were redone in 2022. Here are the permits."
  • Fine: "Here are three sales I think are close matches, and why."
  • Fine: "Here is the contract and the list of credits."
  • Not fine: "We just need it to come in at the contract price."
  • Not fine: "The last appraiser who came in low does not get calls from this office anymore."

A box of open house cookies is a gray area I would rather not test. Keep the cookies for the buyers.

What a comp packet should look like

The best packets I get are short and boring. Boring is good. Boring means facts.

One thing to know: the appraiser has to verify what you hand over. NAR notes that under Freddie Mac's guidelines, information from interested parties must be verified by disinterested third party sources, such as public records, the MLS or real estate professionals who have no stake in the property. You are an interested party. That is not an insult. It just means your sale is a lead, not proof.

A packet that actually helps:

  • A list of updates with dates, costs if you have them and permit numbers
  • Three to five closed sales, each with one line on why it fits: same tract, same condition, same lot type
  • Any sale you know about that the MLS gets wrong, like a remodel that was never photographed
  • Pending sales and active listings marked clearly as not closed
  • The contract, credits and any repair agreements

Leave out the Zestimate printout. I promise I have seen it, and I promise it did not help.

After the report is delivered, the lender is the door

Once the report is done, the rules change. NAR notes that USPAP bars an appraiser from discussing the results with anyone but the client who ordered the appraisal, typically the lender, or people the client specifically authorizes. So if you want a correction, you go through the lender.

Lenders tell borrowers the same thing. Chase's guidance says customers should not contact the appraiser to discuss the contents, analysis or results, and should submit a reconsideration of value request through their loan officer instead.

For loans sold to Fannie Mae, the lender has to have a process for a borrower initiated reconsideration of value, called an ROV. Fannie Mae allows only one borrower initiated ROV per appraisal, it can include no more than five additional comparable sales, and it cannot be submitted after the loan closes. Each one has to explain what is wrong in the report and why the new data supports a change.

One shot, five comps. That is not the time for your whole wish list. Pick the strongest evidence and explain it like you are talking to an underwriter, because you are.

What actually works on me

I am an appraiser, so take this as one appraiser's view of what lands.

Data that I can check works. Context that is not in the MLS works: the sale down the street that closed low because of a foundation problem, the listing photos that are ten years old, the "three bedroom" that is really two and an office. That kind of local knowledge is exactly why agents are worth talking to.

What does not work is the contract price as an argument. The contract is one buyer and one seller on one day. It tells me what those two people agreed to. It does not set value. The value comes from what the wider market did with similar homes, and I measure adjustments from real sales, not from what anyone hopes.

Tone works too. An agent who says "here is what I know, tell me what I am missing" gets a real conversation. An agent who starts with "I've been doing this 30 years" gets a polite nod and a very thorough report.

A quick checklist for agents

  1. Ask the appraiser if they want to meet or would rather get a packet by email. Respect either answer.
  2. Bring facts, not a target. Never mention the number you need.
  3. Give each comp a reason. One line on why it matches beats ten sales with no notes.
  4. Include the contract and credits on a purchase. The appraiser will see them anyway.
  5. Point out what the MLS missed, with something the appraiser can verify.
  6. After delivery, route everything through the lender. Help your buyer build one strong ROV instead of several weak ones.

Key takeaways

  • Agents can talk to the appraiser and share comps, property facts and the contract.
  • Asking for a specific value, or pressuring or bribing the appraiser, crosses the line.
  • Data from agents must be verified by the appraiser through sources with no stake in the deal.
  • After delivery, the appraiser talks only to the client, usually the lender, so corrections go through the lender.
  • Fannie Mae allows one borrower ROV per appraisal with up to five additional comps.

People also ask

Can the listing agent meet the appraiser at the house?

Yes. Many appraisers welcome it, as long as the conversation is about property facts and sales, not a target value. Some prefer to get information by email instead.

Does the appraiser have to use the comps I give them?

No. The appraiser has to consider relevant information, but they choose the comps and must verify any data from interested parties through independent sources.

Can a buyer call the appraiser directly about a low value?

No. The appraiser can discuss results only with the client, usually the lender. The buyer should ask the loan officer about a reconsideration of value.

Sources

About the author

Anthony Young is a California Certified Residential Appraiser (License AR041465) with more than 25 years in residential valuation, offices in the San Francisco Bay Area and Southern California, and a national educator who teaches agents and loan officers how value really works. This article is general information, not legal, tax or lending advice.

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