Does the appraiser have to use the comps the agent sends?

Why the appraiser picks the comps

Appraiser independence is the whole point of the job. If the person who earns a commission when the deal closes could also choose the evidence, the lender would be paying for a very expensive opinion of the agent.

NAR's own guidance to agents says it plainly: do not tell the appraiser which comps to use, and do not say your client needs a certain value. NAR's appraiser independence brief adds that an agent may not intimidate or bribe an appraiser.

What you can do is offer. Under Dodd-Frank, as NAR explains, a party may ask the appraiser to consider additional, appropriate property information, including additional comparable properties. Offering three good sales with notes is welcome. Insisting on them is a different conversation, and nobody enjoys that one.

Why your data gets double-checked

You are an interested party. That is not an insult, it is a job description. NAR's brief notes that under Freddie Mac's guidelines, when an appraiser uses information from a party with a financial interest in the sale, that information must be verified by disinterested third-party sources.

In practice I confirm your sale prices, dates and terms in the MLS and public records. I check square footage against records and my own measurements. I look at the photos to see if the remodeled kitchen in your note is the same kitchen in the listing.

If everything checks out, your comp goes into my pool of candidates on equal footing with the ones I found. If it does not check out, I note what I found and move on. A comp that was really a family sale between cousins at a friendly price is not a market sale, no matter how nicely it is highlighted.

What makes an agent comp actually get used

Fannie Mae requires at least three closed comparables in the sales comparison approach. Pending sales and current listings can be used as supporting data, but they do not count toward that minimum. Fannie also says comparables that closed within the last 12 months should be used, though older sales can be used if the report explains why.

Within those rules, the best comps are the ones a buyer would have weighed against the subject. When your sale is like that, it usually ends up in the report. Here is what helps:

• Closed, not active. Your list of five gorgeous active listings tells me what sellers hope. I need what buyers paid.
• Close by and recent, in the same competing area.
• Similar in the things buyers pay for: size, condition, lot, view, layout.
• Honest about the differences. "Bigger lot than the subject but no remodel" tells me you looked at both sides.
• Verifiable. MLS number or recording info. A comp from "a guy at my brokerage" is a rumor with a price.

What happens in a formal reconsideration of value

If the report is already done and you think the appraiser missed better sales, the path is a reconsideration of value (ROV), and it goes through the lender. NAR notes that after the report is delivered, the agent has to use the client, typically the lender, as the go-between.

For Fannie Mae loans, the borrower-initiated ROV policy Fannie announced in May 2024 sets the rules:

• Only one borrower-initiated ROV is allowed per appraisal, and it must be submitted before closing.
• The borrower can provide up to five comparable sales, with the data sources.
• The appraiser must analyze the relevance of what was provided.
• Whether or not the value changes, the appraiser must deliver a revised appraisal that describes the issues raised and the outcome.

FHA used to have a similar requirement. HUD's 2024 rules made the appraiser answer an ROV in a revised report, even with no change, but HUD rescinded them on March 19, 2025, in Mortgagee Letter 2025-08. Under the current FHA handbook language, the underwriter may ask for a reconsideration when the appraiser did not consider relevant information, and must send the appraiser that data. Ask your lender how it handles the answer.

So the appraiser still does not have to use your comps. On a Fannie Mae loan, they do have to look at them and explain, in writing, why they did or did not.

What I see in the field

Some of the best data I get comes from agents. You know which house had the foundation problem that never made the listing, and which one sold to the neighbor for a private price. That is real market knowledge.

The comps that do not help are the ones picked by price instead of by similarity. A packet that contains only the five highest sales in a mile, half of them with pools and views your listing lacks, tells me the target before I have opened the folder.

My standard is simple: every comp in my report, whether I found it or you did, has to survive the same test. Facts over feelings, regardless of who is holding the folder.

What to do if you think the appraiser missed a comp

1. Read the report first. The appraiser may already have looked at your sale and explained why it was left out.
2. Pick no more than five sales that are closed, recent, close and truly similar. Fannie's ROV policy caps it at five anyway.
3. Explain each one in a sentence, including what makes it a better match than the comps in the report.
4. Point out factual errors separately: wrong square footage, missed bedroom, wrong condition.
5. Send it through the lender, not directly to the appraiser.
6. Leave the value out. A request that says what the number should be reads as pressure. Let the evidence make the case.

If you want an independent read before you file, a desktop review gives you a second opinion on the report, measured against the evidence.