How do I dispute an FHA appraisal? (FHA ROV rules)

FHA's 2024 ROV rules were rescinded in March 2025

On May 1, 2024, HUD issued Mortgagee Letter 2024-07. It created one uniform process for FHA borrowers who wanted to challenge an appraisal: one borrower-initiated request per appraisal, up to five alternative comparable sales, a notice at application and again at appraisal delivery, no ROV costs charged to the borrower, and a rule that the ROV had to be resolved before closing. Lenders had to follow it for FHA case numbers assigned on or after September 2, 2024.

It did not last. On March 19, 2025, HUD issued Mortgagee Letter 2025-08, effective right away. It rescinded ML 2024-07, the letter that pushed back its start date (ML 2024-16), and an older appraisal fair housing letter (ML 2021-27). HUD said the ROV rules added cost and that it did not have enough data yet to judge them, since it only began tracking ROV requests in October 2024.

If you read an article that says every FHA borrower gets "one ROV and five comps," it is describing a rule that lived for less than a year. Plenty of websites never got the memo. Some are still printing the 2024 memo.

What FHA's rules say now

ML 2025-08 put back the earlier handbook language. Here is what it says:

• The underwriter asks. The lender's underwriter may request a reconsideration when the appraiser did not consider relevant information.
• The underwriter sends the data. The underwriter must give the appraiser all the relevant data needed for the review.
• A possible fee. The appraiser may charge an added fee if the data was not available on the appraisal's effective date. If that was not the borrower's fault, the borrower must not be held responsible for the cost.
• The effective date is the inspection date. FHA defines it as the day the appraiser inspected the property.

What is gone as a HUD rule: the borrower notices, the one-request limit, the five-comp cap, the written status updates and the before-closing deadline. A lender may still use parts of it as its own policy.

You can still ask. NAR's summary of the change says borrowers are still entitled to request an ROV and should contact their lender to start one. Fannie Mae and Freddie Mac have their own ROV rules, and those are still in effect, but they cover conventional loans, not FHA loans.

One more thing to watch. The 21st Century ROAD to Housing Act became law on July 11, 2026, and it directs FHA, VA, USDA and FHFA to set up procedures for consumer-requested reconsiderations of value. When HUD publishes FHA's version, the details may change. Until then, the handbook language above and your lender's own process are what you work with.

An ROV is not the same as asking for a correction

Three different things get lumped together as "disputing the appraisal." Knowing which one you have saves time.

• Correction or explanation: the report lists the wrong bedroom count, or an adjustment is not explained. Asking the appraiser to fix or explain that is part of normal appraisal review, not an ROV. Your lender may handle it faster than a full ROV.
• Reconsideration of value: you have new information, like better comparable sales, that could change the value.
• Material deficiency: a serious defect with a direct impact on value or marketability, such as unreported health or safety problems, outdated or dissimilar comps when more recent or more similar sales were available, or fraudulent statements.

For a material deficiency, the lender may order a second appraisal, but only if the appraiser can't or won't fix the problem. In that case, the lender pays for the second appraisal and documents the deficiency. You do not get a second appraisal because the first one was disappointing. Disappointing is not a defect category.

If you believe the report reflects bias, say so in writing to your lender. You can also file a fair housing complaint with HUD.

How to build a strong FHA ROV

1. Ask your lender for its ROV process in writing: what it needs from you, how many sales it will accept, and how long it usually takes.
2. Read the full report and list factual errors first. Send those as corrections where you can.
3. Pick sales from before the effective date. That is the inspection date. If you send data that was not available then, the appraiser may charge an added fee, though the borrower is not responsible for it when the delay was not the borrower's fault.
4. Choose sales that are truly similar: same area, similar size, age, condition and features. Three strong comps beat six weak ones every time.
5. Say which part of the report you dispute and why, in a few sentences.
6. Submit through your lender using its form. The underwriter decides what goes to the appraiser. Do not call the appraiser yourself.
7. Watch your contract clock. Your contingency deadlines keep running while the lender reviews your request. Ask your agent about an extension early.
8. Keep copies of everything and note the dates.

Your agent can help pull the sales. A clean one-page request with a handful of good comps reads better than a heartfelt essay about the backyard.

Leave out what does not count as evidence: the list price, an online estimate, what your neighbor thinks his house is worth, and active listings on their own. Asking prices are what sellers hope for. Closed sales are what buyers actually paid.

What happens after you send it

Your request goes to the lender's underwriter first. Under the current handbook language, the underwriter decides whether the information is relevant, then sends the appraiser the data needed to take another look.

With the 2024 rules gone, HUD no longer spells out the steps after that, such as written status updates or a set format for the answer. Ask your lender how it will tell you the result, and ask for that answer in writing. Your file deserves a paper trail, not a voicemail.

As an appraiser, here is what I look for in a request: sales I may have missed, facts I got wrong, and a reason to believe the market moved. When a request brings real evidence, I take it seriously, because my name is on the report. When a request brings the listing price and a sad emoji, there is not much for me to work with.

If the value stays the same, you still have options: renegotiate the price, cover the gap in cash, or use your contract's appraisal contingency if you have one. For anything in your contract, ask your agent or attorney about your exact deadlines.