What are the new Fannie Mae and Freddie Mac ROV rules?

What changed and when it started

A reconsideration of value (ROV) is a formal request asking the appraiser to take another look at the value, based on information that may have been missed. Before 2024, every lender ran ROVs its own way. Some had a real process. Some had a shared inbox and a prayer.

Fannie Mae published a standard ROV policy on May 1, 2024, and Freddie Mac set matching requirements in its Guide (section 5604.4). Lenders had to put them in place for loans with applications dated on or after August 29, 2024.

FHA briefly had its own version. HUD's Mortgagee Letter 2024-07 applied to FHA case numbers assigned on or after September 2, 2024, but HUD rescinded it on March 19, 2025, in Mortgagee Letter 2025-08. The Fannie Mae and Freddie Mac rules are still in effect, and they are what this post covers.

Freddie Mac calls its rules minimum standards. Your lender can add to them, but not go below them.

The borrower gets one shot with five comps

Here are the borrower-side limits, straight from the Fannie Mae and Freddie Mac language:

• One ROV per appraisal. Only one borrower-initiated request is allowed for each appraisal report.
• Up to five alternative comps. The borrower can submit no more than five comparable sales, and each one needs its data source, like the MLS listing or public records.
• Before closing. Once the loan closes, the borrower can no longer submit an ROV for that appraisal.
• Specific complaints. The borrower has to point to what is unsupported, inaccurate or deficient, provide the data, and explain how it supports a different conclusion.

That last point is the one people skip. "The house is worth more" is a feeling. "Comp 2 is a short sale and these three standard sales two blocks away closed higher" is a request.

One shot means the first draft has to be the good draft. This is not the time for a rough cut and a sequel.

The lender's job comes before the appraiser sees anything

The policy puts real work on the lender, and the order matters.

1. Disclose the process. Fannie Mae requires a disclosure explaining the ROV process at application and again when the appraisal goes to the borrower. Freddie Mac requires one when the appraisal is delivered.
2. Finish your own review first. The lender completes its appraisal review before starting any ROV.
3. Name a reviewer. An underwriter or other appraisal expert reviews the borrower's request.
4. Screen it. The lender confirms the request has enough supporting evidence before sending it to the appraiser. If it is unclear or thin, the lender goes back to the borrower.
5. Send a standard package. Fannie Mae lists what goes to the appraiser: borrower names, property address, effective date, appraiser name, ROV date, the specific issues, the data or comps (five max), turn-time expectations and instructions to return a revised report.
6. Keep everything. All ROV documents and communication stay in the loan file.

Lenders must also report unresolved material problems to the appraiser's licensing board and suspected discrimination to the proper agency. And all of it has to stay inside the Appraiser Independence Requirements. Fannie Mae says the ROV policy does not change those rules.

What the appraiser has to do with it

On my side of the desk, the rules are simple. I have to look at what was sent, decide whether it is relevant, and deliver a revised report within the time frame the lender set. That revised report describes the points in dispute and the outcome, whether the value changes or not.

What I see in the field: the ROVs that work bring evidence the market produced. A closed sale I missed. A comp with a condition problem I had no way of knowing about. A wrong square footage on a public record. Those get real attention, because facts over feelings cuts both ways. If I missed something, the value should move.

The ones that don't work are a list of active listings, the Zestimate and a note that the seller's brother-in-law "knows the area." I have met a lot of brothers-in-law. None of them have closed escrow.

One more rule loan officers should know. Freddie Mac says a lender must not order a second appraisal unless there are signs the first one was not credible, it is part of a set review or quality control process, or the law requires it. When there are two, the lender uses the most credible one, not the one with the number somebody wanted.

How to build an ROV that gets read

1. Read the whole report first. Find the exact line you disagree with: a comp choice, an adjustment, a room count, a square footage.
2. Pick your best five, or fewer. Closed sales, similar size, age and condition, close to the subject and close to the effective date. Three strong comps beat five weak ones.
3. Give the source for each one. MLS number or public record. The rules require it.
4. Explain the why in plain words. One or two sentences per comp on how it supports a different value.
5. Fix the facts separately. Wrong bedroom count or lot size? Say so clearly. Fannie Mae's package includes a reference for correcting minor errors unrelated to the ROV.
6. Submit early. The clock ends at closing, and the lender still has to screen it before the appraiser even starts.
7. Leave out pressure. No target value, no "we need it at." That is an independence problem, not an argument.