Overview
Five federal agencies finalized interagency guidance in July 2024 on Reconsiderations of Value (ROVs) in residential real estate appraisals, giving consumers a formal path to flag information an appraiser may have overlooked or point out deficiencies in an initial appraisal. This matters directly to Miami buyers and sellers, where condo appraisals often hinge on limited, sometimes stale comparable sales within a single building. Knowing this process exists, and how to use it, can make a real difference if an appraisal comes in lower than expected.
What the New Guidance Covers
Five federal agencies finalized guidance on Reconsiderations of Value (ROVs) in residential real estate transactions. This protocol lets consumers submit additional information that may have been overlooked, or flag deficiencies identified in an initial property appraisal.
An ROV is a request made by a financial institution to an appraiser or other valuation-report preparer to reassess a property's value. Federal agencies note an ROV may be warranted if a consumer provides information highlighting potential deficiencies or other factors that could reasonably affect the property's estimated value.
The guidance was issued jointly by:
- Consumer Financial Protection Bureau (CFPB)
- Federal Deposit Insurance Corp. (FDIC)
- Federal Reserve Board (FRB)
- National Credit Union Administration (NCUA)
- Office of the Comptroller of the Currency (OCC)
It includes example ROV policies and procedures financial institutions can adopt, aimed at helping institutions manage discrimination risk in real estate valuations.
Why This Matters
The guidance addresses a real gap: appraisal deficiencies can have outsized consequences for homeownership and wealth-building. By giving consumers a formal channel to flag overlooked information, it aims to support more accurate valuations across financing, home equity access, and determining fair market value for sales and refinances.
Why This Matters More in Miami Specifically
Condo appraisals in Miami lean heavily on comparable sales within the same building, ideally the same line, since unit value can vary significantly by floor and exposure even within one property. In buildings with limited recent sales activity, an appraiser may end up relying on thinner or older comparable data than ideal. If you believe an appraisal missed a relevant comparable sale or overlooked a recent renovation, the ROV process gives you a formal way to raise that with your lender before the deal is jeopardized.
How the Guidance Developed
The agencies sought public comment on proposed guidance in 2023, asking specifically what financial institutions should do when information wasn't considered during an original appraisal, or when deficiencies are identified afterward. That feedback shaped the final guidance issued in 2024.
Common questions
A request from a financial institution to an appraiser to reassess a property's value, often prompted by a consumer flagging information that wasn't considered in the original appraisal.
The formal request comes from the financial institution, but you can raise your concerns with your lender, who then decides whether to initiate the ROV process based on the guidance's framework.
Condo values often rely on limited comparable sales within a single building. If an appraisal appears to have missed a relevant comp or overlooked a renovation, the ROV process gives you a formal channel to raise that concern.
The CFPB, FDIC, Federal Reserve Board, NCUA, and OCC jointly finalized the guidance in 2024.
Navigating an appraisal on your Miami condo purchase or sale? Browse current listings on Allioo or reach out for guidance through the process.
Anthony Johnson is a Miami Real Estate Agent, licensed for over 10 years and specializing in Downtown Miami and South Beach condos. He is the founder of Allioo, a platform enhancing the experience for Miami condo sellers and landlords, and of Allioo Studio, which builds real estate tools and website templates for real estate agents.
