These responses in regard to ROV's are my favorite read on the AF.
ECONSIDERATION OF VALUE
The requirements of a Reconsideration of Value are very specific in that the appraiser can only be requested to review appropriate comparable sales. Upon submission of any alternate sales for a Reconsider of Value, the lender must include a summary why these sales are superior to the ones chosen for the report.
FEE FOR RECONSIDERATION OF VALUE
If the appraiser has erred and the submitted additional sales are good comparable sales and the market value is changed, no additional fee will be charged. If the appraiser finds that these sales are not as good of comparables as the sales used in the original appraisal report and no change in market value is found, the client shall pay a fee of $25 for each sale that was submitted to review.
NOTE: Any pressure to use or review sales that are chosen simply for their sale price in a "Reconsideration of Value" request and are not found to be appropriate comparable sales will be considered a violation of Appraiser Independence protected in the Dodd-Frank Act by unlawfully influencing an appraiser and encouraging a targeted value. This violation will be immediately reported to the Consumer Financial Protection Bureau, the ASC, the State Attorney General and all other applicable State and Federal authorities as well as any related Government Sponsored Enterprises, which consider it an unacceptable practice to select inappropriate comparable sales.
Keep this very broad! Don't give them the final criteria and don't give them a list of properties. Here's how I start my sales comparison approach commentary for comp criteria:
Every effort was made to use/reflect comparable sales as close in proximity to the subject as possible and comparables that would necessitate minimal adjustments. Search for comparables were selected by an initial broad search of all sales within the past 12 months and expanding ~2 miles, including properties with large variances from the subject, then systematically narrowed to the most similar, most recent and closest in proximity to the subject with similar neighborhood surroundings. All comparables are similar as possible in design, appeal, quality of construction, overall condition, effective age, and site value, and if not, were adjusted accordingly for inferiority and superiority. This appraiser gathers comparable property condition(s) from the exterior inspection from the street, along with interior MLS photos, and attempts to contact the buyer/seller agents for further and more complete descriptions and data verification, including contract information and buyer/seller motivation in order to most accurately determine the effect on value. All comparables are located in the same or nearby competitive neighborhoods, and again, within as close proximity to the subject as possible. This appraiser reviewed all comparable sales in the market area over the past 12 months and deemed the comparables provided to be the best available, regardless of date of sale. Date of sale adjustments were made if/when necessary to compensate for current market conditions.
The comparables used are the most recent, which still produced as low gross adjustment percentage as possible. Every effort was made to "bracket" the sales/listings in order to express both slightly inferior and slightly superior comparable properties. All sales were considered. The comparable sales used in the report were the best available sales and proved reliable indicators of value. The use of additional comparables would necessitate even larger adjustments, or greater distance than the current comparables, which is considered by this appraiser to be unnecessary as it would have NO impact on the final value estimate, but may lead to a misleading report. Five sales were selected to lend additional support to this analysis. To show current market trend and provide support for the primary indicators of market condition (growth rate, property values, demand/supply, and marketing time), 2 comparable MLS active listings in the subject's area were also included - see active listing comps. All adjustments were extracted from the subject's market and rounded to the nearest $500. Any variance that shows a zero (0) adjustment means that the variance was considered but found not to have significant contributable value in the market place.
