The Quick Read: Yes, but only through your lender, and only on facts. You cannot call the appraiser yourself. You give your loan officer documented proof of completed work the report missed, and the lender’s underwriter decides whether to send a Reconsideration of Value (ROV) request. A low number alone does not qualify, and an ROV can return the same value if the comparable sales support it.
What Is a Reconsideration of Value?
An ROV is a request from the lender’s underwriter asking the appraiser to reassess the report based on information that may affect the value conclusion. HUD used this wording in Mortgagee Letter 2024-07. HUD’s consumer page also says that if the value comes in lower than expected, you can ask your lender to request one. It lists wrong square footage, wrong room counts and unsuitable comparable sales as grounds, and notes the appraiser may issue an amended report or conduct another appraisal.
The borrower makes the case. The lender sends it. That is the whole chain.
One currency note matters here. HUD’s 2024 guidance briefly created a formal borrower-initiated appeal process, and the effective date was later extended. A later HUD letter, Mortgagee Letter 2025-08, rescinded both and restored the earlier handbook language. So do not assume FHA guarantees you an appeal. Think of it as your lender’s ROV process, and ask how your lender runs it.
Did the Appraiser Ignore It or Under-Credit It?
Start by diagnosing the problem, because each one has a different fix.
| Situation | What the report shows | Likely path |
|---|---|---|
| Omitted work | Finished renovation not mentioned | ROV with documentation |
| Wrong facts | Square footage or rooms misstated | ROV citing the error |
| Weak comparables | Sales that don’t match your home | ROV with better closed sales |
| Under-credited | Work noted, value lower than cost | Usually no ROV basis |
| Unfinished work | Work incomplete on inspection date | Not part of this value |
“Ignored” means a factual omission. “Under-credited” means you disagree about how much the work is worth. The first is a legitimate ROV. The second rarely is.
What an FHA Cash-Out Appraisal Actually Does With Renovations
The appraisal values the home as it stands on the inspection date. Work that was unfinished, or that the appraiser could not see or verify, can be left out or discounted without any error on the appraiser’s part.
Value also reflects what buyers in your market pay, not what you spent. A kitchen that cost a lot may add less, and comparable sales drive the number. This is how appraisals work in general, not a HUD quote, but it explains why cost does not equal value.
FHA appraisals also check property condition standards: safety, soundness and security. That is a separate job from valuing your upgrades. A required repair is not the same thing as a renovation the appraiser overlooked.
If your plans involve heavy renovation still ahead, an FHA cash-out is the wrong tool. The FHA 203(k) renovation product handles that. HUD’s FHA Connection help shows a 203(k) case needs an as-is appraisal and a “subject to” appraisal (HUD FHA Connection). A cash-out appraisal values only what exists today.
Why Appraised Value Matters So Much on a Cash-Out
Across the wholesale programs Lendmire works with, the FHA cash-out reaches 80% loan-to-value on a home you have owned and occupied for 12 months before the case number. Value is the denominator. A missed renovation shrinks the ceiling, which shrinks your cash.
Picture a homeowner whose finished renovation adds a meaningful slice of value. If the report leaves it out, the 80% cap applies to a smaller number. Cash available falls by 80% of the missing value, less whatever the existing balance already uses. A lower value can also mean less cash or no cash-out, and it can shift the loan-to-value tier that drives mortgage insurance. The FHA upfront premium is 1.75% of the base loan, and the annual premium runs between 0.15% and 0.75% depending on term, amount and LTV. Program figures are subject to lender guidelines and full file review.
The mechanics are why a documented ROV is worth the effort when the omission is real. If you want the program basics first, Lendmire’s FHA cash-out refinance program page lays them out.
How to Build the Evidence Package
HUD’s sources do not publish a document checklist, so treat this as a practical suggestion drawn from how files get reviewed.
| Document | What it proves | Common mistake |
|---|---|---|
| Permits and final inspections | Work was legal and complete | Missing sign-off |
| Contractor invoices and contracts | Scope and completion | Invoices without dates |
| Before-and-after photos | Condition change | Photos with no context |
| Scope of work | What was done, where | Vague summaries |
| Closed comparable sales | Market value of similar finishes | Using listings, not sales |
Dates matter most. The work has to have existed on the appraisal’s effective date.
Present facts, not a target number. Federal interagency guidance says an ROV may ask the appraiser to consider additional appropriate property information or correct errors, but it bars coercion and pressure on the value (Interagency Guidance on ROVs). A request that demands a figure reads as pressure.
A neutral request might say: “The report does not reflect the completed kitchen and bath renovation, final inspected on the dates attached. Please reconsider the report in light of the enclosed documentation and the listed comparable sales.”.
Step by Step: How the Process Runs
1. Get the report. Your lender must give you a copy of the appraisal. Under the CFPB’s rule, creditors must notify you of this right promptly after application (CFPB fact sheet).
2. Read it line by line. Look for omitted work, wrong condition notes and wrong measurements.
3. Gather the evidence from the table above.
4. Send it to your loan officer. The underwriter reviews and decides whether to submit a ROV.
5. Wait for the response. The appraiser may keep the value, or issue a revised report.
6. Resolve before closing. An open ROV can hold the file, so ask your loan officer how it fits your timeline.
Procedures and who pays vary by lender, since ROV policies under the interagency guidance are optional (NASCUS).
When a Challenge Works and When It Doesn’t
An ROV tends to work when you can show a verifiable fact: permitted, completed work the report left out, or a clear data error. It also works when you can supply closed comparable sales the appraiser did not cite.
It tends to fail when the argument is “I spent a lot,” when the work was unfinished, or when comparables already support the original value. A fresh look can return the same number.
Practitioner note: on files like these, the strongest requests are short. A single page naming the omission, with dated proof attached, tends to land better than a long argument about what the home is worth.
If the Value Doesn’t Move
A second appraisal is a narrow exception. Under the language HUD restored in ML 2025-08, it may be ordered only if the underwriter finds the first report materially deficient and the appraiser cannot or will not resolve it. Disagreeing with the value is not enough.
Your realistic options:
- Take less cash. Scale the request to the value on the report.
- Pay down principal to fit the loan-to-value limit.
- Wait and reapply once the work is better documented or newer comparable sales exist.
- Consider a renovation loan if more work is planned.
If you suspect the value reflects bias rather than error, HUD’s page points to the National Housing Discrimination Hotline.
Key Terms Defined
Reconsideration of Value (ROV): A lender’s request that the appraiser review the report based on information that may affect value.
As-is value: The home’s worth in its condition on the inspection date.
Comparable sale: A recently closed sale of a similar nearby home used to set value.
Loan-to-value (LTV): The loan amount as a percentage of the appraised value.
Material deficiency: A flaw in the report serious enough that the appraiser’s conclusion cannot be relied on.
Frequently Asked Questions
Can I contact the appraiser myself?
No. Only the lender’s underwriter makes the request, and a borrower pushing for a value can cross into pressure. Give your documents to your loan officer and let the lender take it from there.
Can the value go down after an ROV?
It can stay the same, and in principle it can change in either direction, because the appraiser rechecks the comparables. That is why a request should rest on facts you are confident support the work, not on hope.
Does unpermitted or unfinished work count?
Usually not. The report values what existed and could be verified on the inspection date. Unfinished work does not raise that value, and unpermitted work is harder to credit, though how a given appraiser and lender treat it varies.
Can I just order a second appraisal if mine is low?
Not for a low number alone. A second appraisal generally requires the underwriter to find the first one materially deficient and unresolved by the appraiser.
Does my renovation cost equal added value?
Rarely. Appraisers reflect what typical buyers pay in your market, so value can land above or below what you spent.
If you are weighing a cash-out refinance against keeping the loan you have, Lendmire can help you compare the programs and the equity each one reaches. Tax treatment can depend on your situation; borrowers should speak with a qualified tax professional before relying on any deduction or credit. All program details are subject to lender guidelines and full file review, and nothing here is a commitment to lend.
For your own numbers, request a scenario review with Lendmire.
About Lendmire
Lendmire, NMLS# 2371349, is a mortgage brokerage with consumer lending licenses in 16 states. FHA, VA, conventional and jumbo purchase and refinance loans are arranged through wholesale lending partners, and each application is reviewed individually by the lender. Scotsman Guide named Lendmire a Top Mortgage Workplace in both 2025 and 2026.
For the program’s current guidelines, see FHA loan programs.
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References
1. HUD Mortgagee Letter 2024-07
2. HUD Mortgagee Letter 2024-16
3. HUD Mortgagee Letter 2025-08
5. Interagency Guidance on ROVs
6. CFPB ECOA valuations coverage fact sheet
7. NASCUS
This article is part of Lendmire’s FHA Loan series — every loan program’s qualification details, guidelines, and scenarios live on the loan options page.
Related reading: Can You Challenge a Low FHA Cash-Out Appraisal With a Second One? · How a Low Appraisal Cuts an FHA Cash-Out on a Paid-Off Home · FHA Cash-Out Refinance Requirements at a Glance
Brandon Miller
Founder & CEO, Mortgage Loan Originator, Lendmire LLC
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Important disclosures. Lendmire (NMLS# 2371349) is a licensed mortgage brokerage. Lendmire is not a direct lender, depository institution, or financial advisor. All loan inquiries are subject to lender underwriting; this article does not constitute a commitment to lend. Rates, terms, and program guidelines are subject to change without notice and vary by borrower profile, property type, and state. Information in this article is general in nature and is not financial, legal, or tax advice. Equal Housing Opportunity. NMLS Consumer Access: nmlsconsumeraccess.org.