VA Reconsideration of Value (ROV) 2026: Low Appraisal Steps

If your VA appraisal came in low, you get two separate chances to change the number, and most people blur them together. Tidewater happens while the appraisal is still open: the appraiser starts it, and your side gets 2 business days to send sales data. A reconsideration of value (ROV) comes after the Notice of Value is issued: the veteran requests it, and VA decides whether to amend the value. Which one you're in determines who acts, what gets sent, and to whom.

Tidewater vs. reconsideration of value at a glance

VA's own fee appraiser training course on Tidewater and ROV treats these as two procedures that start at different moments and end with different people.

A low value is the exception. VA's quick-reference toolkit for real estate professionals reports that 90% of initial VA purchase appraisals met or exceeded the contract sales price in fiscal year 2023. If yours didn't, here is each track in order.

Track 1: Tidewater, while the appraisal is still open

What sets it off

VA's training requires the appraiser to notify the requester or their designee before uploading the appraisal when it appears the estimated market value will fall below the sales price. The name is geographic: VA says the process was first piloted in the Tidewater area of Virginia, and the 2024 interagency guidance on reconsiderations of value notes it has existed since 2003.

Don't expect a number on that call. VA's toolkit is direct about it: "The appraiser is unable to discuss the anticipated appraised value during this process." VA's training slide on Tidewater adds one more line: "Process is for sharing market data only."

Who gets the notice

The appraiser contacts the Tidewater point of contact listed on VA Form 26-1805, the Request for Determination of Reasonable Value that starts the appraisal order. VA Circular 26-22-15 made the Tidewater contact's name, phone, and email a conditionally required field on Lender Appraisal Processing Program (LAPP) and independent (IND) appraisal requests when the request lists a sale price. The current VA Form 26-1805 instructs: "When Purchase Price is not supported, Tidewater is to be sent to Tidewater POC in Section 4." Section IV of that form is the point-of-contact section, and it has a dedicated Tidewater POC block (item 10), separate from the lender, veteran, buyer's agent and seller's agent contacts.

The lender fills out that form, so whoever it lists as the Tidewater contact gets the call. That could be your loan officer, your agent, or someone else. When you go under contract, ask your loan officer who is listed as the Tidewater contact, and make sure that person and your buyer's agent can reach each other quickly.

The 2-business-day window

VA's training says the appraiser "must allow 2 business days for the requester, or their designee, to submit additional sales data for consideration." You will also see "48 hours," including in VA's April 2023 report to Congress, which says the appraiser must "allow 48 hours for the real estate agent, lender or Veteran to supply evidence-based data." Two business days and 48 hours are not the same when a weekend falls in the middle. The practical answer is the same under either reading: have your sales ready to send the day the notice arrives.

What to send

For each sale you want the appraiser to consider, VA's training lists:

• Street address
• Sales price
• Date of sale
• Gross living area
• A copy of the listing, if applicable
• Any other information to assist the appraiser

The training sets no minimum or maximum number of sales, and the appraiser decides whether each one could be used as a comparable. It also doesn't address pending sales. An older VA circular that allowed pending contracts to support a time adjustment, Circular 26-17-18, was rescinded July 1, 2020, so don't treat its rules as current.

What the appraiser has to put in writing

If you submit data, VA's training says the report should note the street address of each sale, whether each was considered (and if not, the justification), and the effect of the data, if any, on the opinion of value. If nothing arrives within 2 business days, the appraiser completes the report and notes that Tidewater was followed with no response from the requester.

Read that section closely if the value still lands short. The appraiser's written reasons for passing over your sales are a good place to start when you build an ROV request.

Track 2: Reconsideration of value, after the Notice of Value

Only the veteran can ask, and only after the NOV

VA's training is specific: "A Reconsideration of Value (ROV) may only be requested by the Veteran borrower after the appraisal is submitted and the Notice of Value (NOV) is issued." A request made before the NOV exists is too early, and the training says the request "must be from the Veteran borrower."

Appraisers are told to stay out of it. VA instructs them to "direct all requests for ROV from the Veteran, real estate agent, or the requester/lender to VA."

Where the request goes

VA's training says the veteran submits the ROV directly to VA through VA's ServiceNow portal. VA's Construction and Valuation page links that portal as the contact route for questions about "reconsiderations of value." VA's toolkit for real estate professionals describes the same step from the lender's side: "The buyer can ask the lender to contact VA to request an ROV if they believe sales data supports an increased value."

Both documents start the request with the veteran and leave the decision with VA. Whichever route your file takes, tell your loan officer the day you decide to file.

Get the full appraisal report first

You can't rebut a report you haven't read. On most VA loans the lender reviews the appraisal and issues the Notice of Value itself, and the statute requires it to share the report: under 38 U.S.C. § 3731(f), a lender authorized to determine reasonable value "shall, as soon as possible thereafter, furnish a copy of the appraisal to the veteran." VA's 2023 report to Congress says a lender's Staff Appraisal Reviewer issues the NOV under the Lender Appraisal Processing Program, and estimates that in fiscal 2022 the veteran may have picked a lender outside that program in approximately 1.8% of VA home loan transactions, in which case VA issued the NOV.

What VA reviews

Per VA's training, VA reviews the appraisal report, additional market data submitted by the veteran, and market data available to VA. The 2023 report to Congress describes that last source as market data available to VA "through its Appraisal Management System." If VA determines a change in reasonable value is appropriate, it issues an amended Notice of Value. VA may also contact the appraiser during the review, and the appraiser must respond to VA's requests for report revisions or clarifications by the following business day.

Building the request

Step 2 follows the 2024 interagency guidance, which says an ROV request may include "property characteristics, or other information about the property that may have been incorrectly reported or not previously considered." VA's training doesn't publish a separate ROV data checklist, so step 3 borrows the Tidewater list above as a template. That's our suggestion, not a VA rule.

How long it takes

None of the VA documents we could open for this guide set a deadline for VA to decide an ROV. The only clock VA's training attaches to the review is the appraiser's next-business-day response to VA. Check the appraisal and closing dates in your purchase contract, and if the review could run past them, raise a written extension with your agent early. For where the appraisal sits among everything else in the file, see the VA loan process timeline; the appraiser's own business-day deadline for your state is in the VA appraisal fee schedule.

What the statute says about a second appraisal

Two provisions of 38 U.S.C. § 3731 also bear on a low value. Under subsection (d), a lender that is not authorized to determine reasonable value may furnish an additional appraisal from an appraiser on VA's list, within a period VA prescribes, and VA "shall consider both the initial appraisal and the additional appraisal." Subsection (e)(1) says a veteran can't be required to pay any portion of that additional appraisal. Subsection (e)(2) lets the veteran furnish an additional appraisal from an appraiser on VA's list, which VA must consider before issuing a revised value "if appropriate." None of the VA materials we reviewed explain how VA handles either route today or what period it prescribes, so ask your lender before paying for another appraisal.

The 2024 interagency ROV guidance is not a VA rule

On July 18, 2024, five federal agencies (the Federal Reserve Board, CFPB, FDIC, NCUA, and OCC) issued final guidance on reconsiderations of value. VA is not one of them. The guidance covers transactions secured by a single 1-to-4 family residential property, and the agencies state that it "does not have the force and effect of law or regulation and does not impose any new requirements on supervised institutions."

What it offers are examples of policies a lender may adopt: plain-language notices telling consumers how to request an ROV, timelines for milestones, guidelines on when a second appraisal could be ordered and who assumes the cost, and protocols for telling the consumer the status and the lender's determination. The agencies declined to prescribe "a rigid, one-size-fits-all ROV process across institutions," and named VA's Tidewater procedure as an existing process institutions may consider. If your lender has its own ROV form or process, ask for it in writing.

The guidance also points to a regulation that does bind creditors, and it matters for an ROV because you need the report in hand. Under Regulation B, 12 CFR § 1002.14(a)(1), a creditor "shall provide an applicant a copy of all appraisals and other written valuations" on an application secured by a first lien on a dwelling, delivered "promptly upon completion, or three business days prior to consummation of the transaction" on closed-end credit, whichever is earlier. An applicant can waive that timing and agree to receive the copy at or before closing, so read anything you're asked to sign about appraisal delivery before you sign it.

If Tidewater and the ROV both fail

VA's toolkit lists two options alongside the ROV, and the escape clause adds a third.

The cancel option comes from 38 CFR § 36.4303(k). VA won't guarantee a loan on a covered contract signed before the veteran received notice of the reasonable value unless it includes a clause stating the purchaser "shall not incur any penalty by forfeiture of earnest money or otherwise be obligated to complete the purchase" if the price exceeds VA's reasonable value. The same clause keeps your option to proceed anyway. If you do, VA's escape clause page says the loan amount is capped at the lesser of the purchase price or the reasonable value. The full text and its limits are in our guide to the VA escape clause, and what happens to the deposit itself is covered under VA loan earnest money.

Bottom line

Know which track you're on. During Tidewater, speed matters: get sales data to the appraiser within 2 business days. After the Notice of Value, what counts is a clear request from you to VA, built on the full report and specific sales or factual errors. If neither moves the number and your contract carries the escape clause, a low value doesn't have to cost you your deposit. For the wider appraisal picture, start with the VA appraisal guide. If you'd like a VA-experienced specialist in your corner before the next appraisal, take the 2-minute eligibility check.