NAR commented on the Housing and Urban Development (HUD)'s Draft Borrower Request for Review of Appraisal Results ML.
NAR raised concerns that not limiting the number of comparable properties offered in the reconsideration policy could lead to abuse of the reconsideration process. Rather, NAR recommended following the VA's Tidewater process that limits that figure to three.
In addition, NAR recommended increasing consumer and agent awareness of the process as well as consumers' right to use the reconsideration process. Furthermore, NAR stressed that improving communication between the consumer or agent and the appraiser in advance of the appraisal will improve data sharing and reduce the need for reconsiderations of value.