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Reconsideration of Value in Tennessee: A Complete Guide

Everything Tennessee homeowners need to know about disputing a low appraisal, including state-specific regulations, TREAC filing procedures, and regional market considerations.

February 4, 202610 min read

You got a low appraisal on your Tennessee home. The purchase is in jeopardy. And now you're wondering: what's different about Tennessee's process? What are my specific rights in this state?

If you're a Tennessee homeowner facing appraisal challenges, you need to understand Tennessee-specific regulations, filing procedures, and state resources. The basic ROV process is the same everywhere, but Tennessee has some unique requirements and advantages you need to know about.

This guide covers everything Tennessee homeowners need to know about Reconsideration of Value, state regulations, filing complaints, and Tennessee-specific market considerations.

Tennessee's Appraisal Regulatory Framework

In Tennessee, appraisers are licensed and regulated by the Tennessee Real Estate Appraiser Commission (TREAC), which operates under the authority of the Tennessee Code Annotated, Title 62, Chapter 1.

Key facts:

  • TREAC oversees all appraiser licensing and discipline
  • Appraisers must follow USPAP (Uniform Standards of Professional Appraisal Practice) as adopted and interpreted by Tennessee
  • All appraisers on federally-related transactions must be state-licensed (that's essentially all appraisals tied to mortgages)
  • Tennessee requires continuing education: Licensed appraisers must complete 28 hours of continuing education every 2 years

    • This matters because it means Tennessee has enforcement mechanisms. If an appraiser violates professional standards, you have recourse beyond just disputing with your lender.

    The Tennessee ROV Process

    The fundamental ROV process in Tennessee is the same as nationwide:

  • Receive low appraisal
  • Identify specific errors
  • Prepare ROV letter with evidence
  • Submit through your lender (or directly to appraiser with lender copy)
  • Appraiser reviews and responds (5-15 days)
  • Value revised or stands as-is

    • But Tennessee has some specific requirements and considerations:

    Tennessee-Specific ROV Timing

    Most lenders operating in Tennessee follow GSE (Fannie Mae/Freddie Mac) guidelines, which mandate:

  • 5-15 business days for appraiser response to ROV
  • Clear documentation of the reconsideration request
  • Written response from appraiser explaining their decision

    • Tennessee law doesn't establish specific ROV timelines, so lenders use federal standards. However, many Tennessee lenders are regional banks and credit unions that have their own policies. Always ask your lender specifically:

  • "What is your ROV timeline?"
  • "Can you provide their policy in writing?"

    • Who Can File an ROV in Tennessee

    In Tennessee, an ROV can be initiated by:

  • The borrower (you)
  • The real estate agent
  • The seller
  • The lender

    • However, lenders are most likely to take ROV seriously. If your lender submits it, there's an official stamp of credibility. If you submit directly to the appraiser, include a copy to your lender so they're aware.

    USPAP in Tennessee: What's Unique

    Tennessee adopted USPAP as the professional standard for all state-licensed appraisers. However, Tennessee's Real Estate Appraiser Commission has issued specific guidance and interpretations that Tennessee appraisers must follow.

    Key Tennessee USPAP Guidance:

  • Scope of Work Requirements: Tennessee appraisers must clearly define scope before beginning. Limited inspections or valuations must be explicitly disclosed and justified.
  • Comparable Property Standards: Tennessee guidance emphasizes that comparables must be truly comparable in market, location, and property characteristics. Using properties from significantly different markets requires adjustment or justification.
  • Market Analysis Requirements: For residential appraisals, Tennessee requires consideration of recent neighborhood sales (3-6 months) unless justified otherwise.
  • Professional Ethics: Tennessee's adoption of USPAP includes strict anti-bias requirements. Appraisers cannot let personal preferences, market assumptions, or demographic factors influence their analysis.

    • Why this matters for you: If a Tennessee appraiser violates these standards, you have clear grounds for complaint to TREAC and for ROV.

    Tennessee Market-Specific Considerations

    Tennessee has distinct regional markets that affect appraisals:

    Nashville Metropolitan Area

  • Market characteristics: Rapidly growing, appreciating market with strong demand
  • Appraisal considerations: Properties often appreciate faster than comps reflect. If your appraisal used older comps, it's likely too conservative.
  • School district factor: Nashville has significant variation in school district quality. Out-of-district comps should require adjustment.
  • Recent development: New neighborhoods and redeveloped areas may not have sufficient comparable sales. Watch for appraisers using generic comps.

    • Memphis Metropolitan Area

  • Market characteristics: Moderate growth, diverse neighborhoods, significant variation in property values
  • Appraisal considerations: Comps must be carefully matched to neighborhood. A property in East Memphis is very different from one in Midtown, despite proximity.
  • School district factor: Very significant. Shelby County Schools' quality varies. Appraisers must use same-district comps.
  • Economic factors: More sensitive to market trends and economic indicators. Commercial district proximity affects residential values.

    • Knoxville Metropolitan Area

  • Market characteristics: Moderate appreciation, balanced market, strong demand in specific neighborhoods
  • Appraisal considerations: University of Tennessee proximity affects property values in central Knoxville. Appraisers should account for this.
  • Historic neighborhoods: Many historic neighborhoods (Fort Sanders, Sequoyah Hills) have unique characteristics requiring special consideration.
  • School district factor: Knox County Schools quality varies significantly. East Knox districts are generally stronger than West Knox.

    • Secondary Markets (Chattanooga, Clarksville, Tri-Cities, Jackson)

  • Market characteristics: Smaller markets, potentially fewer recent comparable sales
  • Appraisal considerations: Limited comparable sales can force appraisers to use less-comparable properties. Be particularly vigilant about comp selection.
  • Regional factors: Proximity to military bases (Clarksville), universities (Chattanooga), or employment centers affects values.

    • Action for your ROV: If your appraisal uses comps from a different market segment or area, this is a key argument. "Your appraisal included comparables from [different area] when better-matched comparables exist in [neighborhood/district]."

    Tennessee-Specific Comparable Property Considerations

    When researching comps for your Tennessee ROV, use Tennessee-specific resources:

    Tennessee MLS Systems

  • Multiple MLS systems serve different regions (Nashville, Memphis, Knoxville, etc.)
  • Work with a real estate agent in your area to access your local MLS
  • MLS data is the gold standard for appraisers

    • Tennessee County Records

  • Online access: Tennessee offers online property record searches through county registers' offices
  • Property details: Tax records, deed records, previous sales
  • County-specific sites:

    • - Davidson County (Nashville): Assessor.davidson.tn.gov

    - Shelby County (Memphis): Register.shelby.tn.us

    - Knox County (Knoxville): Knox.tn.gov (assessor office)

    Tennessee-Specific Market Data

  • TREAC market data: The Real Estate Appraiser Commission publishes guidance on market conditions
  • Real estate association reports: Your local association of Realtors may publish market trends
  • Tennessee economic data: The state's economic development office publishes market reports

    • Public Record Searches

  • Zillow, Redfin, Trulia: These aggregate Tennessee data and can help identify recent sales
  • County courthouse records: Some Tennessee counties have online deed recording
  • Tax assessor websites: Most Tennessee counties offer property tax assessments online

    • For your ROV: When presenting Tennessee comparable properties, cite the source. "Based on MLS data for [neighborhood/zip code], recent sales include..." is more credible than "Based on Zillow."

    Filing a Complaint with TREAC

    If your ROV is denied and you believe the appraiser violated professional standards or USPAP, you can file a formal complaint with the Tennessee Real Estate Appraiser Commission.

    TREAC Contact Information

  • Address: 500 James Robertson Parkway, Suite 500, Nashville, TN 37243
  • Phone: (615) 741-1831
  • Website: https://www.tn.gov/commerce/trec/appraisers.html
  • Email: Check website for complaint procedures

    • Complaint Process

  • Gather documentation: Your appraisal, your ROV, the appraiser's response, and evidence of the violation
  • Identify the violation: Specific USPAP standard or professional requirement violated
  • File complaint: Submit to TREAC with all supporting documentation
  • TREAC investigation: Commission investigates (typically 30-60 days)
  • Appraiser response: Appraiser is asked to respond
  • Determination: Commission determines if violation occurred
  • Discipline: If violation found, ranging from warning to license suspension/revocation

    • What Violations Can You Complain About?

  • Scope of Work violations: Appraiser didn't perform adequate inspection or research
  • Comparable property violations: Used improper comparables, didn't research adequate options
  • USPAP violations: Failed to follow professional standards
  • Bias or unprofessional conduct: Actions suggesting bias or conflict of interest
  • Misrepresentation: False statements in the appraisal or professional communications

    • Important Considerations

  • Timeline: Complaints should be filed within reasonable timeframe (within 1-2 years ideally)
  • Documentation: You need specific evidence of violation, not just disagreement with opinion
  • Outcome timing: Investigations take 2-6 months, not resolved before your closing
  • Your current transaction: Filing a board complaint doesn't automatically resolve your current appraisal. It creates a formal record and may lead to appraiser discipline, but it's slow.

    • TREAC complaints are best for: Serious violations (bias, scope failures, USPAP breaches) where you want to protect other homeowners and create an official record.

    Tennessee Lender-Specific Considerations

    Tennessee has several large mortgage lenders and regional players. Each may have slightly different ROV procedures:

    Mortgage Companies Operating in Tennessee

  • National lenders: Fannie Mae, Freddie Mac conforming loans (via sellers)
  • Regional lenders: Tennessee Commerce Bank, FirstBank, SmartBank
  • Credit unions: Multiple Tennessee credit unions with their own appraisal policies
  • Mortgage brokers: Many independent mortgage brokers operate in Tennessee

    • Key point: Always ask your specific lender about their ROV procedures, timelines, and escalation pathways. Procedures vary.

    Questions to ask your Tennessee lender:

  • "What is your ROV submission process?"
  • "What documentation do you require?"
  • "What is your timeline for appraiser response?"
  • "If ROV is denied, can I request a desk review?"
  • "Can I order a second appraisal?"
  • "What is your loan-to-value flexibility if appraisal is low?"

    • Tennessee School District Appraisal Impact

    Tennessee property values are heavily influenced by school district quality. This is critical for your appraisal:

    Major Tennessee School Districts

  • Nashville-Davidson: Metropolitan District with varying quality by area
  • Shelby County (Memphis): Suburban districts often different from city
  • Knox County (Knoxville): East Knox districts (Turkey Creek, Rocky Hill) valued higher than West Knox
  • Williamson County (Franklin): Highly desirable, commands premium

    • Appraisal Implications

    If your appraisal uses comparables from a different school district, this is a major error argument for your ROV.

    Example: "Subject property is in [School District A]. Appraisal includes comparable from [School District B]. Market analysis shows properties in School District A command [X%] premium. Comparable should be adjusted accordingly."

    Tennessee school district boundaries are sometimes complex and cross-zoned. Verify your property's exact school assignment before citing this in your ROV.

    Second Appraisals in Tennessee

    If your ROV is denied and you want a second opinion, Tennessee has no state-specific restrictions on second appraisals. Your lender will typically:

  • Allow you to order a new appraisal (you pay, typically $400-$600)
  • Use the average of two appraisals for loan decision
  • Or use the higher appraisal in some cases

    • Tennessee considerations:

  • Appraisal companies: Multiple AMCs (Appraisal Management Companies) operate in Tennessee
  • Turnaround time: Tennessee appraisals typically complete in 5-7 days
  • Appraiser selection: Ask your lender if they can request a Tennessee appraiser familiar with your specific market

    • Tennessee-Specific Market Documents

    For your ROV, Tennessee market documents carry weight:

    Useful Sources

  • Nashville Area Association of Realtors market reports: Published monthly, widely cited
  • Memphis Area Association of Realtors market data: Regional trend analysis
  • Knoxville Area Association of Realtors reports: Knox County market conditions
  • Tennessee Council of Realtors statewide reports: State-level market analysis
  • Chamber of Commerce economic reports: Nashville, Memphis, Knoxville chambers publish economic data
  • University of Tennessee Extension: Agricultural economics department sometimes publishes rural property market analysis

    • For your ROV: Cite these sources. "According to the Nashville Area Association of Realtors market report for [month], neighborhood median sale price is $X."

    Tennessee-Specific ROV Letter Template

    Here's a Tennessee-focused ROV letter structure:

    ```

    [Date]

    [Appraiser Name]

    [Company]

    [Address]

    Re: Reconsideration of Value Request

    Property: [Address], [City], Tennessee [Zip]

    Appraisal Date: [Date]

    Lender: [Your Lender Name]

    Dear [Appraiser Name]:

    I am requesting reconsideration of the appraisal dated [date] for the above-referenced

    property. Based on documented errors and additional market information, I believe the

    appraised value does not accurately reflect the property's market value in the current

    Tennessee market.

    SPECIFIC ERRORS:

  • Comparable Property Selection - Market and District Considerations

    • Issue: Appraisal includes comparable properties from [different school district/market area]

    when better-matched comparables exist within [subject school district/neighborhood].

    Evidence: According to [market report/MLS data], properties in [subject district] command

    an average [X]% premium to [comparison district]. Better-matched comparables:

    - [Address]: Sold [date] for $[price] (same district, similar size)

    - [Address]: Sold [date] for $[price] (same neighborhood, comparable condition)

    Impact: Using same-district comparables supports higher market value.

  • Property Description/Feature Errors

    • [Specific error - e.g., missing kitchen renovation, incorrect square footage]

    Evidence: [County records/Photos/Receipts]

    Impact: $[Amount]

    Based on corrected analysis, appraised value should be $[amount].

    Respectfully,

    [Your Name]

    [Your Phone]

    [Your Email]

    Enclosures: [List supporting documents]

    ```

    When to Escalate in Tennessee

    If your ROV is denied in Tennessee:

    Option 1: Desk Review (2-4 weeks)

  • Ask your lender to request desk review
  • Tennessee lenders typically allow this

    • Option 2: Second Appraisal (5-10 days)

  • Order new appraisal from different Tennessee appraiser
  • Lender uses average or higher value

    • Option 3: TREAC Complaint (30-90 days)

  • File formal complaint with Tennessee Real Estate Appraiser Commission
  • Creates official record
  • Won't resolve current transaction but may discipline appraiser

    • Option 4: Negotiate or Walk (immediate)

  • Negotiate with seller to reduce price
  • Walk away if gap is too large

    • Tennessee-Specific Resources

    Bookmark these Tennessee appraisal resources:

  • TREAC (Tennessee Real Estate Appraiser Commission)

    • - Website: tn.gov/commerce/trec/appraisers

    - Licensing, complaint procedures, appraiser lookup

  • Tennessee Register of Deeds Association

    • - Directory of county register offices

    - Links to online record searches

  • Tennessee Realtor Associations

    • - Nashville Area: nvar.org

    - Memphis: midsouthrealtors.org

    - Knoxville: knoxvillearea.org

  • County Tax Assessors

    • - Online property record searches

    - Tax valuations and assessments

  • County Clerk's Office

    • - Deed records and historical sales data

    The Bottom Line: Tennessee-Specific Action Plan

    If you're a Tennessee homeowner facing a low appraisal:

  • File your ROV through your Tennessee lender with documentation specific to Tennessee market, school districts, and recent comparable sales
  • Research Tennessee school district impact and cite it if applicable
  • Use Tennessee-specific comparables from your local MLS and market
  • If ROV fails, request desk review from your lender
  • If violations exist, file with TREAC for formal record
  • If needed, order second appraisal from Tennessee appraiser familiar with your market

    • Tennessee has strong professional standards, good regulatory oversight through TREAC, and multiple options for dispute resolution. You have tools and pathways. Use them.

    ---

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