VA Appraisal Comps: How Comparable Sales Are Chosen
VA appraisal comps are the single biggest factor in whether your purchase price holds up at closing. The appraiser pulls three to six recent sold properties within a reasonable radius, adjusts for differences in square footage, condition, lot size, and concessions, then lands on a fair market value. Deals get sideways when the comp pool is thin or the best comparables have seller concessions that force downward adjustments, leaving the appraised value short of the contract price.
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Before the Appraiser Pulls Comps
- The appraisal requires at least three comparable sales, and the appraiser selects them independently from MLS and public records.
- Every property must meet VA Minimum Property Requirements before the comp analysis even matters to the final value conclusion.
- Texas is a non-disclosure state, which limits publicly available sale price data and can slow the comp selection process significantly.
What the Appraiser Needs for Comps
- At least three comparable sales within a reasonable distance and timeframe, with sales beyond six months requiring written explanation from the appraiser.
- Prepare a list of recent closed sales near the subject property before the appraisal, especially in areas where public sale price data is limited.
- Having your agent identify backup comps early gives you use if the appraiser triggers a Tidewater notice and needs additional sales data fast.
How Long the Comp and Appraisal Process Takes
- The appraiser pulls three comparable sales from recent closings, typically within six months, though older sales may be used with explanation.
- If the value comes in low, the Tidewater notice gives your team a 2-business-day window to submit additional sales data before the report finalizes.
- From assignment to final report, most VA appraisals complete within two to three weeks, longer if a reconsideration of value is requested.
What a VA Appraisal Costs
- The VA sets maximum allowable appraisal fees by region, and the Veteran pays the fee upfront or rolls it into closing costs.
- A reconsideration of value after the initial report can add time and a second review fee depending on the lender’s process.
- Ordering your own comps through a licensed agent before the appraisal helps avoid surprises that trigger costly delays or renegotiation.
Top questions before you dig in
How many comps are required for an appraisal?
How picky are VA appraisers?
VA appraisers follow specific guidelines, not personal preference. They need three comparable sales ideally from the past six months, verify the property meets minimum property requirements for safety and structural soundness, and adjust comp values for concessions or condition differences. The process is standardized, not subjective.
What are the new VA appraisal requirements for 2026?
The VA still requires three comparable sales to establish value, and the appraiser must confirm the property meets VA minimum property requirements for safety and structural soundness. Concession adjustments on comps must reflect actual sale price impact, and any comp older than six months needs written explanation in the report.
The Bottom Line Up Front
The VA appraisal lives and dies on comparable sales. The appraiser does not decide your home’s value by walking through the kitchen. They pull recent closed sales from the same area with similar features, and those comps set the number. When good comps do not exist or the appraiser pulls from the wrong neighborhood, the value comes in low and the deal stalls.
The appraiser needs at least three comparable sales to build a defensible opinion of value. Sales beyond six months old require written explanation, and comps from a different school district or neighborhood can drag the number down even when the subject property is clearly worth more. If the value falls short, Tidewater gives your lender and agent a 2-business-day window to submit stronger sales data before the report finalizes. After the appraisal posts, a formal reconsideration of value is still available through the regional loan center.
- The appraiser needs at least three comparable closed sales to support the value.
- Comps pulled from the wrong neighborhood or school district can suppress the appraisal.
- Tidewater opens a 2-business-day window for your team to submit better sales data.
- Texas is a non-disclosure state, which limits the sales data appraisers can access.
- After the value posts, you can request a formal reconsideration through the regional loan center.
How the VA Appraiser Selects Comparable Sales
The appraiser needs at least three comparable closed sales to establish value, and the selection criteria are more specific than most borrowers expect. Recent sales from the same neighborhood carry the most weight, but the appraiser also adjusts for differences in square footage, lot size, condition, and features. When the local market is thin on recent activity, the search area and timeframe expand, which is where value disputes usually start.
- Recency matters most: The VA generally wants closed sales from within the past six months, stretching to twelve months only when recent activity is sparse. Older sales carry less weight and require larger market-condition adjustments that can drag the appraised value down.
- Proximity is flexible, not fixed: There is no set radius or distance requirement. The appraiser works outward from the subject property until comparable sales appear, but using sales from a different neighborhood or school district introduces adjustments that often skew value lower than local comps would.
- Bracketing keeps the value defensible: A strong appraisal brackets the subject property, meaning at least one comp sells above and one below the contract price. When all three comps sit below the purchase price, the appraiser has limited room to support value, and a low appraisal becomes far more likely.
- Adjustments are where deals get complicated: Every difference between the comp and the subject property gets a dollar adjustment. Seller concessions, garage additions, pool removals, lot size gaps. The commonly held view that concession adjustments are automatic dollar-for-dollar is wrong. Adjustments should reflect how much the concession actually impacted the sale price, not its face value.
When Comparable Sales Are Thin or Unavailable
Rural properties, unique homes, and new construction are the three scenarios where the appraiser struggles to find three comparable closed sales within a reasonable distance and timeframe. When comps are thin, the appraiser does not just guess. The report must explain exactly why the available comparables were selected, what adjustments were made, and why more proximate or recent sales were not used. That explanation section of the appraisal is where most value disputes start.
- Rural and acreage properties: The appraiser may pull sales from 10 or more miles away and across county lines when nearby closed transactions do not exist, but the report must document why those distant sales are the best available match for the subject property.
- Unique or custom homes: Properties with non-standard features like oversized lots, atypical square footage, or unusual construction materials force the appraiser to make heavy adjustments to each comp, which increases the chance the final value comes in lower than the contract price.
- New construction from plans: Proposed construction is appraised from plans and specifications or a model home rather than from traditional closed sales, and the appraiser relies on builder contracts and comparable new-build closings in the same subdivision or market area when available.
- Texas non-disclosure factor: Texas is a non-disclosure state, meaning sale prices are not part of the public record. Appraisers rely on MLS data and proprietary sources, which can create gaps in the comp pool that borrowers and agents never see until the report comes back.
New Construction and Builder Comps
Proposed construction is appraised from plans and specifications or a model home, not from a finished product the appraiser can walk through. That changes the comp picture entirely. The appraiser still needs three comparable closed sales, but finding them in a new subdivision where the builder controls all the pricing creates a problem most buyers and agents do not anticipate until the appraisal comes back short.
Builder-direct sales within the same subdivision are the obvious comp candidates, but they carry a catch. When the builder is both seller and price-setter, the appraiser has to determine whether those transactions reflect true market value or an artificial price point. Incentives like rate buydowns, closing cost credits, and upgrade packages muddy the actual sale price. The appraiser adjusts for those concessions, and when they do, the adjusted comp value can land well below the contract price on your deal. On files I work where new construction appraisals come in low, builder concessions buried in the original comps are the most common driver.
Texas makes this harder. Texas is a non-disclosure state, which means sale prices are not part of the public record. The appraiser cannot simply pull closed prices from county records the way they would in a disclosure state. They rely on MLS data, and if competing builders in the area sold direct without listing on the MLS, those transactions may not show up at all. That leaves the appraiser working with a thinner comp pool than the neighborhood’s actual sales activity would suggest. When you are buying new construction in a non-disclosure market, having your agent provide the lender with competing-builder sales data before the appraisal orders helps the appraiser build a stronger comp set from the start. Waiting until Tidewater to submit additional comps means you have already lost time and use in the negotiation.
Three Windows to Supply Comparable Sales
You get three separate chances to influence which comps shape the appraised value, and each window has different rules, different timelines, and a different level of use. The strongest move is supplying comps before the appraiser ever sets foot on the property. After that, your options narrow and the clock speeds up.
| Window | When It Opens | Who Submits | What You Provide | Timeline |
|---|---|---|---|---|
| Before assignment through the lender | Before the appraisal order is placed | Lender or agent through the lender | Three comparable closed sales supporting contract price, with addresses, sale dates, and adjustments noted | No formal deadline, but must reach the appraiser before the inspection |
| Tidewater | When the appraiser believes value may fall short, before finalizing the report | Lender relays to agent or borrower | Additional comparable sales data that supports the contract price | 2-business-day window to respond |
| Reconsideration of Value | After the Notice of Value is issued | Veteran requests in writing through the Regional Loan Center | Comparable sales the appraiser did not consider, with clear support for a higher value | Initiated after NOV issuance, takes three to five business days to process |
The comp selection that matters most on VA appraisals is when the appraiser pulls sales from a different neighborhood or school district that drag the value low. Providing strong local comps to your lender before the appraisal order goes out is the highest-use move because the appraiser sees your data before forming an opinion. Tidewater is reactive, and the ROV is a formal dispute after the number is already on paper.
How Texas Non-Disclosure Affects Appraisal Comps
Texas is a non-disclosure state, which means sale prices are not recorded in public deed records. The appraiser cannot pull county records and see what a home sold for. MLS data becomes the primary source for comparable sales, and if a sale never hit the MLS, the appraiser may never know it happened. This creates a comp environment where your agent’s preparation matters more than in most states.
Builder-direct sales and off-market transactions are the biggest gaps. A builder sells 40 homes in a subdivision, but if those sales closed through an in-house title company without MLS entry, the appraiser is working with incomplete data. For-sale-by-owner closings have the same problem. The appraiser relies on what is verifiable through MLS, and anything outside that system is difficult to confirm without extra legwork.
This is where the comp packet from your agent carries real weight. On files where the property sits in a neighborhood with limited MLS activity, the agent who pulls verified closed sales, includes MLS sheets with actual sale prices, and delivers that packet to the lender before the appraisal order gives the appraiser something concrete to work with. In a disclosure state, the appraiser has public records as a backstop. In Texas, the MLS-verified comp packet is the backstop. If your agent does not assemble one, the appraiser uses whatever comps are available, and those may come from a different subdivision or school zone that pulls the value in the wrong direction.
The Bottom Line
VA appraisal comps come down to three factors: how closely the comparables match your property in location, size, and recency of sale. The appraiser needs at least three closed sales, and the tighter those comps align with your subject property, the stronger your valuation. Rural properties, unique homes, and new construction all create comp gaps that force the appraiser to widen the search radius or make larger adjustments, which introduces more risk to the final number.
You get three separate windows to supply comparable sales before, during, and after the appraisal, and each one carries different use. The strongest move is submitting relevant comps before the appraiser goes out. In Texas, non-disclosure rules make this even more critical because the appraiser cannot pull sale prices from public records the way they can in most other states. Know your comp windows, use them early, and make sure every comp you submit actually supports your contract price.
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Frequently Asked Questions
What are the three S’s of a VA appraisal?
The three S’s are safety, soundness, and sanitation. The VA appraiser checks that the property meets minimum standards in all three areas before clearing the appraisal. Safety covers hazards like faulty wiring, missing handrails, or lead paint. Soundness means the structure is solid, the roof is functional, and major systems work. Sanitation covers working plumbing, a functional septic or sewer connection, and safe drinking water. If the property fails any of the three, the appraiser flags required repairs before the loan can close.
What are VA appraisal minimum property requirements?
VA minimum property requirements, or MPRs, are the baseline conditions a home must meet for VA financing. The property needs adequate roofing, functioning mechanical systems, safe electrical, no termite damage, proper drainage, and no health hazards. The appraiser also confirms the home has sufficient heating, a continuous water supply, and a working sewage system. These are not cosmetic standards. Peeling paint on a post-1978 home, exposed wiring, or a non-functional HVAC system will trigger repair conditions that must be resolved before closing.
What happens when there are not enough comparable sales for a VA appraisal?
A lack of strong comps is one of the harder problems in VA appraisals. When the appraiser cannot find three comparable sales within a reasonable distance and timeframe, they may expand the search radius, go back further in time, or adjust for differences more aggressively. In rural areas this is common. The risk is a lower appraised value because the comps used are less comparable to the subject property. In some cases, the property becomes nearly impossible to finance if no defensible value can be supported.
How does the Tidewater process work on a VA appraisal?
Tidewater is the VA’s early warning system when the appraiser believes the value may come in short. The appraiser notifies the lender, which opens a 2-business-day window for your lender and agent to submit additional comparable sales data before the appraisal is completed. This is your best shot at influencing the outcome. The comp selection that matters most is when the original appraisal uses sales from a different neighborhood or school district that pull the value down. Strong local comps submitted during Tidewater can correct that.
Can you dispute a low VA appraisal?
Yes. After the Notice of Value is issued, the Veteran may request a Reconsideration of Value in writing through the Regional Loan Center. Your agent provides additional comps not used in the original appraisal along with any supporting data that justifies a higher valuation. The ROV process is not a guarantee. The VA reviews the new information and decides whether the additional comps warrant a value revision. If the ROV fails, your options are renegotiating the purchase price, bringing cash to cover the gap, or walking away using the VA escape clause.
How does the VA handle appraisals on new construction?
Proposed construction is appraised from plans and specifications or from a model home rather than the finished product. The appraiser reviews the blueprints, lot location, and comparable new builds in the area to establish value. Once construction is complete, a final inspection confirms the home was built according to the approved plans. This creates a timing issue: if the market shifts between the initial appraisal and completion, the original value still stands unless a new appraisal is ordered. Builders familiar with VA loans understand this process.
Why is finding VA appraisal comps harder in Texas?
Texas is a non-disclosure state, meaning sale prices are not part of the public record. Appraisers cannot simply pull county records to verify what a home sold for. They rely on MLS data, which requires cooperation from agents and is not always complete. This makes comp verification slower and sometimes less reliable than in disclosure states. If you are buying in a newer subdivision or rural area in Texas, the comp pool shrinks further. Providing your appraiser with strong recent sales data through your lender before the inspection helps offset this limitation.
Where can I find a VA approved appraiser?
You do not choose your VA appraiser. The VA assigns appraisers through its fee panel rotation system managed by the VA portal. Your lender orders the appraisal, and the VA assigns the next available appraiser on the panel for that area. Neither the borrower, the agent, nor the lender gets to pick who shows up. This rotation exists to prevent pressure on appraisers to hit a target value. If you have concerns about the assigned appraiser’s familiarity with your market area, that is a conversation with your lender, not with the VA directly.