For conventional secondary market loans, Fannie/Freddie require a field review if the appraisal SSR score hits a certain level. Would a field review fee be a changed circumstance if incurred due to the high SSR score? We have a new MLO who insists that we have to eat the field review fee.

What does it have to do with the loan applicant? What is a SSR score? Sounds like something you need to take care of to sell the loan that has nothing to do with the borrower.

The Loan Collateral Advisor (LCA) score is generated by the Uniform Collateral Data Portal (UCDP) and found on the Submission Summary Report (SSR). There are three possible score messages:

• LCA Risk is assessed at [Risk Score] indicating a [Risk Level] of overvaluation.
• The appraised value may have a significant risk of undervaluation.
• LCA Risk could not be assessed for this submission. Please review the findings for additional information.

If you get the first message, the possible risk scores and risk levels are:

• 1 to 1.5 - Very Low (Appraisal is not missing critical data and the appraised value aligns with the AVM value generated by the agency)
• 2 to 2.5 - Low (Appraisal is not missing critical data and the appraised value aligns with the AVM value generated by the agency)
• 3 to 3.5 - Moderate (There is some risk of overvaluation considering the appraised value and the AVM value. There may also be certain appraisal defects. Consider the information and proprietary messages in the SSR to determine whether the appraisal provides sufficient information to support the analysis and conclusions and to determine next steps.)
• 4 to 4.5 - High (There is more significant risk of overvaluation considering the appraised value and the AVM value. There may also be critical appraisal defects. Consider the information and proprietary messages in the SSR to determine whether the appraisal provides sufficient information to support the analysis and conclusions and to determine next steps.)
• 5 - Very High (There is significant risk of overvaluation considering the appraised value and the AVM value. There may also be critical appraisal defects. Consider the information and proprietary messages in the SSR to determine whether the appraisal provides sufficient information to support the analysis and conclusions and to determine next steps.

Since the borrower does not select the appraiser, I don't think it is reasonable to charge the borrower for reappraisal. You may also want to consider an internal appraisal review before proceeding to re-appraisal, when that is permitted by Fannie/Freddie.