Consumer complaint received 2026-06-08 00:00:00
Product: Mortgage — Home equity loan or line of credit (HELOC)
Issue: Applying for a mortgage or refinancing an existing mortgage — Negative impact of inaccurate appraisal
Company: CITIZENS FINANCIAL GROUP, INC.
State: PA

Complaint narrative:
I am filing this complaint regarding Citizens Bank 's handling of a Reconsideration of Value ( ROV ) in connection with my HELOC application, which has resulted in an application decline I believe was based on a flawed appraisal and a procedurally deficient review process. Background I applied for a HELOC with Citizens Bank for my primary residence at XXXX XXXX XXXX XXXX, XXXXXXXX XXXX XXXX. The appraisal was conducted by Class Valuation ( Order # XXXX, XXXX ) and assigned to XXXX XXXX XXXX ( License # XXXX ), who is based in XXXX, XXXX, approximately five hours from XXXX. The appraised value came in at {$320000.00}, unchanged from my XXXX purchase price despite approximately {$110000.00} in documented capital XXXX and an estimated XXXX % annual appreciation in my neighborhood over that period. Specific Concerns Owner-occupancy misclassification. The appraisal listed the property as " Vacant. '' I am the owner and primary resident. The property was temporarily vacated only for hardwood floor installation. I submitted voter registration and utility bills confirming primary occupancy. This was never corrected. Appraiser geographic competency. The appraiser is based approximately five hours from XXXX with no documented knowledge of the XXXX XXXX XXXX XXXX The appraisal contains no disclosure of geographic competency concerns as required under the USPAP Competency Rule. Condition rating. The property was assigned a C3 ( Average ) condition rating, identical to all three comparable sales, despite more than {$110000.00} in capital improvements including a new roof, additional HVAC system, solid hardwood floors, custom trim and wainscoting, and bathroom renovations. A C2 ( Good ) rating is supported by the photographic evidence in the report itself. Comparable sales selection. All three comps sold in XXXX - XX/XX/XXXX, historically the lowest point of the annual real estate cycle, and are all materially smaller than my property ( XXXX sq ft vs. XXXX sq ft ). The appraiser acknowledged being unable to bracket the subject 's size. I provided more recent XX/XX/XXXX comparable sales, including XXXX XXXX XXXX, which sold for {$420000.00} in unfinished, physically damaged, as-is condition at XXXX sq ft, that better reflect current market conditions. None were incorporated. That represents a {$100000.00} gap between an adjacent property that is both smaller and sold in distressed condition, compared to my fully renovated home. Market Evidence Ignored Multiple independent sources place the property 's value significantly above {$320000.00}. XXXX estimates the current value at {$420000.00} with an estimated sale price range of $ XXXX {$480000.00}. The XXXX of XXXX 's own XXXX XXXX XXXX XXXX increased the assessed value from {$71000.00} in XXXX to {$500000.00} in XXXX, reflecting the neighborhood 's significant appreciation, a trend entirely absent from the appraisal. Neighboring properties on the same block carry XXXX estimates ranging from {$390000.00} to {$490000.00}. Procedural Failures The original XXXX communication from Citizens Bank stated : " The outcome will depend on the strength of the supporting documents you provide and the result of the review process. '' Despite this, I was never asked to provide any supporting documentation- not the capital improvement invoices I offered, not updated photographs I requested be taken. No documentation was ever requested from me at any point in the XXXX process. I submitted a formal ROV on XX/XX/XXXX identifying all XXXX disputes above. I received no written response to any of them. Instead I received the same unchanged appraisal report twice with no accompanying explanation. When I asked what was actually reconsidered, I was told Citizens policy does not permit connection to the XXXX department. My application was then declined with no substantive written explanation of the review outcome. Summary Citizens Bank initiated an ROV process, promised that outcomes would depend on supporting documentation, never requested that documentation, provided no written responses to any of my four specific disputes, and declined my application. I have no way of knowing whether a meaningful review took place. The combination of a flawed appraisal and a procedurally deficient XXXX process has resulted in the denial of a loan for which I may have otherwise qualified. I am requesting that the CFPB investigate Citizens Bank 's ROV process and require them to provide complete written documentation of what was reviewed and on what basis the value was upheld.

Company response to consumer: Closed with explanation