This is not a question of legality; it is a question of appropriated appraisal practice. The appraiserâ€™s job is to determine the propertyâ€™s value as of a specific point in time. The appraisal report may indicate declining values, but appraiser should not negatively adjust the sales unless he can prove the amount of decline is accurate and prove that it will continue; the same goes for appreciating values. That proof should be included within the report itself. My experience indicates that values in the metro Denver are flat â€“ neither declining nor appreciating. Most likely, any differences in value from one property to another, at this point in time, is a result of differing attributes of each property and not the time period in which they sold. However, if the lender specificity asked the appraiser to forecast if the property would decline in value in the future he will have to comply; but, his forecast should be based on facts and not conjecture, and not just based on economic forecasts, rather it should be proven in the market. If it canâ€™t be proven in the market then the adjustment should not be made. Question the appraisal with the lender, ask for a copy and see how the adjustment was proven, ask for an appraisal review by an independent review appraiser, then you can decide an adequate course of action. I hope this is of some help. Feel free to call me, Mike Callis 303-563-9143 or email me at, email@example.com.