Our 120 day FHA pre-foreclosure (ATP) period expired last Thursday, with US Bank stuck on 2 appraisals that are easily 20% higher than actual comps for the area.  This home is on some pretty bad acreage ...untillable, and located way out in the country.  The US Bank appraiser is using several comps in nearby towns that are closer to a large metro area, and therefore pricier.  We've given US Bank REAL comps, just a few weeks into the pre-foreclosure program, and again, just before the program expired last Thursday.  The negotiator now tells me that 1) the comps we provided are unconvincing, and 2) they can't extend the FHA pre-foreclosure program by 60 days (as Tier 1 participants, like US Bank may do) without an offer.  She went on to tell me that the "I can not grant an extension without a valid offer.  I sent the appraisal value dispute and the value did not change.  I will have to deny the short sale.", this after I informed her that I would escalate to HUD.

Any suggestions other than escalation to HUD? 

Thanks in advance!