WASHINGTON–NCUA has joined with four other federal regulatory agencies in requesting public comment on proposed guidance addressing reconsiderations of value (ROV) for residential real estate transactions.
According to the agencies, which in addition to NCUA include the CFPB, FDID, Federal Reserve and OCC, the proposed guidance advises on policies that financial institutions may implement to allow consumers to provide financial institutions with information that may not have been considered during an appraisal or if deficiencies are identified in the original appraisal.
ROVs are requests from a financial institution to an appraiser or other preparer of a valuation report to reassess the value of residential real estate. An ROV may be warranted if a consumer provides information to a financial institution about potential deficiencies or other information that may affect the estimated value, the agencies noted.
An Intersection
“The proposed guidance shows how ROVs intersect with appraisal independence requirements and compliance with applicable laws and regulations,” the agencies said in a joint statement. “The proposed guidance describes how financial institutions may create or enhance their existing ROV processes while remaining consistent with safety and soundness standards, complying with applicable laws and regulations, preserving appraiser independence, and remaining responsive to consumers.”
In addition, the agencies noted the proposed guidance would describe the risks of deficient residential real estate valuations and how financial institutions may incorporate ROV processes into established risk management functions.
Inaccuracies & Errors
“Deficient collateral valuations can contain inaccuracies due to errors, omissions, or discrimination that affect the value conclusion,” the agencies said. “The proposed guidance would also provide examples of ROV policies and procedures that a financial institution may establish to help identify, address, and mitigate valuation discrimination risk.”
Comments must be received within 60 days of the proposed guidance’s publication in the Federal Register.