This is a requirement that has been a long time coming in light of recent activity around appraisal bias and related issues. While there is no “one-size-fits-all” requirements here, it is paramount that lenders adopt appropriate policies, procedures, and processes around ROVs. Part of the challenge is understanding precisely what an ROV request is. It is important to note it is not only about bias – there are a number of reasons an appraisal may be flawed, and this broad application must be utilized when executing an ROV process.
There are a number of disclosure requirements that go along with this as well, as a means to notify customers that they have the ability to contest an appraisal if they wish. Then, what do you do if the appraisal is, in fact, fatally flawed? Should (or can) you order a new one? What about charging the borrower a fee for that second one? Doesn’t that fly in the face of appraiser independence?
In this webinar, we’ll address all these important questions, as well as provide practical advice on how to incorporate this critical new requirement into your lending program.
What You’ll Learn
- Many links to regulatory guidance – there is help out there!
- What exactly is a Reconsideration of Value request? What do I do once I receive one?
- Interplay with complaint management processes
- What is a “deficiency” that should be addressed?
- When can we get a second appraisal? Can/should we charge the borrower for it?
- Communications and working with appraisers
- Usage of third parties such as AMCs
- Utilization of AVMs and other automated solutions
- Interplay with appraiser independence
- Policies, procedures, and controls, including examples
- Disclosure to customers around their right/ability to request an ROV
- Resolving the ROV – it’s not always about getting a second appraisal
- Timelines – when should all this be done? Are there deadlines?
- Additional requirements for FHA and Fannie/Freddie lenders
Who Should Attend
This session is ideal for real estate lenders, compliance officers, auditors, underwriters, appraisers (in-house or external), closing agents, management, and anyone else involved in the real estate or residential lending process with a need to understand the current state of appraisal regulation and requirements.