Appraisal Bias, Reconsiderations of Value (ROVs), and Automated Valuation Models (AVMs): Regulatory Expectations and How to Put Together Your Valuation Process
In 2024, the regulatory agencies issued instructions to examiners on examining lenders’ processes for ensuring the valuations they accept are credible. They also issued interagency guidance on ROVs, which creates clear expectations on mortgage lenders to formulate and execute programs to provide customers with access to ROV requests, as well as how to handle them once received. It is important to note that this guidance has not been rescinded by the new administration. HUD, FHFA, and Fannie Mae and Freddie Mac have issued guidance over the past few years as well, although some of this has been changed. This is an issue that has been a long time coming in light of reported activity around appraisal bias and related issues. While there is no “one size fits all” requirements here, it is important 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 also a number of disclosure requirements that go along with this, 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.
