Reconsiderations of Value (ROVs): Regulatory Expectations and How to Put Together Your Process
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.
