The NCUA, CFPB, and other federal regulatory agencies issued final guidance addressing reconsiderations of value (ROVs) for residential real estate transactions advising on policies and procedures financial institutions may implement to allow consumers to provide financial institutions with information that may not have been considered during an 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.
The guidance:
- Offers examples of ROV policies and procedures that a financial institution may implement to help institutions identify, address, and mitigate discrimination risk;
- Describes the risks of deficient residential real estate valuations; and
- Explains how financial institutions may incorporate ROV processes into risk management functions.
America’s Credit Unions’ legacy organizations commented on the proposed guidance noting that it should not create additional burdens for credit unions and other regulated entities.
