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

The regulatory agencies, as well as HUD, FHFA, Fannie Mae, and Freddie Mac, recently issued their Final 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.

Upcoming
Monday, January 13th, 2025
10:00 am - 12:00 pm
Presented by Carl Pry
2.5 CRCM Credits
$299.00 or 1 Token

Includes: Live Access, 30 Days OnDemand Playback, Presenter Materials and Handouts

  • Compliance
  • Lending
  • Lending Compliance
  • Branch Manager
  • Compliance Officer
  • Consumer Lender/Retail Banker
  • Internal Auditor
  • Loan Closer
  • Loan Operations Manager/Specialist
  • Senior Management
  • Training Manager
  • Trainer

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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.


Carl Pry

Instructor Bio

Carl Pry is a Certified Regulatory Compliance Manager (CRCM) and Certified Risk Professional (CRP) who is a Senior Advisor for Asurity Advisors in Washington, DC. Through his more than 30-year working career, as well as through his experience as a banking attorney and officer, he has provided a variety of regulatory compliance and financial performance services to financial institutions and other clients throughout the country. He has written extensively regarding consumer and commercial compliance, tax, audit, and financial institution legal issues, and is a frequent contributor to and currently serves as the Chair of the Editorial Advisory Board for the ABA Bank Compliance magazine. He has spoken at scores of banking, compliance, and state bar associations, and has conducted training sessions for financial institutions across the country.


Continuing Education Credit Information

Reconsiderations of Value (ROVs): Regulatory Expectations and How to Put Together Your Process has been approved for 2.5 CRCM credits. This statement is not an endorsement of this program or its sponsor. Credits are redeemable for both Live and OnDemand viewing. For questions on certificates, please email support@oncourselearning.com. Certification holders must report these credits at https://aba.csod.com.