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The OCC, FRB, FDIC, CFPB and NCUA issued a joint proposed guideline on Reconsiderations of Values (ROV) of Residential Real Estate Valuations. This is just an interagency proposal, but because your bank has compliance obligations today under anti-discrimination laws and regulations, if you do not already have a compliance and risk management plan to deal with this issue, this proposal will certainly help you with interim steps to comply. But this is “just” a proposal, right. It absolutely is, but that doesn’t mean you can afford to wait on addressing the issues. One estimate is that appraisals come in low 20% of the time. That means 2 of every 10 of your mortgage loans that are about to hit your pipeline are hearing about getting a ROV. How will you react to that request?
Well let’s start with an overview of:
- The ROV process,
- What’s needed to contest a low value,
- Steps the bank and customer need to take to initiate an ROV,
- Possible outcomes and reactions,
- Factors influencing an ROV,
- Mistakes to avoid in ROVs,
- Who pays for this, and
- Key elements of the Proposed Guidance, plus more.
WHO SHOULD ATTEND:
Compliance, audit, Loan staff and anyone handling residential mortgages and appraisals.
Questions and Answers