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Under federal law, mortgage lenders are required to work at arm’s length during the appraisal process, partnering with independent appraisal management companies who assign the work to state-licensed professional appraisers,” a spokesperson for Rocket told HousingWire.
Appraisal bias issues are more commonly discussed on the forward lending side of the mortgage business, but entities including the federal government and independent advocacy groups — including the National Consumer Law Center (NCLC) — have warned that appraisal bias could also impact seniors seeking a reverse mortgage.
The guidance, to be published in the Federal Register with a 60-day public comment period thereafter, “shows how ROVs intersect with appraisal independence requirements and compliance with applicable laws and regulations,” according to the announcement. The guidance also prioritizes appraisers’ independence and responsiveness to consumers.
The changes include communicating to applicants that they have the right to request a reconsideration of value (ROV); explaining why an ROV is denied or the valuation is unchanged; and training its credit, valuation and customer service staff on the topic.
HUD has also added new language to the section about potential second appraisals for the original mortgagee, incorporating language that describes “a potential violation of fair housing laws or professional standards related to nondiscrimination” as one such reason for initiating a second appraisal.
The task force report said that the appraisal industry “lacks clarity around its antidiscrimination obligations,” and so the Consumer Financial Protection Bureau , the Department of Justic e, the Department of Veterans’ Affairs and HUD will issue specific guidance on how fair housing law applies to the appraisal industry.
We followed the rules; we followed the law. We offered a reconsideration of value twice to the client. Emerson: I don’t think there’s anything we can do in the current environment with the way the laws and the rights are written. We did nothing wrong. Clarity must be brought to the industry.
But I digress… According to the Dodd-Frank law, and the HVCC before it, clients are allowed to challenge the appraiser’s value opinion by submitting what is termed in the law “appropriate” sales to be further reviewed, with the expectation that. White Paper: Requests for Reconsiderations The paper states that….
Lenders will need to understand implications to any policies, procedures, or practices associated with reconsiderations of value or the decision to obtain another appraisal. Both Fannie Mae and Freddie Mac are clear in their selling guides that certain conditions must be met if a lender decides to obtain multiple appraisals.
We’re excited to share some important updates regarding the Reconsideration of Value (ROV) process. Federal banking regulators and the GSEs have stressed the importance of financial institutions managing their relationships with service providers, including appraisers, to ensure compliance with consumer protection laws.
There is no law forbidding someone from paying more than the average market participant for a home unless the motive for doing so falls under money laundering, bribery, or some other equally nefarious scheme. Usually this is done via a document known as a “reconsideration of value” (ROV for short). How best to convey the facts?
The bank is required by law to provide a copy of the appraisal report to the borrower. There is always the possibility that the appraisal value is less than the contract price. If this is the case most banks and mortgage companies have a formal reconsideration of value process.
Highlights how financial institutions may create or enhance existing ROV processes that are consistent with safety and soundness standards, comply with applicable laws and regulations (including nondiscrimination requirements), preserve appraiser independence, and remain responsive to consumers. million Mortgage applications decreased 2.2
They alleged that the appraiser had taken into account their race in his valuation of their home in violation of the federal Fair Housing Act and other laws prohibiting discrimination. Connolly and Mott and for loanDepot.com filed a settlement with the court. There is a monetary component – which is confidential.
The finance giant will also begin training home lending advisors and client care specialists in the reconsideration of value process and fair lending issues related to appraisals. The Appraisal Institute , in fact, has said it will now require all appraisers to take a seven-hour course focused on Fair Housing laws and bias.
Excerpts: Suggested protocols for responding to Reconsideration of Value requests. Click here to listen to Tim Andersen, MAI’s podcast, “Reconsiderations of Value: Satan’s Own Seed, Right?” The architect Sandra Rishani told Insider no new structure can be built in its place because of zoning laws. 1826 Clement Ave.
This will save time, especially when consumers request a Reconsideration of Value. Again, who controls and regulates the data? Who controls the consumer’s data when it is collected on data collection apps, by Appraisal Management Companies, and by appraisal software providers?
Marty Green, a principal with the law firm Polunsky Beitel Green LLP, thinks that the board shakeups will accelerate Fannie and Freddies departure from FHFA conservatorship. The underwriter must provide the Appraiser with all relevant data that is necessary for a reconsideration of value. Property Acceptability Criteria (II.A.3.a)
Assessor, The R Word, HUD Appraiser Complaints March 14, 2025 Whats in This Newsletter (In Order, Scroll Down) LIA AD: Navigating value revisions in appraisals Why Is the Square Footage in Public Records Different from the Appraisal? In this role Miller, has helped pass over half-a-dozen laws protecting appraisers in Minnesota.
Broader questions have now been raised about potential new legal liabilities that businesses in the mortgage industry may be subjected to merely for following the letter of the law. When federal agencies bypass the law to advance a political agenda, it harms honest actors like Rocket and poses a threat to all consumers as well.
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