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Writer's pictureAnthony Johnson

New Guidelines Allow Consumers to Address Overlooked Information in Real Estate Appraisals

In a groundbreaking move, five federal agencies have introduced new guidelines for Reconsiderations of Values (ROVs) in residential real estate transactions. These guidelines allow consumers to submit additional information that may have been overlooked or to address deficiencies identified in initial property appraisals. This development aims to enhance property valuations' accuracy and fairness, which is crucial for homeownership and real estate transactions. By empowering consumers and financial institutions alike, the new guidance seeks to mitigate risks associated with deficient appraisals, ultimately supporting wealth-building opportunities through homeownership.



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New Guidelines Allow Consumers to Address Overlooked Information in Real Estate Appraisals

Five federal agencies have approved new guidance on Reconsiderations of Values (ROVs) in a significant development for residential real estate transactions. This new protocol empowers consumers to submit additional information that may have been overlooked or to address deficiencies identified in the initial appraisal.


ROVs are requests made by financial institutions to appraisers or other valuation-report preparers for a reassessment of a property's value. According to federal agencies, an ROV may be warranted if a consumer provides information that highlights potential deficiencies or other factors that could influence the property's estimated value.


  • Consumer Financial Protection Bureau (CFPB)

  • Federal Deposit Insurance Corp. (FDIC)

  • Federal Reserve Board (FRB)

  • National Credit Union Administration (NCUA)

  • Office of the Comptroller of the Currency (OCC)


It includes examples of ROV policies and procedures that financial institutions can implement. These measures aim to help institutions mitigate discrimination risks associated with real estate valuations. Additionally, the guidance elaborates on the dangers of deficient residential real estate valuations. It suggests how financial institutions can incorporate ROV processes into their risk management functions.


In the final report, the agencies emphasized the importance of credible collateral valuations, including appraisals, to the integrity of the residential real estate lending process. "Deficient collateral valuations can keep individuals, families, and neighborhoods from building wealth through homeownership by potentially preventing homeowners from accessing accumulated equity, preventing prospective buyers from purchasing homes, making it harder for homeowners to sell or refinance their homes, and increasing the risk of default," the report stated.



Importance of the New Guidance

The new guidance seeks to address and rectify deficiencies in the appraisal process that can have far-reaching consequences on homeownership and wealth-building opportunities. By allowing consumers to submit overlooked information or address deficiencies, the guidance aims to ensure more accurate property valuations, critical in various aspects of real estate transactions. These aspects include obtaining financing, accessing home equity, and determining fair market value for sales and refinances.



Public Comment and Future Implications

In June 2023, the agencies sought public comment on the proposed guidance, asking for input on what financial institutions should do if information was not considered during an original appraisal or if deficiencies are later identified. The feedback received from the public is expected to shape the implementation and refinement of the ROV processes, ensuring that they are practical and beneficial to consumers.


Adopting this guidance marks a proactive step toward enhancing the accuracy and fairness of real estate appraisals. It underscores the federal agencies' commitment to addressing potential biases and ensuring that all relevant information is considered in property valuations.


Conclusion

The new appraisal reconsideration guidance offers a pathway for consumers to address overlooked information or deficiencies in initial appraisals, promoting more accurate property valuations. Financial institutions can better manage risks by implementing these guidelines and contribute to fairer, more equitable real estate transactions. As this guidance is implemented, it is expected to help individuals and families build wealth through homeownership, thereby supporting broader economic stability and growth.

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