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Reconsiderations of Value (ROVs) – Regulatory Expectations and How to Put Together Your Process
February 04, 2025
Program Overview
The regulatory agencies, as well as HUD, FHFA, and 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.
This has been a requirement that 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 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 Will 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.
Date & Time
February 4, 2025
9:50AM Zoom Sign In | 10:00AM Webinar Start | 12:00PM Webinar Concludes
Who Should Attend?
Compliance Officers & Staff, Lending Officers, Residential Lenders
Continuing Education
2 Professional CE Credits
Agenda
Speakers
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Carl Pry
<p>Carl Pry, a Senior Advisor at Asurity Advisors, is a seasoned executive with banking law, corporate finance, and regulatory compliance experience in Fortune 500 institutions, regional banks and industry consulting firms. Carl advises clients on consumer and commercial compliance, fair lending, operations, risk, corporate treasury, and risk management.</p><p>Over the last thirty years, Carl has held senior leadership positions including Managing Director and Senior Advisor at a boutique regulatory compliance consulting firm, Senior Vice President and Compliance Manager for the Compliance and Control Division at KeyBank, Manager of Finance and Performance Management Service Line at Accenture, and Vice President of Regulatory Services at Kirchman Corporation. With strong knowledge and experience as a banking attorney and officer, Carl is a frequent contributor to and currently serves as the Co-Chair of the Editorial Advisory Board for the ABA Bank Compliance magazine. As a featured speaker for numerous banking, compliance, and state bar associations, he has led hundreds of training sessions across the country. Carl has served as an instructor at FDIC examiner school and back-up instructor for NCUA examiner school. He has authored training programs covering consumer and commercial compliance, Compliance Management Systems, audit, quality control, tax, privacy and risk management. He also serves as a frequent expert witness in litigation matters.</p><p>Carl is a regular columnist for the ABA Bank Compliance magazine. He has authored scores of articles on financial issues and developed testing and support materials for both the ABA’s Certified Regulatory Compliance Manager (CRCM) and BAI’s Anti-Money Laundering Professional (AMLP) certifications, and served as subject matter expert for web-based compliance and audit educational testing programs for banking training firms. He is the author of “Internet Banking Manual”, a comprehensive guide to business planning, risk analysis and maintaining a presence for financial institutions on the Internet. For LexisNexis, he also authored “The New RESPA Rule: Navigating New Disclosures” and “The Evolution of Reg. Z: Increased Duties and Responsibilities for Lenders,” among other publications.</p><p>Carl holds a JD and an MBA from the University of Toledo and a BSBA from Bowling Green State University. He is also a Certified Regulatory Compliance Manager (CRCM) and Certified Risk Professional (CRP).</p>
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