NAR submitted comments to the Consumer Financial Protection Bureau (CFPB) and the bank regulators on their request for input (RFI) proposing some improvements to the reconsideration of value (ROV) process.
The ROV process is critical for consumers to raise questions about potential errors or omissions in an appraisal and fundamental to confidence in the process.
- Recognizes the need for reforms and thanks the regulators,
- Agrees with the regulators that communication between the appraiser and consumer before the appraisal is critical,
- Emphasizes the need for the Federal Housing Administration (FHA) and Federal Housing Finance Agency (FHFA) to be included in the process,
- The Veterans Affairs (VA) Tidewater process is a good model as it includes a minimum threshold and standards to request an ROV, and
- Competency of the appraiser is critical, and the industry needs to do a better job of training, attracting, and retaining the best appraisers to keep errors and bias low.
Download NAR's Letter to the CFPB and Bank Regulators (PDF: 202 KB)