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CFPB publishes blog post on ROV process for mortgage appraisals | PC Weiner Brodsky Kider

A recent CFPB blog post provides that mortgage lenders should have a non-discriminatory review of value (ROV) process when borrowers have concerns about the accuracy of an appraisal. While an individual lender’s ROV process may vary, the CFPB explains that responsible lenders provide all borrowers with clear, actionable information on how to raise concerns about the accuracy of an appraisal.

The blog post states that accurate appraisals are an integral part of home ownership, as overvaluation can reduce a home’s affordability, for example by making it harder to sell or refinance. Similarly, undervaluation can prevent a homeowner from accessing accumulated equity, whether through a sale or a home equity loan. The CFPB states that each lender’s ROV process must explain the benefits of a review to determine if a review is appropriate and must ensure that all borrowers have the opportunity to explain why they believe an appraisal is inaccurate. Additionally, lenders help ensure that their ROV process is non-discriminatory when they provide borrowers with clear, plain language notices about ROV opportunities. According to the CFPB, lenders who do not have clear and consistent ROV processes risk violating federal law.

Finally, the blog post indicates that the CFPB and other federal regulators are taking steps to ensure fair and accurate assessments. In addition to the CFPB’s actions to limit bias in algorithmic valuations, it and other regulators are members of the Interagency Working Group on Real Estate Valuation and Equity (PAVE). More information about PAVE is available here. Although this blog post does not have the same legal effect as a rule that has been the subject of notice and comment, it does indicate an area of ​​interest for the CFPB in the future.

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