Federal Agencies Finalize Guidance on ROVs in Residential Transactions

The CFPB, FDIC, Federal Reserve, NCUA, and OCC recently issued final interagency guidance on reconsiderations of value (ROVs) in residential real estate transactions.

The guidance highlights risks associated with deficient appraisals; provides examples of ROV policies and procedures that a financial institution may implement to identify, address, and mitigate discrimination risk; and explains how financial institutions may incorporate ROV processes into existing risk management functions.

The guidance is final upon publication in the Federal Register.  The final guidance is largely unchanged from the proposed guidance, which WBK previously covered here and here.