Fair lending is always a hot topic and then toss in the real estate appraisals, it can get even hotter! And now comes the Interagency Guidance that addresses Reconsideration of Real Estate Valuations or ROVs. We know that examiners are already laser focused on fair lending issues, but the appraisal issue mixed with a potential discrimination claim stemming from a lower-than-expected home value is something that every bank should be prepared for.
Does your bank already have a program to deal with issues like this?
Does your complaints program already categorize the different complaint reasons so that you can easily extract issues like this?
How does your appraisal review desk deal with a request from a customer when they feel like the appraiser came in way too low on the property value?
We will look at scenarios like this, including cases that have already settled, and find out what not to do so that your consumer real estate lending program will be better prepared for the “when”, not the “if” this situation arises.