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2024-07-18 | FIL-41-2024

Agencies Finalize Interagency Guidance on Reconsiderations of Value for Residential Real Estate Valuations

The FDIC, Federal Reserve Board, NCUA, OCC, and CFPB issued final interagency guidance requiring financial institutions to implement or enhance reconsideration of value (ROV) processes for residential real estate appraisals. The guidance mandates that institutions identify and correct deficient valuations caused by errors, omissions, or prohibited discrimination while preserving appraiser independence and maintaining robust third-party oversight. Institutions must align these ROV procedures with safety and soundness standards, applicable consumer protection laws, and nondiscrimination requirements through targeted policies, control systems, and resolution mechanisms.

United States

Federal Deposit Insurance Corporation

Supervisory Guidance

July 18, 2024

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Summary: The Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, the National Credit Union Administration, the Office of the Comptroller of the Currency, and the Consumer Financial Protection Bureau (collectively, the agencies), are issuing final Interagency Guidance on Reconsiderations of Value (ROV) of Residential Real Estate Valuations in the Federal Register . The final guidance highlights the risks associated with deficient residential real estate valuations, particularly those that contain inaccuracies due to errors, omissions, or discrimination that affect the value conclusion. Additionally, the final guidance describes how financial institutions may incorporate effective ROV processes into established appraisal and evaluation programs, consistent with safety and soundness standards and all applicable laws and regulations, including those designed to protect consumers. Statement of Applicability: The contents of, and material referenced in, this FIL apply to all FDIC-supervised financial institutions. Highlights: Valuations are important to the integrity of the residential real estate lending process. Deficient valuations, including those that are deficient due to prohibited discrimination, can keep individuals, families, and neighborhoods from building wealth through homeownership, and may pose risks to an institution’s financial condition and operations. The guidance: Describes the risks of deficient residential real estate collateral valuations that remain uncorrected. Highlights how financial institutions may create or enhance existing ROV processes that are consistent with safety and soundness standards, comply with applicable laws and regulations (including nondiscrimination requirements), preserve appraiser independence, and remain responsive to consumers. Provides examples of policies, procedures, control systems, and complaint resolution processes that may help financial institutions identify, address, and mitigate risks of deficient valuations, including those that may have involved discrimination. Describes actions that financial institutions may take to resolve valuation deficiencies, including resolving the deficiencies with the appraiser or preparer of the valuation report; requesting a review of the valuation by an independent, qualified, and competent state certified or licensed appraiser; or obtaining a second appraisal or evaluation. Reminds financial institutions that the use of third parties in the appraisal review process does not diminish their responsibility to oversee those activities in the same manner as if they were conducted by the institution itself.

FIL-41-2024

Attachment(s)

Part 302 – Use of Supervisory Guidance

Part 323 – Appraisals

Part 364 – Standards for Safety and Soundness

Interagency Appraisal and Evaluation Guidelines

Interagency Guidance on Reconsiderations of Value of Residential Real Estate Valuations