Compliance: Data points covered by S. 2155 HMDA exemption

PAVE action plan includes reconsideration of value steps

March 23, 2022

The interagency task force on Property Appraisal and Valuation Equity (PAVE) released its Action Plan to Advance Property Appraisal and Valuation Equity Wednesday morning. CUNA has engaged with many of the 13 agencies that compose PAVE throughout the process on the need for assessing racial and other bias in the appraisals process.

The report outlines a series of action steps, including requiring agencies to issue guidance and implement new policies to improve the processes by which a valuation may be reconsidered if the initial valuation is lower than expected.

“A reconsideration of value (ROV) may be requested by consumers to reassess the analysis and conclusions of their initial appraisal when provided with additional information that may affect the value conclusion,” the plan reads. “Consumers can provide information to a lender during an ROV request that includes additional comparable property information and additional information pertaining to characteristics of the subject property, such as square footage.”

The plan notes that regulators including NCUA will issue guidance regarding ROVs.

“Issues that the agencies will consider addressing in the guidance would include examples of effective practices in using ROVs, and whether there are any measures that lenders can take to encourage greater use of ROVs,” the plan reads. “Prudential regulators will also review authorities and determine the potential for rulemaking related to ROV processes, as rulemaking would drive additional accountability beyond that of guidance.”