CUNA highlights potential challenges in ROV guidance

CUNA commended federal regulators for undertaking efforts to provide regulated entities with guidance on integrating reconsiderations of value (ROV) into their appraisal processes in comments filed Tuesday. CUNA’s comments were filed with NCUA in response to proposed interagency guidance on ROVs of residential real estate valuations.

“Credit unions oppose discrimination in the appraisal process, and ROVs can benefit both credit unions and their members by addressing any potential errors in an appraisal,” the letter reads. “Accurate appraisal values are necessary to ensure that credit unions are making lending decisions in a safe and sound manner, and accurate appraisal values can affect members’ ability to build wealth through homeownership.”

CUNA notes that two parts of the proposal could be challenging for credit unions to implement, policies and procedures to require:

• Monitoring multiple channels for ROV requests.
• Ensure credit unions’ lending and valuation staff are trained to identify prohibited discriminatory practices through the appraisal review.

“CUNA respectfully requests that NCUA and the Agencies exclude training staff to identify prohibited discriminatory practices through the appraisal review process as a proposed policy or procedure in the final guidance, or in the alternative to clarify that training to identify prohibited discriminatory practices is expressly limited to the language contained in an appraisal or other explicit statements made by an appraiser, because it goes beyond NCUA’s appraisal requirements and is unworkable,” the letter reads.