They have already done that;- below is the next round of clamping ( in my email today). My objection is that they ignore the fact that 90% of the ROV from a client is the lender or parties pushing for a higher value ( and the assumption that the appraisal is deficient) Then they double down with the assumption that bias is an actual problem to be reported when no evidence of the kind exists. All this mandatory reporting is from their side; where is the appraisal process to report client misconduct with the ROV process? ( like the old, never enacted line, buried in the Bermuda Triangle )? Meanwhile, one can steal billions and get a slap on the wrist, but appraisers must get reported for a perceived error to punish them for l...what? Doing their job for sub par fees? Why would anyone in their right mind enter the field at this point? Those already appraising for res lending end will likely be gone in a few years or sooner if one of us gets reported - (for some infraction or other, even USPAP states perfection does not exist yet they will report fro the smallest of anything they want it seems not just in the appraisal but in the ROV )
RECONSIDERATION OF VALUE (ROV) PROCESS
Effective August 29, 2024
Freddie Mac, in collaboration with Fannie Mae and HUD, is implementing requirements related to reconsideration of value (ROV) that promote consistency when a perceived appraisal issue and/or appraisal deficiency exists. These requirements also recognize the importance of the Borrower having the knowledge and opportunity to request an ROV. The Seller must have policies and procedures in place addressing Seller or Borrower requests for ROVs, and the policies and procedures must include, but are not limited to, the following:
- A review and resolution procedure for an ROV request, including steps for the Borrower(s) to appeal an appraisal report’s findings when the Borrower(s) believes the appraisal report or the appraiser’s opinion of value is unsupported, may be deficient due to an unacceptable appraisal practice or reflects discriminatory practices
- A process for disclosure of the ROV process to the Borrower(s) and instructions for initiating an ROV request
- A standardized format for communicating the rationale, requirements and supporting documentation to the appraiser
- Instructions for the appraiser to deliver a revised appraisal report that includes specific commentary explaining their conclusions to the ROV request
- Turn-time expectations for communicating results of the ROV to the Borrower
- A requirement for the retention of all documentation and communications related to the initiation and outcome of the ROV in the Mortgage file
This update also requires the Seller to:
- Forward the appraisal report, along with a summary of findings, to the appropriate appraisal licensing agency or regulatory board if material deficiencies are identified in the appraisal report that are not corrected or addressed by the appraiser upon request or if there is evidence of unacceptable appraisal practices. In addition, if there are suspected overt violations of antidiscrimination laws, the Seller must report them to the proper local, State or federal agency.
- Ensure valuation and related staff, inclusive of third parties, are trained to identify prohibited discriminatory practices and appraisal deficiencies through the valuation review and ROV processes. The Seller must have a process for remediating these deficiencies.
Freddie Mac is evaluating methods for future tracking of Mortgages originated where an ROV was obtained. More information will be provided as it becomes available.
