HUD Appraisal Value Reconsideration


On May 1, HUD guidance to protect borrowers from appraisal bias.


  • HUD issued Letter 2024-07, INFO 2024-24, appraisal reconsideration of value (ROV).
  • Update as a result of draft letter on borrower request for appraisal review, #160192.
  • FHFA reported ROV process for Fannie (#210750) and Freddie (#210584), #210755.
  • Reconsideration of Value
  • Updated Single Family Housing Policy Handbook 4000.1 on new ROV guidance.
  • Apply to FHA Single Family Title II forward and Home Equity Conversion Mortgages.
  • Lenders must disclose to borrowers that they may request an ROV with instructions.
  • Including what information will be required and the expected ROV processing times.
  • Disclosures must be provided at time of application and presentation of the appraisal.
  • New policy includes a requirement that underwriters be trained to identify and remedy appraisal deficiencies, including racial and ethical bias; ROV status communications.
  • Standards for lender quality control of appraisal reviews and reconsiderations of value.
  • Also, standards for appraisers to respond to requests from lenders for ROV review.
  • Effectiveness
  • Must be implemented for FHA case numbers assigned on or after Sep. 2, 2024.
  • Jul. 2024 HUD FHA ROV Policy
  • On Jul. 2, 2024, HUD issued FHA INFO 2024-43 regarding FHA ROV policy updates.
  • Updated FHA Connection (FHAC) system and an industry stakeholder briefing webinar as part of the implementation of appraisal ROV updates ML 2024-07 issued on May 1.
  • FHA modified FHAC for forward and Home Equity Conversion Mortgages (HECM).
  • A sub-section titled Borrower Request for Appraisal Review Information will be added to the Endorsement information section of the Insurance Application screen.
  • Mortgagees must respond to questions on appraisal request, basis, request resolution.
  • New functionality will be available for case numbers assigned on or after Sep. 2, 2024.
  • FHAC guide updated with instructions for borrower request for appraisal review.
  • Mortgagees must retain all documentation associated with an ROV in FHA Case Binder.
  • Industry stakeholder briefing webinar on ROV guidance to be held on Aug. 1, 2024.
  • Aug. 2024 Fannie Extended Implementation Date
  • On Aug. 6, 2024, HUD issued Letter 2024-16 to extend the implementation date for development of a framework for lenders to review ROV updates, to Oct. 31, 2024.
  • Feedback gathered after the initial ROV announcement revealed more time needed for lenders to meet all the elements outlined in the policy, so was extended by 60 days.
  • HUD also extended the implementation of the mortgagee letter (ML) 2024-07.
  • Lenders should implement the ROV policy immediately but must do so for loans with applications, and FHA case numbers re ML 2024-07, dated on or after Oct. 31, 2024.
  • Oct. 2024 HUD FHA FAQs
  • On Oct. 10, 2024, HUD reported FHA posted questions and answers (FAQs) from Aug. 8, 2024, webinar, to address inquiries on ML 2024-07, Appraisal Review and ROV.
  • Mortgagees reminded that while provisions in ML 2024-07 may be implemented immediately, must implement for FHA case numbers assigned on, after Oct. 31, 2024.

Regulators HUD
Entity Types Bank; CU; MG Orig; Servicer; Thrift
Reference FHA INFO 2024-70, FAQ, 10/10/2024; Lt 2024-16, FHA INFO 2024-54, 8/6/2024; PR FHA INFO 2024-43, 7/2/2024; PR 24-096, Lt 2024-07, FHA INFO 2024-24, 5/1/2024;
Functions Actuarial and Valuation; Compliance; Financial; Legal; Operations; Reporting; Underwriting
Countries United States of America
Category
State
Products Banking; Loan; Mortgage
Regions Am
Rule Type Final
Rule Date 5/1/2024
Effective Date 10/31/2024
Rule Id 210754
Linked to Rule :210755
Reg. Last Update 10/10/2024
Report Section US Banking

Last substantive update on 10/15/2024