On behalf of the industries, clients, and communities we represent, we write to comment on
HUD’s proposed process for Mortgagees when a Borrower requests a review of the appraisal
results associated with their application for an FHA-insured mortgage. This joint industryconsumer comment sets out essential principles we see as vital for the successful development
and deployment of a reconsideration of value (ROV) process.
We appreciate that FHA recognizes the value of providing additional guidance on the ROV process, and is offering an opportunity to comment on the proposed policy changes. We believe, however, that an ROV process would be more effective if FHA and HUD were to work with other Property Appraisal Valuation Equity (PAVE) Task Force members to develop a uniform, market-wide process that includes detailed information for all of the parties that may engage in the various components of the process, including (but not limited to) the borrower, lender, and appraiser.
We recommend that FHA and HUD work collaboratively with other government guarantee agencies and the GSEs to construct a standardized/uniform approach to the reconsideration process, including procedural steps and requirements for all of the parties involved, as a uniform framework would directly benefit the government, industry, and borrowers alike. We believe that a comprehensive approach would include, at a minimum, educational resources for consumers, clear responsibilities outlined for lenders, and infrastructure for accountability of appraisers.