IBA Compliance Connection

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Do you have a sample “Reconsideration of Value” form?

Jan 3, 2023

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We found several sample “Reconsideration of Value” or similar forms, which are linked in the resources below.

Additionally, we note that the CFPB recently published an article stating that a “lender’s reconsideration of value process must ensure that all borrowers have an opportunity to explain why they believe that a valuation is inaccurate and the benefit of a reconsideration to determine whether an adjustment is appropriate.”

For resources related to our guidance, please see:

U.S. Department of Veterans Affairs, Reconsideration Grid Form

Class Appraisal, Reconsideration of Value Form

Dart Appraisal, Appraisal Appeal Form

JMAC Lending, Appraisal Reconsideration of Value (ROV) Form

CFPB, Mortgage Borrowers Can Challenge Inaccurate Appraisals Through the Reconsideration of Value Process (October 6, 2022) (“Responsible lenders focused on serving their customers typically will provide borrowers with clear, actionable information about how to raise concerns about the accuracy of an appraisal. A lender’s reconsideration of value process must ensure that all borrowers have an opportunity to explain why they believe that a valuation is inaccurate and the benefit of a reconsideration to determine whether an adjustment is appropriate. While an individual lender’s reconsideration of valuation process may vary, lenders must make sure that their reconsideration of value process is nondiscriminatory and available and accessible to all.”)

this question indicates that if a customer waits two years before reporting recurring fraudulent charges on their account, their bank likely would be required to credit the customer for any unauthorized transactions that occurred during the first sixty days following the periodic statement reflecting the initial fraudulent transaction. Are we correct that such a customer also would be eligible for a refund of all fees and interest we charged for that sixty-day period, but not for any fees and interest we charged after the sixty-day period?