Tag: fifth factor

Feds to Lenders: Take AVMs Seriously

Regulators are signaling that they are going to be looking at how AVMs are used and whether lenders have appropriately tested them and continuously monitor them for valuation discrimination. This represents a change in the focus on AVMs and the need for all lenders to focus on AVM validation to avoid unfavorable attention from government regulators.

On Feb 12, the FFIEC issued a statement on examinations from regulators. It specifically stated that it didn’t represent a change in principles, nor a change in guidance, and not even a change in focus. It was just a friendly announcement about the exam process, which will focus on whether institutions can identify and mitigate bias in residential property valuations.

Law firm Husch Blackwell published their interpretation a week later. Their analysis included consideration of the June 2023 FFIEC statement on the proposed AVM quality control rule, which would include bias as a “fifth factor” when evaluating AVMs. They interpret these different announcements as part of a theme, an extended signal to the industry that all valuations, and AVMs in particular, are going to receive additional scrutiny. Whether that is because bias is as important as quality or because being unbiased is an inherent aspect of quality, the subject of bias is drawing attention, but the result will be a thorough examination of all practices around valuation, including AVMs, from oversight to validation, training, auditing, etc.

AVM quality has theoretically been an issue that could be enforced by regulators in some circumstances for over a decade. What we’re seeing is not just an expansion from accuracy into questions of bias. We’re also seeing an expansion from banks into all lenders, including non-bank lenders. And, they are signaling that examinations will focus on bias, which is an expansion from the theoretical requirement to an actual, manifest, serious requirement.