Guidance on Reconsidering Residential Property Valuations

ZIONS BANCORPORATION, NATIONAL ASSOCIATION /UT/

Zions Bancorporation operates as a banking institution providing residential real estate lending services, which directly falls under the rule's scope targeting financial institutions engaged in single 1-to-4 family residential property transactions. The company's risk management functions and existing complaint resolution processes align with the guidance's requirements for incorporating ROV processes and addressing valuation discrimination risks. The rule focuses on residential real estate valuation risks and discrimination concerns, which are not reflected in the company's disclosed risk factors. The company's risks center on credit quality, cybersecurity, operational disruptions, talent retention, and counterparty concentration, with no mention of real estate lending, valuation processes, or fair lending compliance.

Axos Financial, Inc.

Axos Financial operates a significant banking business segment that includes residential real estate lending through retail, correspondent, and wholesale channels, directly aligning with the rule's focus on financial institutions engaged in residential real estate lending secured by 1-to-4 family properties. As a supervised financial institution, Axos would be subject to this guidance's requirements for establishing formal reconsiderations of value processes and controls. The company's disclosed risk factors show minimal alignment with this rule's focus on residential real estate valuation processes and discrimination risks. The company's risks center on financial accounting (allowance for credit losses, fair value estimation) and general economic uncertainty, with no specific mention of real estate lending, valuation processes, or fair lending compliance that would be directly impacted by this guidance.

ENTERPRISE FINANCIAL SERVICES CORP

Enterprise Financial Services Corp operates a residential real estate lending segment, which directly falls under the scope of this guidance that applies to financial institutions engaged in residential real estate lending secured by 1-to-4 family properties. The company's existing lending operations and complaint resolution processes would need to incorporate ROV procedures as described in the guidance. The rule focuses on residential real estate valuation reconsideration processes and discrimination risks, which does not directly align with the company's top risk factors. While the company has regulatory compliance risks (8 identified), its primary concerns are credit loss, real estate market downturns, and construction loans rather than valuation-specific discrimination or ROV processes.

ASSOCIATED BANC-CORP

Associated Banc-Corp operates as a financial institution engaged in residential real estate lending through its Community, Consumer and Business segment, directly aligning with the rule's scope on single 1-to-4 family residential properties. The company's lending solutions and existing risk management functions would be subject to the guidance's requirements for ROV processes and valuation controls. The company's disclosed risk factors show minimal alignment with this residential real estate valuation guidance. While the company has one regulatory compliance risk (capital requirements), none of its specific risks address real estate lending, valuation processes, or discrimination concerns that are central to this guidance.

BANNER CORP

Banner Corporation operates as a federally insured commercial bank that originates consumer loans including home equity lines of credit, which fall under residential real estate lending activities covered by the guidance. As a supervised financial institution engaged in residential real estate transactions, the company would need to implement ROV processes for valuation reconsiderations. The federal rule focuses exclusively on residential real estate valuation risks, discrimination concerns, and ROV processes, while the company's only disclosed risk is cybersecurity threats related to technology compromise. There is no overlap between the rule's consumer protection and real estate lending risk focus and the company's cybersecurity risk profile.

BankUnited, Inc.

BankUnited operates as a bank holding company providing banking products and services, which clearly falls under the category of supervised financial institutions targeted by this guidance. The company's residential real estate lending operations directly align with the rule's scope covering 1-to-4 family residential property valuations and ROV processes. The company's risk profile shows minimal alignment with this guidance, as it identifies only one regulatory compliance risk among 28 total risks, none specifically related to real estate valuation or discrimination. The guidance focuses on residential real estate lending and valuation processes, while the company's primary risks center on interest rate volatility, credit losses, and lease financing revenue decline with no mention of real estate operations.

BOK FINANCIAL CORP

BOK Financial operates a Consumer Banking segment that includes mortgage loan origination and servicing, directly aligning with the rule's focus on residential real estate lending secured by 1-to-4 family properties. As a financial institution engaged in residential mortgage lending, it would be subject to the guidance's requirements for establishing ROV processes and addressing potential valuation discrimination risks. The rule focuses on residential real estate valuation risks and discrimination concerns, which do not directly align with BOK Financial's disclosed risk factors. While the company has regulatory compliance risks (2 identified), none specifically mention real estate valuation, appraisal processes, or fair lending discrimination that this guidance addresses.

CITIZENS FINANCIAL GROUP INC/RI

Citizens Financial Group operates as a supervised financial institution engaged in residential real estate lending, which falls directly under the guidance's scope for single 1-to-4 family residential properties. The company's core business of deposit-taking and loan-making, particularly in residential mortgages, aligns strongly with the ROV process requirements and risk management expectations outlined in the guidance. The company's disclosed risk factors show minimal alignment with this guidance. While the company has a general regulatory compliance risk category, the specific risks mentioned (restrictions on activities and business strategy execution) do not directly correspond to the valuation reconsideration processes and discrimination mitigation requirements of this residential real estate guidance.

CVB FINANCIAL CORP

CVB Financial Corp operates Citizens Business Bank, which engages in residential real estate lending and is a supervised financial institution subject to this interagency guidance. The company's banking operations directly align with the rule's focus on residential real estate valuations and reconsideration of value processes for 1-to-4 family properties. The rule focuses on residential real estate valuation risks and discrimination concerns, while the company's primary real estate exposure is commercial real estate loans with no mention of residential lending or valuation risks. The company has regulatory compliance risks identified, but none specifically related to residential property valuations or fair lending practices addressed by this guidance.

Eastern Bankshares, Inc.

Eastern Bankshares operates as a regional banking institution, which clearly falls under the category of supervised financial institutions targeted by this guidance. As a banking entity engaged in residential real estate lending, the company's core operations align directly with the rule's focus on residential real estate valuations and reconsiderations of value processes for 1-to-4 family properties. The rule focuses on residential real estate valuation risks and discrimination concerns, which do not align with the company's disclosed risk factors of merger integration, regulatory scrutiny, competitive pressure, asset growth management, and data security. There is minimal overlap as the company's single regulatory compliance risk is generic and not specific to real estate lending or valuation processes.

FB Financial Corp

FB Financial Corp operates as a banking institution through its subsidiary FirstBank, directly falling under the category of supervised financial institutions targeted by this guidance. The company's banking services likely include residential real estate lending secured by 1-to-4 family properties, which is the explicit scope of this interagency guidance on reconsiderations of value. The company's disclosed risk factors focus entirely on capital requirements and dividend restrictions, which are unrelated to residential real estate valuation processes or discrimination concerns addressed by this guidance. There is no mention of valuation risks, fair lending compliance, or consumer protection issues in the company's risk profile.

FIRST INTERSTATE BANCSYSTEM INC

First Interstate BancSystem is a regional bank that engages in residential real estate lending, including mortgage origination for 1-to-4 family properties, which falls directly under the rule's scope. As a supervised financial institution, it would need to implement ROV processes and controls for valuation reconsiderations, aligning with the guidance's requirements for residential lending operations. The company's disclosed risk factors focus entirely on interest rate fluctuations and liquidity/capital constraints, with no mention of real estate valuation risks, discrimination concerns, or residential lending operations. The guidance addresses valuation discrimination and ROV processes that are completely unrelated to the company's identified financial and market competition risks.

FIRST MERCHANTS CORP

First Merchants Corp operates as a banking and financial services institution, directly aligning with the rule's target of supervised financial institutions engaged in residential real estate lending. As a bank, it would be subject to this interagency guidance on residential real estate valuation reconsiderations and would need to establish formal ROV processes for its mortgage lending operations. The rule focuses on residential real estate valuation processes and discrimination risks, which do not directly align with the company's disclosed risk factors of net income decrease, nonperforming assets, cybersecurity threats, regulatory changes, or competitive pressure. There is minimal overlap as the company's single regulatory compliance risk could be tangentially affected, but the specific valuation guidance does not match their identified risk profile.

GLACIER BANCORP, INC.

Glacier Bancorp operates as a bank holding company with significant residential real estate lending operations, including mortgage origination and single-family residential loans, which directly fall under the rule's scope targeting financial institutions engaged in residential real estate lending secured by 1-to-4 family properties. As a supervised financial institution, it would need to incorporate ROV processes and controls into its risk management functions. The rule focuses on residential real estate valuation risks and discrimination concerns, while the company's only disclosed risk is allowance for credit losses estimation, which is a general financial accounting risk with no specific connection to real estate lending or valuation processes. There is minimal overlap as the rule addresses operational and compliance risks in mortgage lending that are not reflected in the company's risk profile.

INTERNATIONAL BANCSHARES CORP

International Bancshares Corp operates as a bank holding company with subsidiary banks providing commercial and retail banking services, including residential real estate lending which falls directly under this guidance's scope for single 1-to-4 family residential properties. As a supervised financial institution engaged in residential lending activities, the company would need to incorporate ROV processes and controls into its risk management functions as described in the guidance. The rule addresses valuation discrimination risks in residential real estate lending, which only weakly aligns with the company's disclosed risk of real estate value decline (operational risk). The company's other primary risks focus on loan loss allowances, competition, liquidity, and regulatory constraints on dividends, none of which are directly addressed by this valuation guidance.

NORTHERN TRUST CORP

Northern Trust Corp operates as a major financial institution with significant residential real estate lending operations, including mortgage origination and servicing, which directly falls under the rule's scope for supervised financial institutions engaged in residential real estate transactions secured by 1-to-4 family properties. The company's existing risk management and compliance infrastructure would need to incorporate the ROV processes and controls described in the guidance. The company's risk factors show no alignment with this residential real estate valuation guidance. The company operates in technology and digital services with risks focused on cybersecurity, data privacy, and technology disruption, while the rule specifically targets financial institutions engaged in residential real estate lending and valuation processes.

PROVIDENT FINANCIAL SERVICES INC

Provident Financial Services operates as a supervised financial institution with residential mortgage lending operations that fall directly under the rule's scope for 1-to-4 family residential properties. The company's residential mortgage loan segment ($2M revenue) and consumer lending operations would be subject to the ROV guidance requirements for valuation reconsiderations and discrimination complaint processes. The rule focuses on residential real estate valuation risks and discrimination complaints, which do not align with the company's disclosed risk factors of legal proceedings, dividend sustainability, stock volatility, branch operations, and leased facilities. There is minimal overlap as the company's single regulatory compliance risk is generic and not specific to real estate lending or valuation processes.

PNC FINANCIAL SERVICES GROUP, INC.

PNC is a major financial institution engaged in residential real estate lending, including mortgage origination and servicing for 1-to-4 family properties, which directly falls under the rule's scope. The company operates nationwide as a supervised financial institution and already maintains complaint resolution processes that would need to incorporate ROV procedures as described in the guidance. The rule focuses on residential real estate valuation risks and discrimination concerns, which do not align with the company's disclosed risk factors. The company's primary risks are operational management, financial derivatives, information security, and general regulatory compliance, none of which specifically address real estate valuation or appraisal discrimination risks.

ServisFirst Bancshares, Inc.

ServisFirst Bancshares operates as a financial institution engaged in residential real estate lending, which falls directly under the rule's scope for supervised financial institutions handling single 1-to-4 family residential properties. The company's mortgage origination and lending activities would require formal ROV processes and controls as described in the guidance, making this rule highly relevant to their core business operations. The rule focuses on residential real estate valuation risks and discrimination concerns, while the company's only disclosed risk is cybersecurity threats related to technology. There is minimal overlap as the rule addresses financial and consumer protection risks in lending operations, not cybersecurity vulnerabilities.

SIMMONS FIRST NATIONAL CORP

Simmons First National Corp operates as a banking and financial holding company subject to federal supervision, directly aligning with the rule's target of supervised financial institutions. The company's banking services likely include residential real estate lending secured by 1-to-4 family properties, which falls squarely within the guidance scope requiring ROV processes for valuation reconsiderations. The company's disclosed risk factors show minimal alignment with this guidance, which focuses on residential real estate valuation reconsiderations and discrimination risks. The company's primary risks relate to credit loss estimation, acquisition accounting, and tax compliance, with no mention of real estate lending, valuation processes, or fair lending concerns that this guidance addresses.

Atlantic Union Bankshares Corp

Atlantic Union Bankshares Corp operates as a regional bank holding company with significant residential real estate lending operations, including mortgage origination and servicing for 1-to-4 family properties, which directly falls under the rule's scope. The company's existing risk management and compliance infrastructure would need to incorporate the ROV processes and controls described in the guidance. The company's single regulatory risk factor (Regulatory Approval) relates to merger approvals rather than real estate valuation processes or discrimination complaints addressed by this guidance. None of the company's identified financial, operational, or market competition risks align with the residential real estate valuation focus of this supervisory guidance.

SYNOVUS FINANCIAL CORP

Synovus Financial Corp operates as a regional bank with significant residential real estate lending operations, including mortgage origination and servicing for 1-to-4 family properties, which directly falls under the rule's scope. The company's existing risk management and complaint resolution processes would need to incorporate ROV procedures as outlined in the guidance. The company's disclosed risk factors focus on funding costs and client confidence in banking systems, which are general financial and market risks not specifically addressed by this valuation guidance. The rule's focus on residential real estate valuation processes and discrimination risks does not align with the company's identified risk profile.

SouthState Corp

SouthState Corp operates as a regional bank providing financial services, which clearly falls under the category of supervised financial institutions targeted by this guidance. As a banking institution engaged in residential real estate lending, its operations directly align with the rule's focus on residential real estate valuations and reconsiderations of value processes for 1-to-4 family properties. The company's disclosed risk factors show minimal alignment with this rule's focus on residential real estate valuation processes and discrimination risks. While the company has one regulatory compliance risk related to transaction approvals, it specifically concerns sale-leaseback transactions rather than residential lending or valuation practices. None of the identified risks address real estate valuation quality, discrimination concerns, or residential lending operations that this guidance targets.

UNITED BANKSHARES INC/WV

United Bankshares operates a residential real estate lending segment generating $46M in revenue, directly aligning with the rule's focus on residential real estate valuations for 1-to-4 family properties. As a financial institution engaged in residential lending, it would be subject to the guidance's requirements for establishing ROV processes and addressing potential valuation discrimination risks. The rule focuses on residential real estate valuation risks and discrimination concerns, which do not align with the company's disclosed risk factors. The company's primary risks relate to loan losses, acquisition integration, economic trends, mortgage consolidation, and data security - none of which directly address valuation accuracy or fair lending compliance.

WSFS FINANCIAL CORP

WSFS Financial Corp operates as a financial institution engaged in residential real estate lending, including mortgage origination for 1-to-4 family properties, which directly falls under the rule's scope. The company's existing complaint resolution processes and risk management functions align with the guidance requirements for handling reconsiderations of value and potential discrimination allegations. The rule focuses on residential real estate valuation risks and discrimination concerns, while the company's primary risks center on credit loss provisioning, commercial real estate market uncertainty, and operational cost increases. There is minimal overlap as the company's disclosed risks do not address residential valuation processes, appraisal quality, or fair lending compliance.

WINTRUST FINANCIAL CORP

Wintrust Financial Corp operates as a banking institution offering commercial lending services, which directly aligns with the rule's focus on financial institutions engaged in residential real estate lending. The company's banking and lending operations would require compliance with ROV processes for residential property valuations as described in the guidance. The rule focuses on residential real estate valuation risks, discrimination concerns, and operational compliance processes, none of which appear in the company's disclosed risk factors. The company's risks are primarily financial and interest rate-related, showing minimal overlap with the guidance's consumer protection and valuation quality focus.

BANK OF AMERICA CORP /DE/

Bank of America is a major financial institution engaged in residential real estate lending, which falls directly under the rule's scope for single 1-to-4 family residential properties. The company's banking operations and existing complaint resolution processes align with the guidance requirements for managing reconsiderations of value and potential discrimination allegations. The rule focuses on residential real estate valuation risks and discrimination concerns, while the company's risk factors center on financial reporting, goodwill impairment, and accounting compliance with no mention of real estate lending, valuation processes, or fair lending risks. There is minimal overlap as both involve regulatory compliance generally, but the specific risk areas addressed by the rule are completely absent from the company's disclosed risk profile.

BANC OF CALIFORNIA, INC.

Banc of California operates as a bank holding company providing banking products and services, which directly aligns with the rule's focus on supervised financial institutions engaged in residential real estate lending. As a national banking institution, it would be subject to this interagency guidance and would need to implement ROV processes for its residential mortgage lending operations. The company's disclosed risk factors show minimal alignment with this residential real estate valuation guidance. While the company has one regulatory compliance risk identified, it is not specifically related to real estate lending, valuation processes, or fair lending concerns that this guidance addresses. The company's primary risks focus on merger integration, interest rates, balance sheet management, cybersecurity, and competition rather than real estate valuation or discrimination risks.

BANCFIRST CORP /OK/

BancFirst Corporation operates as a commercial banking institution that provides residential real estate lending services, directly falling under the rule's scope for supervised financial institutions engaged in single 1-to-4 family residential property transactions. As a regulated financial institution, it would need to implement ROV processes and controls for valuation reconsiderations, aligning with the guidance's operational requirements. The company's disclosed risk factors show minimal alignment with this residential real estate valuation guidance. While the company has regulatory compliance risks (Patriot Act, OFAC sanctions), none specifically address real estate lending, valuation processes, or discrimination concerns that this guidance targets. The company's risk profile focuses on financial services regulation, technology adoption, and market competition rather than residential real estate valuation risks.

FIRST BUSEY CORP /NV/

First Busey Corporation operates as a financial holding company providing banking services including loans and credit facilities, which directly aligns with the rule's focus on financial institutions engaged in residential real estate lending. The company's banking operations would be subject to this supervisory guidance on residential real estate valuation reconsiderations and risk management processes. The company's risk factors show no alignment with this residential real estate valuation guidance. The company operates in commercial real estate and technology sectors, with risks focused on market competition, technology disruption, and commercial property valuation - none of which overlap with the rule's focus on residential property valuations, discrimination risks, or consumer lending compliance.

COMERICA INC /NEW/

Comerica operates as a major financial institution with significant residential real estate lending operations through its Consumer and Residential Mortgage Loan Portfolios segment, directly falling under the rule's scope for supervised financial institutions engaged in residential real estate transactions secured by 1-to-4 family properties. The company's existing risk management frameworks and complaint resolution processes align with the guidance's focus on incorporating ROV processes into established risk management functions. The rule focuses on residential real estate valuation risks and discrimination concerns, while the company's only disclosed risk is cybersecurity threats with no mention of real estate lending, valuation processes, or fair lending compliance. There is no overlap between the rule's consumer protection and valuation risk focus and the company's technology cybersecurity risk profile.

COLUMBIA BANKING SYSTEM, INC.

Columbia Banking System operates as a regional bank providing residential real estate lending services including mortgage origination for 1-to-4 family properties, which falls directly under this guidance's scope. The company's core business involves real estate valuation processes and consumer lending operations that would require implementation of ROV procedures as described in the guidance. The company's disclosed risk factors show minimal alignment with this rule's focus on residential real estate valuation discrimination risks. While the company has one regulatory compliance risk identified, it is not specifically related to real estate lending or valuation processes, and none of the top risks address fair lending, appraisal quality, or discrimination concerns that this guidance targets.

Mr. Cooper Group Inc.

Mr. Cooper Group operates as both a major mortgage originator and the largest residential mortgage loan servicer in the U.S., directly engaging in residential real estate lending activities that fall squarely within the rule's scope of single 1-to-4 family residential properties. The company's core business model involves handling mortgage valuations and would be significantly affected by requirements to establish formal ROV processes and address potential valuation discrimination. The company's single regulatory compliance risk factor shows minimal alignment with this guidance, which focuses specifically on residential real estate valuation reconsiderations and discrimination risks. The company's disclosed risks are primarily financial and operational (interest rates, servicing growth, channel mix), with no mention of valuation processes, fair lending, or residential real estate-specific compliance concerns.

FIRST FINANCIAL BANCORP /OH/

First Financial Bancorp operates as a regional bank holding company engaged in residential real estate lending, including mortgage origination for 1-4 family properties, which falls directly under the rule's scope. The company's core business activities in residential lending and existing compliance infrastructure align strongly with the guidance requirements for ROV processes and valuation risk management. The company has significant exposure to real estate market risks (3 identified risks) and regulatory compliance risks (6 identified risks), which directly aligns with this guidance's focus on residential real estate valuation processes and discrimination mitigation. The guidance addresses valuation deficiencies and collateral value concerns that match the company's high-impact real estate market risk factor.

FIRST HORIZON CORP

First Horizon Corp operates as a regional bank with significant residential real estate lending operations, including mortgage origination and servicing, which directly falls under the rule's scope for supervised financial institutions engaged in 1-to-4 family residential property transactions. The company's existing risk management and complaint resolution processes would need to incorporate ROV procedures as outlined in the guidance. The rule's focus on residential real estate valuation processes has weak alignment with the company's risk profile. While the company identifies 'Mortgage Demand Decline' as a market risk, the guidance addresses operational compliance requirements rather than demand fluctuations, and the company's single regulatory compliance risk is generic without specific mortgage lending focus.

FLAGSTAR FINANCIAL, INC.

Flagstar Financial operates a significant one-to-four family first mortgage business segment ($5.2M revenue) and provides mortgage servicing rights ($73M revenue), directly aligning with the rule's focus on residential real estate lending secured by 1-to-4 family properties. As a supervised financial institution engaged in residential real estate transactions, the guidance's ROV processes and valuation risk management requirements would materially impact their lending operations. The company identifies 'Legal and Regulatory Risk' and 'Operational Risk' as key concerns, which partially align with this guidance's focus on compliance processes and operational controls for valuation reconsiderations. However, the guidance specifically targets residential real estate lending valuation practices, which is not explicitly mentioned in the company's broad risk categories, limiting direct alignment.

FULTON FINANCIAL CORP

Fulton Financial Corp operates as a regional bank holding company with significant residential real estate lending operations, including mortgage origination and servicing for 1-to-4 family properties, which directly aligns with the rule's scope. The company's existing risk management and compliance infrastructure would need to incorporate the ROV processes and controls described in the guidance. The company's disclosed risk factors focus entirely on dividend restrictions, equity compensation, and shareholder value dilution, with no mention of residential real estate lending, valuation processes, or discrimination risks. The rule addresses valuation reconsideration and discrimination risks in residential real estate, which are completely absent from the company's risk profile.

HUNTINGTON BANCSHARES INC /MD/

Huntington Bancshares operates significant residential real estate lending through its mortgage banking services, directly falling under the rule's scope for financial institutions engaged in 1-to-4 family residential property transactions. The company's consumer banking segment would be required to implement ROV processes and controls as a supervised financial institution. The rule focuses on residential real estate valuation risks and discrimination concerns, which do not align with the company's disclosed risk factors. The company's primary risks relate to credit losses, interest rates, and loan portfolio quality without specific mention of valuation or appraisal risks.

HANCOCK WHITNEY CORP

Hancock Whitney Bank operates as a supervised financial institution engaged in residential real estate lending, which directly falls under the rule's scope for single 1-to-4 family residential properties. The company's traditional banking services include mortgage origination and lending activities that would require compliance with ROV processes and valuation risk management. The rule focuses on residential real estate valuation risks and discrimination concerns, which are not reflected in the company's disclosed risk profile. The company's risks center on information systems, liquidity, cybersecurity, and deposit runs, with no mention of real estate lending, valuation, or fair lending compliance risks.

JPMORGAN CHASE & CO

JPMorgan Chase operates extensive residential real estate lending through its Consumer & Community Banking segment, including mortgage origination and servicing, directly falling under the rule's scope for financial institutions engaged in residential real estate lending secured by 1-to-4 family properties. As a major supervised financial institution, it would be significantly affected by the guidance's requirements for ROV processes and valuation risk management. The rule focuses on residential real estate valuation risks and discrimination concerns, which do not align with the company's disclosed risk profile dominated by fair value measurement of financial instruments, consolidation of VIEs, and accounting standards compliance. The company's single regulatory compliance risk appears unrelated to real estate lending or valuation processes.

KEYCORP /NEW/

KeyCorp operates KeyBank, a major financial institution engaged in residential real estate lending and mortgage origination, which directly falls under the rule's scope targeting supervised financial institutions handling single 1-to-4 family residential properties. The company's banking services include valuation processes and complaint resolution mechanisms that would need to align with the guidance on ROV procedures and discrimination risk mitigation. The rule focuses on residential real estate valuation risks and discrimination concerns, which do not align with the company's disclosed risk profile centered on cybersecurity threats, third-party vulnerabilities, and information security program effectiveness. There is no overlap with the company's regulatory compliance risk, which appears to be general rather than specific to real estate lending or valuation processes.

M&T BANK CORP

M&T Bank operates as a financial institution engaged in residential real estate lending through its Retail Bank segment, which directly aligns with the rule's focus on supervised financial institutions handling single 1-to-4 family residential property valuations. The company's existing complaint resolution processes and risk management functions would need to incorporate ROV procedures as outlined in the guidance. The company identifies only one regulatory compliance risk generally, but this specific guidance on residential real estate valuation reconsiderations does not align with its disclosed risk profile. The company's risks focus on broad financial, operational, and competitive pressures rather than real estate valuation processes or discrimination concerns.

PINNACLE FINANCIAL PARTNERS INC

Pinnacle Financial Partners operates as a bank holding company providing residential real estate lending services, including mortgage origination for 1-to-4 family properties, which directly falls under the rule's scope. The company's core business involves real estate-secured financial transactions and would require implementation of ROV processes and controls as outlined in the guidance. The company's disclosed risk factors show minimal alignment with this rule's focus on residential real estate valuation processes and discrimination risks. The only potential connection is the single regulatory compliance risk (FDIC assessments), but this guidance specifically addresses valuation reconsideration processes rather than assessment fees or general compliance costs.

REGIONS FINANCIAL CORP

Regions Financial Corporation operates as a supervised financial institution engaged in residential real estate lending through its mortgage banking services, directly falling under the rule's scope for single 1-to-4 family residential properties. The company's existing credit risk management and compliance functions align with the guidance's focus on incorporating ROV processes into established risk management frameworks. The rule focuses on residential real estate valuation risks and discrimination complaints, which are not explicitly mentioned in the company's disclosed risk factors. While the company has general legal/regulatory compliance risks, there is no specific mention of real estate valuation, appraisal, or fair lending risks that would align directly with this guidance.

Rocket Companies, Inc.

Rocket Companies operates primarily in residential mortgage origination through Rocket Mortgage, directly engaging in real estate lending secured by 1-to-4 family residential properties, which is the core focus of this guidance. Their digital-first model and technology-driven solutions align with the operational requirements for establishing formal ROV processes and managing valuation-related complaints. The company's disclosed risk factors show minimal alignment with this rule's focus on residential real estate valuation discrimination and ROV processes. The company's single regulatory compliance risk relates to legal proceedings rather than fair lending or valuation practices, and its operational risks concern facility management rather than financial services operations.

TEXAS CAPITAL BANCSHARES INC/TX

Texas Capital Bancshares operates a Mortgage Finance segment that purchases and holds 1-4 family residential mortgage loans, directly aligning with the rule's scope on residential real estate valuations. The company's Consumer segment also includes first and second lien mortgages for 1-4 family dwellings, further demonstrating operational relevance to the guidance on reconsiderations of value processes. The company's single regulatory compliance risk is generic and does not specifically address residential real estate valuation discrimination or ROV processes, which are the core focus of this guidance. The company's identified risks are primarily financial (credit losses, debt management, share repurchases) with no mention of real estate lending, valuation practices, or fair lending concerns.

TRUSTMARK CORP

Trustmark Corporation operates a General Banking segment that includes mortgage banking services, directly aligning with the rule's focus on residential real estate lending secured by 1-to-4 family properties. As a supervised financial institution engaged in residential real estate transactions, the company would need to implement ROV processes and controls for valuation reconsiderations. The company's disclosed risk factors focus entirely on interest rate risk, derivatives exposure, and credit risk participation in swaps, with no mention of residential real estate lending, valuation processes, or discrimination risks. The guidance targets residential real estate valuation reconsiderations and discrimination mitigation, which are completely absent from the company's risk profile.

WAFD INC

WaFd Inc operates a significant consumer lending segment that includes single-family residential loans, which directly falls under the rule's scope for residential real estate valuations. The company's banking operations as a supervised financial institution would be subject to this interagency guidance on ROV processes for residential property valuations. The rule focuses on residential real estate valuation risks, discrimination concerns, and operational compliance requirements for financial institutions, while the company's only disclosed risk is cybersecurity threats with no connection to real estate lending, valuation processes, or consumer protection. There is no overlap between the rule's risk mitigation objectives and the company's technology-focused cybersecurity risk profile.

WESTERN ALLIANCE BANCORPORATION

Western Alliance Bancorporation operates as a financial institution engaged in residential real estate lending, which falls directly under the rule's scope for supervised financial institutions handling single 1-to-4 family residential properties. The company's loan business segment would be significantly affected by the requirement to establish formal reconsiderations of value processes and controls for valuation risk management. The rule focuses on residential real estate valuation risks and discrimination concerns, while the company's primary risks are concentrated in commercial real estate (CRE) exposure, charge-offs, and FDIC assessments. There is minimal overlap as the company shows no residential lending risks or valuation-related concerns in its disclosed risk profile.

WESBANCO INC

Wesbanco operates as a financial institution with liquidity management focus, but the rule specifically targets residential real estate lending and valuation processes, which are not mentioned in the provided business operations description. The company's core activities of maintaining liquid assets and stable deposits do not align with the rule's focus on ROV processes for residential property valuations. The company has 7 identified regulatory compliance risks and 13 operational risks, which directly align with this guidance's focus on establishing formal ROV processes and compliance requirements for residential real estate lending. The guidance's emphasis on managing valuation-related complaints and discrimination allegations matches the company's regulatory action risk category, indicating material impact potential.