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Financial institutions rely on property valuations to assess the credit worthiness of borrowers offering property as collateral. Accurate valuations are crucial for mitigating risk in case of default, enabling institutions to recover losses by selling the mortgaged property.

While Institutions typically engage professional Valuers, internal credit officers often conduct independent reviews, including site visits and market surveys, intending to ensure accuracy. However, credit officers may lack basic valuation knowledge. They frequently compare formal valuations with informally gathered market data and valuation figures received from the property owner, loan agent, or CA who sourced the credit proposal. This may result in incorrect assessments of valuation assignments.

Take a case, when a valuer estimates a property’s value at ₹100, and a credit officer’s market research suggests values between ₹95 and ₹105, the ₹100 valuation to be deemed acceptable. Conversely, a valuation exceeding ₹105 might be flagged as overvalued.

Assessment of Property Valuations by Financial Institutions Challenges & Recommendations

Similarly, a properly submitted valuation of ₹ 70-80 (based on recorded comparable sales and adjustments for the specific purpose of the valuation) may be considered undervalued.

This can result in Valuers providing figures between ₹95 and ₹105 receiving preferential treatment and securing future valuation work from the financial institution. Conversely, Valuers who adhere to valuation principles, standards and ethic, and thus provide a more accurate value (e.g., ₹70-80 in the example), may be penalized and excluded from future assignments by being labeled as “undervalue.”

Consequently, much of the valuation work for financial institutions relies on hearsay asking prices without applying any valuation principles and corrections for the specific purpose for which the valuation is made.

This practice raises serious concerns about the role and proper use of professional Valuers. If a valuer’s assessment merely aligns with a credit officer’s informal market inquiries or figures provided by the client, loan agent or CA, it is indicative of a convenience value being opined and can lead to an understanding that proper valuation principles and standards have not been applied, nor do they understand the specific purpose of the valuation. In such cases, why not rely solely on the credit officer’s assessment?

Assessing valuation reports based on hearsay, informal market inquiries, and figures gathered from interested parties undermines the entire valuation process. It creates an unfair environment for qualified and experienced Valuers who adhere to professional standards and ethics, leaving them with an understanding that their expertise is disregarded. This practice incentivizes poor valuation practices and ultimately defeats the purpose of obtaining an independent and subjective valuation for secured lending, potentially leading to substantial financial losses due to overvaluation.

These discrepancies often stem from inadequate training and understanding of valuation methodologies among credit officers. They may rely on anecdotal information from neighbours, real estate agents and property owners, failing to grasp the nuances of market value and, crucially, the specific purpose of the valuation – secured lending.

Valuation for secured lending focuses on the realizable value in a foreclosure scenario, which differs significantly from the price a willing buyer and seller might agree upon in a typical transaction (market value). Factors influencing realizable value include property characteristics, surrounding area, demand and supply dynamics, purchasing power, the time and costs required for sale.

Furthermore, the prevalence of “unaccounted “money in local market transactions, while relevant to open market value, is less relevant for forced sale value.

Professional valuation standards emphasize using comparable sales data with appropriate adjustments. This systematic approach minimizes subjective biases and provides a more robust estimate of market value. While credit officers’ market surveys can be valuable, their interpretations must be grounded in sound valuation principles. Simply gathering data points without proper analysis and adjustments can be misleading.

The current practice of credit officers reviewing valuations presents several challenges. Their lack of specialized expertise can lead to inaccurate judgments, potentially jeopardizing the institution’s financial security. This necessitates a more structured and professional approach to valuation review.

Recommendations:

1. Automated Valuation System: Use a central, automated system for all valuation activities and reports. Credit officers should not assign valuations or review reports.

2. Valuer Performance Evaluation: A recognized valuation Institution should evaluate valuer performance, checking reports for quality, adherence to guidelines, and consistency. This helps address any performance issues. Valuers must have a valid Certificate of Practice from a recognized valuation institute for annual renewal.

3. Independent Valuation Review Panel: Banks should establish an independent panel of valuation experts to review reports, ensuring they meet industry standards and are objective. The bank should review 2.5% of each Valuer’s annual work. If the valuer or the bank disagrees with the review, the report goes to the valuation institution for a final decision.

4. Annual RBI Audit of Valuation Work: The RBI should appoint a valuation institute to conduct an annual audit of valuation work across all banks. This audit will ensure adherence to valuation standards and identify best practices.

5. Enhanced Credit Officer Training: Credit officers need better training on valuation principles, methodologies, and rules. Training should cover valuation basics, different methodologies and approaches, the difference between cost, price, and value, and how these vary by purpose. Valuation institutions should provide this training.

6. Standardized Valuation Guidelines: Banks should create clear, standard valuation guidelines. These should detail requirements for comparable data, adjustments, and reporting, and comply with recognized standards. Valuation institutions should help develop and update these guidelines.

7. Transparent Documentation: The valuation review process must be transparent and well-documented. All review comments and justifications for adjustments, along with the valuation institution’s review, should be recorded.

By following these recommendations, especially the involvement of established valuation institutions in reviews, performance evaluations, and training, will significantly improve the accuracy and reliability of property valuations and reduce lending risks for banks.

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9 Comments

  1. ARVINDD MALPANI says:

    Sir, every point written in your article is in the mind of every valuer (who works with ethics), but we have not found any proper platform to tell or explore these. Your suggestions for superior quality valuation are correct and practical.
    But We have to argue with these kinds of unskilled and non-technical peoples every day and when the matter gets out of hand, they directly say that if we want the work then we will have to do as they say.
    In the current scenario in the view of private banks, there is no difference between a valuer who has registered valuer title with passing IBBI exam or got registered under section of 34AB Wealth Tax Act 1957 and a fresher who does not even know the basics of valuation.
    A new practice is going on in private banks right now, they are directly appointing fresh engineering graduates to the post of internal technical manager and then banks are distributing loans by taking desired valuations from those fresh graduates (Those who do not even know the basics of valuation and have not taken any training program to groomed their skills for valuation task) And those freshers don’t even know what they are doing because they don’t consider themselves as valuer but as employees of the bank and in order to save their jobs, under the pressure of bank’s brokers and sales team, they are doing all those things which a skilled and ethical valuer should not do.

    So, one more suggestion is that there should be some guideline from the government as to whom the bank should appoint as internal technical manager (for doing valuation task), otherwise the skilled valuers will always have to waste their energy with these unskilled valuers.

  2. GURU PRASAD MATHUR MATHUR says:

    The suggestions given for improving work distribution and its review will not only make valuation fair but will also improve its quality to a great extent, the biggest benefit of which will be a substantial reduction in the losses incurred by banks at the time of recovery and the valuation field will gain prestige.

  3. Guru Prasad Mathur says:

    The suggestions given for improving work distribution and its review will not only make valuation fair but will also improve its quality to a great extent, the biggest benefit of which will be a substantial reduction in the losses incurred by banks at the time of recovery and the valuation field will gain prestige.

  4. Gajendra paliwal says:

    This is fact and burning issue which is adversely affecting valuation profession, due to lack of knowledge, mostly valuers are doing unethical work which will create very big problem but valuers are not ready to accept this truth. Every one knows that after breakeven point every thing will break but not ready to accept this science rule. so be ready to face new crises.

  5. Anand S.Saxena* says:

    Nice article, not an article but a fact,but due to obtain targets bankers deny the rules, regulations even their circulars. Non technical officer of bank/ fincial institutions review the valuation report of a Qualified valuers, तभी तो मेरा भारत महान। Valuation report totally managed by these bankers, loan agents and by some needy,greedy valuers etc. I fully agree with the recommendations suggested by Mr.Dungarwal ji. I request Mr.Dungarwal ji and Taxguru team to send this article to RBI & FM Govt.of India, so the dirty game of such type peoples can expose and save the future possible financial loss of banks etc. Regards Mr.Sanjay Dungarwal ji .
    Anand S. Saxena RV , 9414184052

  6. Surendra kumar gupta says:

    this is the actual problem in valuation profession. Bankers do not botherrd about true valuation. they want valuation which is required by clients. They don’t bothered about future loss to bank which may due to inflated valuation. Valuers those want to do valuation on principal basis is out of profession from bankers side. Bankers simply asked what is amont of valuation before giving valuation. even they want valuation on same day. when valuation fees will receive by valuer, they don’t give any answer. if loan is not given by bank from any reason, valuer will not get
    profession fees.

  7. Manoj Kumar Dharnia says:

    Very well portrayed the situation that’s how an ethical independent valuer faces hindrance across in his day to day affairs. The Banks /FIs are not bothering and focused only convert leads in to loan instead of quility check. Such practices have worsened after starting sourcing from independent loan agent/ touts etc.They forcing to The FI to utilise services of their preferred professionals. This caused degradation of profession’s standards and respect.

  8. Sanjeev Kumar Jain says:

    The writeup is crisp and clear emanating the real heat and pain a genuine Valuer faces. The prize they get is the loss of practice on the grounds of not matching up to the whims of Credit and Sales officials. No one listens to the applied methodology, Sales Comparisons, or the fine aspects which is essentially the intrinsic domain of a Professional Valuer. The suggestions made are very practical but need a very proactive approach from the policymakers. They should now shed away the inertia that is throwing true professionalism into the doldrums. Kudos Sanjay Ji for such a fine writeup. Regards, Sanjeev Kumar Jain 9352600515

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