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The Independent Community Bankers of America (ICBA)1 appreciates the opportunity to provide feedback to the Office of the Comptroller of the Currency (OCC); Board of Governors of the Federal Reserve System (Board); Federal Deposit Insurance Corporation (FDIC); and Consumer Financial Protection Bureau (CFPB), the Agencies, regarding their proposed guidance that would underscore the risks associated with deficient residential real estate valuations and outline how financial institutions may integrate reconsiderations of value (ROV) processes and controls into established risk management functions.