All in Appraisals

On April 20, 2020, the NCUA issued a final rule to provide appraisal relief to credit unions. The final rule does two main things. First, the final rule increases the residential appraisal threshold from $250,000 to $400,000. The raised threshold provides long-term regulatory relief to credit unions and members and aligns with the appraisal threshold adjustment that banking regulators made during 2019. The rule also increases flexibility for credit unions struggling with mortgage pipeline delays due to appraisals during the COVID-19 pandemic. Secondly, the NCUA has issued an interim final rule to temporarily allow credit unions to defer appraisals and written estimates of market value for up to 120 days after the closing of a loan. This flexibility will expire on December 31, 2020 and this, too, aligns with action taken by banking regulators. The NCUA explains that this deferral is intended to provide liquidity and relief to property owners affected by disruptions to property valuations caused by COVID-19 mitigation efforts. Both rules become effective upon publication in the Federal Register.

On 4/14/20, the banking regulators (except the NCUA) issued an interim final rule to temporarily defer real estate-related appraisals and evaluations under the agencies' interagency appraisal regulations. The Federal Reserve, FDIC, and OCC are providing this temporary relief to allow regulated institutions to extend financing to creditworthy households and businesses quickly in the wake of the national emergency declared in connection with COVID-19. The agencies are deferring certain appraisals and evaluations for up to 120 days after closing of residential or commercial real estate loan transactions. Transactions involving acquisition, development, and construction of real estate are excluded from this interim rule. These temporary provisions will expire on December 31, 2020, unless extended by the regulators.

Which Appraisal Threshold for Two 1-4 Family Properties?

In this Compliance Clip (video), Adam answers a question related to which appraisal threshold applies for a consumer-purpose loan secured by two 1-4 family properties (for a bank). As the answer to this might not be what you expect it to be, Adam points out a few of the challenges of the new appraisal thresholds. This video provides a great overview of when the different appraisal thresholds apply to bank loans.