John Zasada, Compliance Consulting Director, Financial Institutions Group

On April 14, 2020, the Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), and the Consumer Financial Protection Bureau (CFPB) issued an Interagency Statement to address real estate appraisals affected by the COVID-19 pandemic.

Ordinarily exterior and interior inspections are conducted for appraisals. In light of the pandemic, the Interagency Statement states desktop appraisals and exterior-only appraisals are sufficient as long as the analysis is credible. Interior inspections are still required for certain higher-priced mortgage loans. It also outlines applicable exceptions to the appraisal regulations for OCC, FRB and FDIC regulated banks.

Furthermore, the OCC, FRB and FDIC issued an Interim Final Rule which temporarily amends their appraisal regulations. The  rule defers the requirement to obtain an appraisal or evaluation for up to 120 days following the closing of a transaction for certain residential and commercial real estate transactions, excluding transactions for acquisition, development and construction of real estate. This rule expires on Dec. 31, 2020.

For more information on how these regulatory changes impact your institution, contact Doeren Mayhew’s compliance specialists.