John Zasada, Compliance Consulting Director, Financial Institutions Group

On Sept. 17th, 2020, the National Credit Union Administration (NCUA) issued a final rule amending its appraisal requirements. The 18-page final rule defers the requirement to obtain an appraisal or written estimate of market value for up to 120 days following the closing of certain residential and commercial real estate transactions, excluding transactions for acquisition, development and construction of real estate.

It mirrors the interim rule issued in April and is similar to a recent final rule issued by the Office of the Comptroller of the Currency (OCC), the Federal Reserve (FED) and the Federal Deposit Insurance Corporation (FDIC). Credit unions that defer receipt of an appraisal or written estimate of market value are still expected to conduct their lending activity consistent with safe and sound underwriting principles, such as the ability of a borrower to repay a loan and other relevant laws and regulations. The temporary provision allowing credit unions to defer appraisals or written estimates of market value for covered transactions will expire on Dec. 31, 2020, unless extended by the NCUA Board.

For assistance with staying in compliance with appraisal regulations, contact Doeren Mayhew’s regulatory compliance specialists.