CUNA generally supports NCUA’s proposed rule on real estate appraisals, it recommended several substantive changes in potentially problematic areas in its comment letter submitted Monday.
CUNA supports the agency’s efforts to reorganize the appraisal regulation to make it easier for readers to determine whether, and if so by whom, an appraisal is required.
Specifically, NCUA’s proposal would:
One area of the rule flagged by CUNA concerns amending the exemption from appraisal requirements for certain transactions involving an existing extension of credit. The proposal would make the exemption available only if the transaction is not considered a new loan under generally accepted accounting principles (GAAP).
CUNA believes this change reduces flexibility and may make fewer transactions eligible for the exemption.