CUNA commends NCUA proposal to amend appraisal requirements

September 20, 2018

The NCUA board issued a proposed rule that would amend the agency’s regulation requiring real estate appraisals for certain transactions.

"CUNA commends NCUA on its action to raise the non-residential real estate appraisals threshold, and looks forward to commenting on the proposal,” said CUNA Chief Advocacy Officer Ryan Donovan.

According to NCUA, the proposed rule is designed to accomplish four objectives:

  • Increase the threshold below which appraisals would not be required for non-residential real estate transactions to $1 million (up from $250,000). For non-residential real estate transactions that would be exempted from the appraisal requirement as a result of the revised threshold, federally insured credit unions would still be required to obtain a written estimate of market value of the real estate collateral that is consistent with safe and sound lending practices;
  • Restructure §722.3 of NCUA’s appraisal regulation to clarify its requirements for the reader. NCUA’s intent is to more clearly indicate for the reader when a written estimate of market value, an appraisal conducted by a state-licensed appraiser, or an appraisal conducted by a state-certified appraiser is required for a real estate related financial transaction;
  • Exempt from the NCUA’s appraisal regulation certain federally related transactions involving real estate where the property is located in a rural area, valued below $400,000, and no state certified or licensed appraiser is available. This is consistent with provisions in the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155); and
  • Make certain conforming amendments to the definitions section.

Comments on the proposal will be due 60 days after its publication in the Federal Register, which is expected in the coming days.

The NCUA board meeting also included:

  • A board briefing on adoption of a resolution to appoint Administrative Law Judges;
  • A quarterly update on the share insurance fund, showing a year-to-date net income of $65.8 million, as of June 30; and
  • Approval of a Texas member business lending rule.