NCUA approves CUNA-requested appraisal, COVID-19 relief

April 16, 2020

The NCUA Board took several actions Thursday to provide relief to credit unions serving members during the coronavirus disease (COVID-19) pandemic, including several CUNA has called for in its engagement with NCUA.

The board finalized its real estate appraisal threshold rule, raising the threshold level below which appraisals would not be required for residential real estate-related transactions to $400,000 (it was previously $250,000).

CUNA requested NCUA make such a change in October, NCUA proposed the new threshold at its December meeting.

“We thank the NCUA board for moving quickly to finalize the real estate threshold proposal, which is especially necessary as credit unions are devoting increasing time and attention to serving members impacted by COVID-19,” said CUNA President/CEO Jim Nussle. “Full appraisals are a difficult service to obtain as businesses around the country comply with social distancing recommendations, so increasing the threshold is especially helpful for credit unions during this time and will help credit unions that offer mortgage lending going forward.”

The rule will be effective upon publication in the Federal Register.

The board also approved an Interim Final Rule allowing a credit union to temporarily defer certain appraisals and evaluations for up to 120 days when other alternatives are not available and when the appraisal or evaluation would delay the closing of the residential or commercial real estate loan transaction.

It covers all real estate related transactions except those involving acquisition, development, and construction, and will become effective from the date it is published in the Federal Register through Dec. 31, and NCUA will accept comments for 45 days after publication in the Federal Register.

The board also finalized a Temporary Final Rule to provide additional COVID-19 relief to help credit unions increase member services during the pandemic.

“Credit unions have served as financial first responders since the onset of the COVID-19 outbreak, and NCUA’s actions today will help them continue to stand by their members as it continues and its effects are felt further across the economy,” Nussle said. “We thank the board for moving swiftly on these actions, and we look forward to further engagement with the agency to continue to meet credit union needs as the pandemic continues and additional needs arise.”

The relief includes:

  • Temporarily raising the maximum aggregate amount of loan participations that a federally insured credit union may purchase from a single originating lender without seeking a waiver from the appropriate Regional Director to the greater of $5 million or 200% of the federally insured credit union’s net worth.
  • Temporarily suspending limitations on the types of eligible obligations that a federal credit union may purchase and hold. A federal credit union will not be required to refinance a purchased obligation so that it is a loan the federal credit union is empowered to make. Further, a federal credit union with a CAMEL “3” rating will be able to purchase the eligible obligations of any federally insured credit union or liquidating credit union without regard to whether they are obligations of the purchasing federal credit union’s members. Currently, this authority is limited to federal credit unions with CAMEL composite ratings of “1” and “2.”
  • Pausing the required timeframes for the occupancy or disposition of properties not being used for federal credit union business or that have been abandoned.

These temporary modifications will be in place until Dec. 31, 2020, unless extended.