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REGULATION Z CONSUMER CREDIT EXEMPTION AND HPML APPRAISAL THRESHOLDS UNCHANGED FOR 2021

On November 18 the Consumer Financial Protection Bureau (CFPB) and Federal Reserve Board (FRB) published the 2021 threshold for the consumer credit exemption in Regulations Z and M. Additionally, the CFPB, FRB, and Office of the Comptroller of the Currency (OCC) published the 2021 threshold for Higher Priced Mortgage Loan (HPML) appraisal exemption in Regulation Z. There will be no changes from the 2020 threshold amounts. The thresholds for 2021 are as follows: The protections […]

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CORONA RELIEF – ECOA VALUATION RULE

On April 29, 2020 the Consumer Financial Protection Bureau (CFPB) published a Compliance Aid dealing with the ECOA Valuation Rule. The Aid, which is in Question/Answer format, was effective upon publication. QUESTION 1: Under the Equal Credit Opportunity Act (ECOA) and its implementing Regulation B, creditors are required to provide applicants for first-lien loans on a dwelling with copies of appraisals, as well as other written valuations (collectively, “valuations”), developed in connection with the application […]

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AGENCIES DEFER APPRAISALS

On April 14, 2020 the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation,  Office of the Comptroller of the Currency,  National Credit Union Administration,  and the Consumer Financial Protection Bureau (jointly, the agencies) issued an interim final rule to temporarily defer real estate-related appraisals and evaluations under the interagency appraisal regulations. The agencies are providing this temporary relief to allow regulated institutions to extend financing to creditworthy households and businesses quickly […]

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RESIDENTIAL APPRAISAL THRESHOLD INCREASING TO $400,000

The federal banking agencies (Federal Reserve, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency) have issued a final rule increasing the threshold for residential real estate transactions that require an appraisal from the current $250,000 to $400,000; transactions exceeding the threshold are required to obtain an appraisal under the agencies’ appraisal regulations. The agencies believe the increased price of residential real estate transactions since the threshold was set in 1994 warrants […]

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