Section 103 of the Economic Growth, Regulatory Relief and Consumer Protection Act, which was signed on May 24, 2018, provides limited relief from appraisal requirements for certain loans. An appraisal in connection with a federally related transaction involving real property or an interest in real property is not required if:
* the real property or interest in real property is located in a rural area;
* not later than 3 days after the date on which the Closing Disclosure Form is given to the consumer, the mortgage originator, directly or indirectly—
> has contacted not fewer than 3 State certified appraisers or State licensed appraisers; and
> has documented that no State certified appraiser or State licensed appraiser, as applicable, was available within 5 business days beyond customary and reasonable fee and timeliness standards for comparable appraisal assignments;
* the transaction value is less than $400,000; and
* the mortgage originator is subject to oversight by a Federal financial institutions regulatory agency.
Section 103 was effective upon enactment, but regulatory guidance is expected. It is expected that the Federal financial institutions regulatory agencies will develop guidance to clarify the “three appraiser” requirement and “five day” period.
To provide more information about the new law Compliance Resource is conducting a webinar entitled the Economic Growth, Regulatory Relief and Consumer Protection Act Immediate Compliance Concerns. More information about the webinar is available at:
To provide more information about recent revisions to appraisal rules Compliance Resource is conducting a webinar entitled Real Estate Valuation in Today’s Marketplace . More information about the webinar is available at: