Archive

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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EGRRCPA APPRAISAL RELIEF

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 […]

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APPRAISAL REVISIONS TAKE EFFECT

On April 9, 2018 the Office of the Comptroller of the Currency (OCC); Board of Governors of the Federal Reserve System (Board); and Federal Deposit Insurance Corporation (FDIC) published a final rule to amend the agencies’ regulations requiring appraisals of real estate for certain transactions. The final rule increases the threshold level at or below which appraisals are not required for commercial real estate transactions from $250,000 to $500,000 and makes other changes. The final […]

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