ARLINGTON, Va.–In the wake of NCUA's interim final rule allowing credit unions to defer the requirement to obtain an appraisal or evaluation for up to 120 days following the closing of a transaction for certain residential and commercial real estate transactions amid the coronavirus pandemic, NAFCU is offering recommendations for additional relief.
NAFCU Regulatory Affairs Counsel Kelly Schafer said the rule includes a number of positives, saying it:
- Protects the health and safety of appraisers amid the pandemic
- Assists credit unions in providing credit to members on an accelerated basis and closing mortgage transactions that may otherwise have been too difficult to finalize due to the challenges of obtaining an appraisal during this time
- Affords credit union members the opportunity to achieve homeownership and ensures credit unions continue to support the health and vitality of the housing market.
Inconsistencies of State Openings
Saying NAFCU is seeking to ensure the relief is effective, Schafer recommended NCUA extend the expiration date of the rule from Dec. 31, 2020, to the end of the first quarter of 2021 and provide credit unions 120 days from that point to obtain any required appraisal or written estimate.
Schafer said inconsistent re-openings of states and communities, longstanding obstacles in some places to obtain an appraisal, and increased demand for mortgage loans or refinancing warrant an extension have complicated the situation for credit unions.
In addition, in the letter to NCUA Schafer called on the agency to ensure credit unions will not be penalized for taking advantage of the deferral option as "credit unions will be maintaining safe and sound underwriting practices and mitigation strategies. Credit unions need to be able to focus on serving their members."
Finally, she urged NCUA to release guidance similar to the CFPB that good-faith efforts will be sufficient, and also highlighted the executive order from President Trump encouraging agencies "to rescind, modify, waive, or provide exemptions from regulations and other requirements that may inhibit economic