WASHINGTON (8/21/14)--The Credit Union National Association generally supports the National Credit Union Administration's proposed changes to appraisal requirements, according to a comment letter filed Tuesday.
The rule, which was proposed at the agency's June board meeting, would expand the current exemption in existing appraisal regulations to allow credit unions to refinance or modify a real estate-related loan in a declining housing market without having to obtain an additional appraisal.
CUNA first recommended changes to the NCUA's appraisal requirements in its 2013 regulatory review comment letter. The trade group's latest comment letter also offers additional suggestions for a few technical changes to the proposal.
"We request that NCUA's final rule clarify that the 'written estimate of market value,' required for exempt transactions, be satisfied by an estimated market value based on an automated valuation model," the letter reads. "This change would be consistent with the 2010 Federal Financial Institutions Examination Council's interagency appraisal and evaluation guidelines."
The NCUA's proposed rule would also eliminate a now duplicative requirement that federal credit unions make available, to any requesting member, a copy of the appraisal used in connection with that member's application for a loan secured by a first lien on a dwelling.
CUNA supports this part of the proposed rule as well, stating it will reduce regulatory burden for credit unions, a top priority for the association.
Use the resource link to access the letter.