Removing Barriers Blog

CUNA Supports Increase to Residential Appraisal Threshold
Posted January 23, 2020 by CUNA Advocacy

Today, CUNA sent a letter in support of NCUA’s proposed rule to increase the threshold level below which appraisals would not be required for residential real estate-related transactions from $250,000 to $400,000. We believe increasing the residential appraisal threshold will reduce regulatory burden for credit unions, resulting in both transaction cost and time savings for credit unions and their members.

This proposal is consistent with, though not identical to, the final rule adopted last year by the federal banking regulators that increased the residential appraisal threshold to $400,000. Thus, we request NCUA adopt language identical to that included in the bank residential appraisal rule, which exempts transactions “at or below” $400,000, as opposed to the proposal that exempts transactions “below” $400,000. While minor, this is an important distinction that if adopted as proposed could continue to disadvantage credit unions.

In October 2019, CUNA sent a letter to the NCUA requesting the agency pursue a rulemaking to increase the residential appraisal threshold. We appreciate the agency’s response in issuing this proposal that would increase the residential appraisal threshold to $400,000.