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ABA: The American Bankers Association
Regulatory Proposal

NCUA: Proposed Rulemaking on Real Estate Appraisals

Published Proposal: October 2, 2018 Comments Due: December 2, 2018 Disposition: Filed

ABA Comments & Analysis

Summary of the Proposal

The National Credit Union Administration (NCUA) is proposing to amend the agency’s regulation requiring real estate appraisals for certain transactions. The proposed rule would accomplish four objectives: 

  • First, the proposed rule would increase the threshold below which appraisal would not be required for non-residential real estate transactions from $250,000 to $1,000,000. 
  • Second, the proposed rule would restructure the NCUA’s appraisal regulation to clarify its requirements for the reader. 
  • Third, the proposed rule would exempt from the NCUA’s appraisal regulation certain federally related transactions involving real estate where the property is located in a rural area, valued below 400,000, and no state certified or licensed appraiser is available. 
  • Finally, the proposed rule would also make certain conforming amendments to the definitions section.

ABA staff is working on researching and messaging issues regarding any impact to ABA member banks, safety and soundness issues that implementing these changes may pose to the markets, as we look to file our comment letter on the proposed rule.

Agency Material

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Sharon Whitaker

Sharon Whitaker

Vice President, Commercial Real Estate & Finance

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