Compliance Blog

Written by JiJi Bahhur, Regulatory Compliance Counsel

Earlier this week, several agencies (Agencies) – including the Consumer Financial Protection Bureau (CFPB) and the National Credit Union Administration (NCUA) – released a supplemental proposal on appraisals for higher-priced mortgage loans (Supplemental Proposal). 

The proposal relates to the 2013 Interagency Appraisals final rule (Final Rule), which goes into effect on January 18, 2014.  Among other requirements, the Final Rule requires creditors to obtain an appraisal or appraisals for certain mortgages that meet the definition of a higher-priced mortgage.  In part, the Supplemental Proposal would amend the Final Rule to include exemptions from the appraisal rules in the following instances: transactions secured by existing manufactured homes and not land; certain “streamlined” refinancings; and transactions of $25,000 or less (indexed for inflation). 

For more information on these exemptions and what other amendments are contained within the proposal, you can access the Supplemental Proposal here.  Also, NAFCU’s Regulatory Affairs team will be releasing a Regulatory Alert (NAFCU Member log-in required) on the proposal very soon, so keep an eye out for that. 

If the proposal is finalized, the intent of the Agencies is for these exemptions to become effective on January 18, 2014, the same date on which the Final Rule will become effective.