Archive

OCC REMINDS BANKS OF AMC REGISTRATION REQUIREMENTS

The OCC has issued a bulletin (2019-43) reminding banks of the registration requirements for Appraisal Management Companies (AMC), which was effective August 10, 2019. The Dodd-Frank Act and implementing federal regulations provides minimum requirements to be applied by states in the registration and supervision of AMCs. As a result, AMCs (overseeing more than 15 appraisers in a single state or 25 or more appraisers nationally) must be registered in the state(s) in which they do […]

AGENCIES ISSUE PROPOSAL TO INCREASE RESIDENTIAL APPRAISAL THRESHOLD

On November 20, 2018, the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation (the Agencies) released a proposed rule to amend the appraisal requirements. Specifically, the proposal would increase the threshold for which appraisals are required on residential real estate loans, define a residential real estate transaction, include an exemption for rural real estate transactions pursuant to the Economic Growth, Regulatory Relief and […]

EGRRCPA APPRAISAL RELIEF

Section 103 of the Economic Growth, Regulatory Relief and Consumer Protection Act, which was signed on May 24, 2018, provides limited relief from appraisal requirements for certain loans. An appraisal in connection with a federally related transaction involving real property or an interest in real property is not required if: *   the real property or interest in real property is located in a rural area; *   not later than 3 days after the date on […]

APPRAISAL REVISIONS TAKE EFFECT

On April 9, 2018 the Office of the Comptroller of the Currency (OCC); Board of Governors of the Federal Reserve System (Board); and Federal Deposit Insurance Corporation (FDIC) published a final rule to amend the agencies’ regulations requiring appraisals of real estate for certain transactions. The final rule increases the threshold level at or below which appraisals are not required for commercial real estate transactions from $250,000 to $500,000 and makes other changes. The final […]

CHANGE IN APPRAISAL THRESHOLD

On March 20, 2018 the FDIC board of directors approved a final rule to raise the appraisal thresholds for commercial real estate transactions from $250,000 to $500,000. The threshold for loans secured by one-to-four family residential properties will remain at $250,000. The final rule increases the commercial real estate appraisal threshold with three modifications from the proposal. First, the agencies have increased the commercial real estate appraisal threshold to $500,000 rather than $400,000 as proposed. […]