January is deadline for comments on appraisals, remittance threshold

Credit union should be aware comments on proposals from both NCUA and the Consumer Financial Protection Bureau (CFPB) are due in January. NCUA issued a proposed rule in November that would raise the threshold for which an appraisal is required for a residential real estate transaction to $400,000, up from the current $250,000. Transactions that fall below the threshold would require a written estimate of market value of the real estate collateral that is consistent with safe and sound banking practices.

The NCUA board previously finalized a CUNA-backed rule making changes to the appraisal rule to provide relief for commercial real estate transactions and enhancing clarity within the rule, and CUNA requested the agency provide additional relief.

Comments on the proposal are due to NCUA by Jan. 28. Other comment deadlines this month include:

• Jan. 21: CFPB proposal to raise the “normal course of business” threshold to 500 remittances per year, up from 100. CUNA has called for it to be raised to at least 1,000, but considers the proposal a positive step forward; and
• Jan. 21: CFPB request for comment on its assessment of the Truth in Lending Act-Real Estate Settlement Procedures Act Integrated Disclosure (TRID) rule. The CFPB seeks comment on its assessment plan, as well as information and recommendations that may be useful while it conducts the assessment.