No Appraisal Needed

[CaliforniaNative]

FDIC to change de minimis From 250 to 400K

"Financial Institution Letters
FIL-76-2018
November 21, 2018
Appraisal Threshold for Residential Real Estate Loans
Printable Format:
FIL-76-2018 - PDF (PDF Help)
Summary:
The FDIC, the Board of Governors of the Federal Reserve System, and the Office of the Comptroller of the Currency (the Agencies) are jointly issuing a notice of proposed rulemaking titled Real Estate Appraisals (Appraisal NPR), which will be published in the Federal Register for a 60-day comment period. The Appraisal NPR proposes to increase the threshold for residential real estate transactions requiring an appraisal from $250,000 to $400,000. Evaluations would be required for transactions exempted as a result of the proposed threshold. The NPR also would add section 103 of the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRCPA) to the list of exempt transactions in the appraisal regulations, require evaluations for these exempt transactions, and require institutions to subject appraisals to appropriate review for compliance with the Uniform Standards of Professional Appraisal Practice (USPAP).
https://www.FDIC.gov/news/news/financial/2018/fil18076.html

A petition has been started with good response:
https://www.change.org/p/federal-re...loans-we-don-t-trust-banks-without-appraisers

 

[Bob Ipock]

For all these years with a 250 K threshold lenders continued to require appraisals. 1) The borrower was paying and 2) Nobody will buy a loan without an appraisal.

 

[George Hatch]

Everyone knows what happens when lenders make marginal deals that are based on incompetent/unreasonable value conclusions. Whether from a Zillow or a BPO or a sub-performing appraiser. Once they close, those transactions go on to dirty the waters of the datasets we're using and make our jobs more complicated.

The investors who choose poorly in their decision making will get burned. Meanwhile in our regular assignments our users continue to ask for more and more analysis and content.

 

[J Grant]

Most of you guys wanted this admin with its anti regulation and anti consumer protection stance...what happened, you don't like it when it deregulates your own profession into the marginalized zone?

 

[Michigan CG]

Most of you guys wanted this admin with its anti regulation and anti consumer protection stance...what happened, you don't like it when it deregulates your own profession into the marginalized zone?

Surely you are not naive enough to know that the lobbyists would have pushed this no matter who was in office? Surely you know that if the loan is sold to FNMA that an appraisal is required? Surely you know the number of mortgages affected will be small. The last time the de minimis was changed was when Clinton was in office.

 

[ucbruin]

Most of you guys wanted this admin with its anti regulation and anti consumer protection stance...what happened, you don't like it when it deregulates your own profession into the marginalized zone?

While I have zero objections to "kicking them while they're (whomever they are) down"....

This was probably going to happen eventually.....

 

[Terrel L. Shields]

These proposals were being made years ago. Inevitable.

 

[nstanbru]

Most of you guys wanted this admin with its anti regulation and anti consumer protection stance...what happened, you don't like it when it deregulates your own profession into the marginalized zone?

This proposal is still regulation, not anti-regulation. As Terrel stated, the regulators have been trying to do this for years.

 

[Pittsburgh Pete]

This proposal is still regulation, not anti-regulation. As Terrel stated, the regulators have been trying to do this for years.

So omitting some work from the current required regulation is a regulation so there is no deregulation?

 

[George Hatch]

Not that anyone cares, but the primary reason I won't sign that petition is because of the partisan political reference in it.