Federal Banking Agencies Propose Raising Threshold for Requiring Appraisals for Certain Types of Loans

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The five federal banking regulatory agencies – Office of the Comptroller of the Currency (OCC), Federal Reserve Bank (FRB), Federal Deposit. Are certain types of business loans equal to or less than $1 million; 3) Involve an existing line of credit where there is no advancement of. 5 Interagency Appraisal & Evaluation Guidelines.

The final rule will raise the appraisal threshold for commercial real estate transactions from $250,000 to $500,000. Any commercial real estate transaction with a value in excess of the $500,000 threshold is required to have an appraisal by a state licensed or state certified appraiser.

[Gary Gorton:] The output of banks is money, in the form of short-term debt which is used to store value or used as a transaction medium. Such money is backed by a portfolio of bank loans. a.

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I’ve read a number of posts where appraisers are disappointed at federal banking agencies declining to hold public hearings on the topic of raising the appraisal minimum threshold for residential real estate transactions from $250,000 to $400,000.. The request for a public hearing on the issue was ‘worth a shot’ but was never a realistic expectation.

Most significantly, the act requires the agencies to develop a simple. billion and greater in assets) and certain savings and loan holding companies based on risk. The proposed framework identifies four categories of firms based on. issued a proposal to raise the threshold requiring an appraisal on all.

The new proposed subsection (j) in the circulated draft would exempt certain loans from the basic requirements of 15 U.S. C. 1639(c)(a), which establishes a creditor’s obligation to make a good faith effort to determine that the borrower can fulfill the terms of the loan as offered.

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The National Credit Union Administration is proposing to add an additional payday alternative loan option for federal. PAL II loans can qualify under the “alternative loan” exemption under the CFPB.

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