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

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In September 2017, the federal banking agencies issued a proposed rule intended to reduce regulatory burden by simplifying certain requirements for non-advanced approaches banking organizations (i.e., banking organizations with less than $250 billion in total consolidated assets or with less than $10 billion of on-balance sheet foreign exposures) (the “simplification capital proposal”), including the Company.

On December 4, the three federal banking agencies requested comment on a proposal to raise the threshold for residential real estate transactions requiring an appraisal from $250,000 to $400,000. In lieu of an appraisal, an evaluation consistent with safe and sound banking practices would be required.

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Final rule follows ICBA calls for relief benefiting local communities. washington, D.C (April 2, 2018)-The Independent Community Bankers of America (ICBA) today thanked regulators for heeding community banker concerns in easing real estate appraisal mandates for certain transactions. As advocated by ICBA, the federal banking agencies raised the transaction-value threshold requiring.

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may be required by the Administration or the lender in connection with any such loan, if such loan is in an amount equal to or less than the Federal banking regulator appraisal threshold, if such appraisal is necessary for appropriate evaluation of creditworthiness.

Federal banking agencies issue final rule to exempt commercial real estate transactions of $500,000 or less from appraisal requirements. The agencies originally proposed to raise the threshold, which has been in place since 1994, to $400,000, but determined that a $500,000 threshold will materially reduce regulatory burden and the number.

However, these transactions are required to be reported as loans in accordance with. opinion rendered by the investment banking firm hired by the Company’s board of directors, and independent third.

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