The source and use of a federal appraisal panel’s temporary waiver authority regarding state appraisal programs are detailed in a frequently asked questions (FAQ) document published recently on the panel’s website.
The Appraisal Subcommittee (ASC) of the Federal Financial Institutions Examination Council (FFIEC) this summer approved a temporary waiver of appraisal credentialing requirements in North Dakota for appraisals of federally related transactions under $500,000 involving 1-to-4 family residential real estate. That waiver, approved for one year, has since been terminated in light of changes to appraisal exemption threshold limits by banking regulators under the passage of appraisal provisions in the 2018 Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA, S. 2155).
The panel’s approval of the North Dakota waiver request (including a waiver related to commercial real estate transactions, still in place) drew consternation from the Democratic leaders of the House Financial Services Committee and Senate Banking Committee, who wrote to the head of the ASC in September seeking answers.
The ASC’s website doesn’t show any response that may have followed the letter, but the FAQ, dated Dec. 6, provides responses to 15 questions, all related to the ASC’s temporary waiver authority and related considerations.
Letter from House Financial Services Chairwoman Maxine Waters (D-Calif.) and Senate Banking Ranking Member Sherrod Brown (D-Ohio) (Sept. 24, 2019)
RR: Real estate appraisal waiver for North Dakota kicks in (Aug. 7, 2019)