Tefferi backs more appraisal rule exemptions
NAFCU Senior Regulatory Affairs Counsel Tessema Tefferi
Sept. 10, 2013 – NAFCU supports changes proposed by NCUA to exempt more credit union transactions from an interagency rule on appraisals related to higher-priced mortgage loans, NAFCU Senior Regulatory Affairs Counsel Tessema Tefferi said Monday.
Tefferi, in an official comment letter to the agency, also suggested additional rule modifications to exclude Saturdays from the definition of a “business day” and raise the maximum dollar amount of exempt transactions.
NCUA’s proposal would amend an interagency final rule issued this January on higher-priced mortgage loan appraisals. The rule will require credit unions to obtain and provide copies of appraisals of the property to which the mortgage relates. CFPB, federal banking regulators and the Federal Housing Finance Agency are all parties to the final rule.
NCUA is proposing to add to the exempt-transactions list those transactions that are secured by existing manufactured homes, and not land; certain “streamlined” refinancings; and transactions involving $25,000 or less.
Tefferi said NAFCU wants Saturdays removed from the definition of a business day because most credit unions’ back office operations are closed on Saturdays; having to treat Saturday as a business day would only add to credit unions’ regulatory burden. He also urged the agency to increase the $25,000 exemption threshold. While indexed to inflation – which NAFCU supports – the threshold is too low, Tefferi wrote.
NAFCU has urged similar rule changes of the CFPB with respect to its combined mortgage disclosures under the Truth in Lending Act and the Real Estate Settlement Procedures Act. A final TILA/RESPA rule is expected this fall.
NAFCU comment letter