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Following the NCUA's interim final rule allowing credit unions to defer the requirement to obtain an appraisal or evaluation for up to 120 days following the closing of a transaction for certain residential and commercial real estate transactions amid the coronavirus pandemic, NAFCU's Kaley Schafer offered recommendations to further support that relief.

Schafer, NAFCU's regulatory affairs counsel, outlined several positives of the rule, including that it:

• protects the health and safety of appraisers amid the pandemic;
• assists credit unions in providing credit to members on an accelerated basis and closing mortgage transactions that may otherwise have been too difficult to finalize due to the challenges of obtaining an appraisal during this time; and
• affords credit union members the opportunity to achieve homeownership and ensures credit unions continue to support the health and vitality of the housing market.

To ensure this relief is effective, Schafer recommended the NCUA extend the expiration date of the rule from Dec. 31, 2020, to the end of the first quarter of 2021 and provide credit unions 120 days from that point to obtain any required appraisal or written estimate.

She highlighted how inconsistent re-openings of states and communities, longstanding obstacles in some places to obtain an appraisal, and increased demand for mortgage loans or refinancing warrant an extension.

In addition, she asked the NCUA to ensure credit unions will not be penalized for taking advantage of the deferral option as "credit unions will be maintaining safe and sound underwriting practices and mitigation strategies. Credit unions need to be able to focus on serving their members."

She recommended the NCUA release guidance similar to the CFPB that good-faith efforts will be sufficient, and also highlighted the executive order from President Donald Trump encouraging agencies "to rescind, modify, waive, or provide exemptions from regulations and other requirements that may inhibit economic recovery."

Read Schafer's full letter.

NAFCU will continue to work with the NCUA and other regulators to ensure immediate action is taken to provide credit unions with much needed relief in the wake of the coronavirus pandemic.