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June 10, 2014 – NAFCU on Monday told NCUA that inclusion of the agency and federally insured credit unions in an interagency proposed rule on appraisal management companies is confusing and should be corrected in any final rule.

The interagency rule is called for under the Dodd-Frank Act, which specifically requires each prudential regulator represented on the Financial Stability Oversight Council to sign off on it. NCUA has itself noted this rule has no direct application to credit unions.

NAFCU Regulatory Affairs Council Alicia Nealon recommended the clarification in a letter to NCUA on the proposed rule. Nealon also took the opportunity to urge some relief from certain appraisal requirements that do affect credit unions. She points specifically to the duplication of CFPB and NCUA rules on providing members copies of appraisal reports.

NAFCU includes these requirements on its "Dirty Dozen" list of rules deemed to be overly burdensome and good candidates for change or elimination.