After tomorrow's amendments, 225.63(b) -- in FRB Reg Y and in differently numbered sections of the OCC and FDIC rules -- will still read: "(b) Evaluations required. For a transaction that does not require the services of a State certified or licensed appraiser under paragraph (a)(1), (a)(5), (a)(7), or (a)(14) of this section, the institution shall obtain an appropriate evaluation of real property collateral that is consistent with safe and sound banking practices."
As of 1/1/20, that gets changed to: "(b) Evaluations required. For a transaction that does not require the services of a State certified or licensed appraiser under paragraphs (a)(1), (5), (7), (14), or (15) of this section, the institution shall obtain an appropriate evaluation of real property collateral that is consistent with safe and sound banking practices."
The only thing that changes is that the eval paragraph will apply to properties exempted under the rural residential exemption. And you already have the option of doing evals on those properties. The 1/1/20 amendment makes it mandatory.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8