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Has any relief been provided from the requirement that banks obtain an appraisal or evaluation on residential and commercial real estate properties affected by COVID-19 prior to closing the loan?

Yes. On April 14, 2020, the FDIC, FRB and OCC issued an interim final rule that temporarily defers
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, excluding transactions
for acquisition, development, and construction of real estate. Regulated institutions should make
best efforts to obtain a credible valuation of real property collateral before the loan closing, and
otherwise underwrite loans consistent with the principles in the agencies' Standards for Safety and
Soundness and Real Estate Lending Standards. This temporary change to the appraisal rules
expires on December 31, 2020.

 

Interim Final Rule - Facilitating Real Estate-Related Transactions Affected by COVID-19
FDIC FIL-43-2020 https://www.fdic.gov/news/financial-institution-letters/2020/fil20043.html

The final rule, issued September 29, 2020, makes one revision to the interim final rule by clarifying
that transactions for the acquisition, development, and construction of real estate excluded from the
120-day deferral period mean, for purposes of this rule, those loans described in the Call Report
Instructions for Schedule RC-C, Part I, item 1.a.

Final Rule – Real Estate Appraisal and Evaluation Deferral (Agencies Adopt Final Rule on Certain
Real Estate Transactions for Financial Institutions and Consumers Affected by the Coronavirus)
FDIC FIL-94-2020 https://www.fdic.gov/news/financial-institution-letters/2020/fil20094.html

The FDIC, FRB, OCC, NCUA and CFPB, in consultation with the state financial regulators, also
issued an Interagency Statement on Appraisals and Evaluations for Real Estate Related Financial
Transactions Affected by the Coronavirus. The Statement outlines existing flexibilities provided by
industry appraisal standards and the agencies' appraisal regulations and highlights temporary
changes to Fannie Mae and Freddie Mac appraisal standards to facilitate real estate transactions.

Interagency Statement on Appraisals and Evaluations for Real Estate Transactions Affected by the
Coronavirus https://www.fdic.gov/news/news/press/2020/pr20051b.pdf