Lake Thoughts for Your Thursday AM

June 1, 2017 at 7:52 am 1 comment

Greetings from the Sagamore on Lake George where the Association is hosting its 100th anniversary. I’m more of a Hamilton than a Jefferson guy but TJ was spot on when he called Lake George “without question” the most beautiful water he had ever seen.

The need to help people of modest means strive for financial security is as pressing today as it was 100 years ago. What has changed is the economy. Here is a factoid from today’s NY Times: a study of 250,000 bank accounts by JP Morgan/Chase Institute found that 80% of households face a mismatch between income and expenses in a given month. The break-even point is about $105,000. Translation: There are many middle class folks out there for whom every penny counts and for whom cost effective banking is a real life saver.

The nation has become so entangled in regulations that rural parts of the country are finding it hard to find enough qualified appraisers to get mortgages processed in a timely manner. Who knew?

Since 1989. presumably in response to the S &L crisis, federal law has required states to set minimum standards for appraisers and appraisals. Over the last two and a half years these requirements have been a bone of contention for lenders in rural communities who argue that licensing requirements are overly burdensome, particularly in the age of Zillow.

A joint guidance issued yesterday by federal financial regulators including the NCUA highlights two existing options that may address appraiser shortages, particularly in rural areas:  a temporary practice permits and temporary waivers.

First, federal law generally requires the state appraiser certifying or licensing agency to recognize the certification or license of an appraiser issued by another state on a temporary basis. As a result, subject to certain exceptions,  practice permits could allow state certified or licensed appraisers to provide their services in states where they are not certified or licensed, including those experiencing a shortage of appraisers.

In addition, federal law already permits the FFIEC to grant a temporary waiver from state licensing requirements in geographic areas where a shortage of appraisers has led to “significant delays” in appraisal shortages.  Requests for waivers  can be made by:

  • A federal bank regulatory agency;
  • A regulated financial institution or credit union; or
  • ther persons or institutions with a demonstrable interest in appraiser regulation.

On that note, I hope to see you over the next few days.

Entry filed under: General, Mortgage Lending, Regulatory. Tags: , .

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1 Comment Add your own

  • 1. Anthony Demangone  |  June 1, 2017 at 8:56 am

    My parents honeymooned there back in 1960! A great place.


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Authored By:

Henry Meier, Esq., Senior Vice President, General Counsel, New York Credit Union Association.

The views Henry expresses are Henry’s alone and do not necessarily reflect the views of the Association. In addition, although Henry strives to give his readers useful and accurate information on a broad range of subjects, many of which involve legal disputes, his views are not a substitute for legal advise from retained counsel.

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