Appraisal Foundation Offers Advice on In-Home Inspections During COVID-19

Appraisers are encouraged to communicate with their clients and follow public health recommendations.

3/24/20

As COVID-19 continues to spread throughout communities across the nation, the safety question of having appraisers inspect the interior of real property has come up. The Appraisal Foundation has provided the following guidance:

Appraisers and users of appraisal services should remember that the Uniform Standards of Professional Appraisal Practice (USPAP) do not require an inspection unless necessary to produce credible assignment results. (Please refer to USPAP Standards Rule1-2, Standards Rule2-2, and Advisory Opinion2 for further guidance.) When an interior inspection would customarily be part of the scope of work, a health or other emergency condition may require an appraiser to make an extraordinary assumption about the interior of a property. This is permitted by USPAP as long as the appraiser has a reasonable basis for the extraordinary assumption and as long as its use still results in a credible analysis.

Neither the Appraisal Standards Board (ASB) nor The Appraisal Foundation has the authority to suspend interior inspections. Appraisers are encouraged to communicate with their clients and follow public health recommendations (such as those issued by the CDC and World Health Organization), as well as national, state, and local government orders when performing appraisal assignments. The ASB and The Appraisal Foundation encourage lenders, regulators, government agencies, and Government Sponsored Enterprises (GSEs) to consider suspending or relaxing requirements for interior inspections during a national health emergency.

Question of the Week

Q. What are some of the legal and regulatory considerations when offering skip payment options to members?

A. In response to recent events, many credit unions will offer skip payments to their members. What should they consider as they develop skip payment programs? To answer this question, our partners at Farleigh Wada Witt have provided a brief article, which you can find here.

Legal Briefs

National Credit Union Administration (NCUA)

NCUA Actions Related to COVID-19
The NCUA has issued Letter to Credit Unions 20-CU-02 which provides insights and expectations for working with members, a FAQ related to COVID-19 NCUA and credit union operations, the NCUA’s examination and supervision program, and NCUA’s Operational Status.

NCUA Actions Related to COVID-19 – Annual Meeting Flexibility
The NCUA released Letter to Federal Credit Unions 20-FCU-02 which provides guidance and allows federal credit unions to hold virtual meetings under certain circumstances.

Interagency Statement on Loan Modifications
The NCUA and other federal financial institution regulators issued an interagency statement to provide additional information to financial institutions who are working with borrowers affected by COVID-19.

Consumer Financial Protection Bureau (CFPB)

Joint Statement on Foreclosure and Eviction Moratorium
The CFPB released a joint statement along with the U.S. Department of Housing and Urban Development and the Federal Housing Finance Agency that announced a moratorium on foreclosures and evictions.

Office of Comptroller of the Currency (OCC)

COVID-19 (Coronavirus) Information Page
The OCC has launched a coronavirus informational page which contains information, supervisory guidance, and resources related to COVID-19.

Washington State Department of Financial Institutions (DFI)

COVID-19 Resources for Washington Small Businesses
The DFI has developed a webpage that contains resources for Washington small businesses as they respond to COVID-19.

Financial Resources for Washington Residents Impacted by COVID-19
The DFI has developed a webpage that contains resources for Washington consumers impacted by the coronavirus.

Office of Foreign Assets Control (OFAC)

OFAC has updated the SDN list as of March 19. The last update prior to this was March 12.

Questions? Contact the Compliance Hotline: 1.800.546.4465; [email protected].