Illinois Department of Financial and Professional Regulation issues guidance to credit unions regarding deferral of an appraisal or written estimate of market value

State Issues Covid-19 Illinois Credit Union NCUA Appraisal Bank Compliance

On May 1, the Illinois Department of Financial and Professional Regulation issued guidance to credit unions regarding the deferral of an appraisal or written estimate of market value to allow credit unions to continue to extend loans to households and businesses during the Covid-19 crisis. The guidance notes that the National Credit Union Administration (NCUA) Board promulgated an interim final rule allowing a federal credit union to temporarily defer certain appraisals and written estimates of market value for up to 120 days after closing when other alternatives are not available and when the appraisal or evaluation would delay the closing of the transaction, and states its intention to promulgate a substantially similar rule. Until the rule has been promulgated and finalized, the department does not intend to take adverse supervisory or enforcement action against an Illinois state-chartered credit union for deferring the appraisal or written estimate of market value for appropriate transactions up to 120 days from the date of closing, subject to certain exceptions. The guidance provides additional requirements for credit unions to follow when seeking to take advantage of this exemption.