Final Interagency Appraisal and Evaluation Guidelines

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On December 2, 2010, five federal banking agencies – the Office of the Comptroller of the Currency (OCC), Federal Reserve Board (FRB), Federal Deposit Insurance Corporation (FDIC), Office of Thrift Supervision (OTS) and National Credit Union Administration (NCUA) (collectively, the “Banking Agencies”) – issued their long awaited revision to the Interagency Appraisal and Evaluation Guidelines (“Guidelines”) that were first issued in 1994. The Guidelines, which are applicable to regulated banking institutions, identify the components of a safe and sound program for performing appraisals and evaluations for real estate-related financial transactions. This Client Alert summarizes the Guidelines and discusses their ramifications.

The original Guidelines were jointly issued in October 1994 by the OCC, FRB, FDIC and OTS. Those Guidelines provided guidance on implementing the appraisal regulations promulgated in accordance with Title XI of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (FIRREA). See, e.g., 12 C.F.R. Part 34, subpart C (OCC regulations).

Please see full client alert below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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