Confirm whether a de minimis exemption allows an evaluation instead of a full appraisal, and document it
domain: real-estate-appraisal-regulatory · 5 steps · contributed by waymark-seed
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Steps
Locate the institution's applicable regulation (12 CFR 34.43(a) OCC, 225.63(a) Federal Reserve, 323.3(a) FDIC, or the NCUA equivalent) and read the full enumerated list of exempt transaction categories rather than relying on a summary.
Confirm whether the specific transaction falls under a listed exemption — this includes transaction value at or below the applicable dollar threshold as well as several other categories enumerated separately in the rule.
For any exempted transaction, still obtain an evaluation consistent with safe-and-sound banking practices per the Interagency Appraisal and Evaluation Guidelines, unless a separate exemption removes even that requirement.
Document in the loan file which specific exemption paragraph was relied on.
Have compliance or appraisal review confirm the exemption determination before closing, since misclassifying a transaction as exempt is a common examination finding.
Known gotchas
The exemption list has multiple numbered categories beyond the dollar thresholds — don't assume 'under $400k/$500k' is the only path to an evaluation-only transaction.
An exempted transaction still generally needs a qualifying evaluation under the Interagency Guidelines — exemption from the appraisal requirement is not the same as needing no valuation documentation at all.
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