On behalf of its members, NRMLA submitted comments to the Department of Housing and Urban Development that recommended recent changes to the appraisal validity period apply to HECM servicers and that FHA Connection’s automatic case number cancellation procedures be updated to reflect the extended timeframes.
Mortgagee Letter 2022-11, published on July 12, extends the initial appraisal validity period from 120 days to 180 days and the appraisal update validity period from 240 days to one year for most FHA Title II mortgages and HECMs.
In its comments, NRMLA says the policy changes detailed in ML 2022-11 are very much welcomed, as increasing appraisal validity periods decreases the administrative and financial burdens associated with obtaining appraisal updates, which in turn help mitigate mortgage origination and servicing costs incurred by borrowers.
“Unfortunately, the Mortgagee Letter does not address the extension of appraisal validity periods in the context of the Servicing and Loss Mitigation of HECMs,” says NRMLA. “We believe that HUD’s failure to specifically address the extension of ‘as-is’ appraisal reports required for HECM Short Sale and HECM liquidation claim transactions may be an oversight.” NRMLA requested that HUD clarify the matter.
Read the full letter by logging into the Comment Letters section of NRMLAonline.org.