2019-03-15
Regulatory authorities issued draft amendments to Policy Statement 45-106 to clarify the application of the offering memorandum exemption for syndicated mortgages. The changes define the borrower as the primary issuer of a syndicated mortgage and establish specific independence criteria for qualified appraisers to prevent conflicts of interest. Additionally, the amendments mandate that property appraisals disclose the fair market value without accounting for proposed improvements to ensure accurate risk assessment for investors.