The federal bank regulatory agencies have proposed to increase the residential appraisal threshold level from $250,000 to $400,000, exempting nearly three quarters of residential real estate related financial transactions from appraisal requirements.
Appraisers across the country are uniting to protect safety and soundness – and to keep the threshold where it is.
In 2017, the exact same proposal was evaluated and answered in compliance with The Economic Growth and Regulatory Paperwork Reduction Act of 1996, known as EGRPA. This federally mandated regulatory relief process encompassed four different notice and comment periods and six public hearings.
From that process, the same agencies – Office of the Comptroller of the Currency, the Federal Reserve, and the Federal Deposit Insurance Corporation – decided it “would not be appropriate” to increase the threshold from $250,000 based on safety and soundness and consumer protection considerations.
Now – in an apparent attempt to pacify rural community banks – the agencies will increase the threshold … unless they hear convincing comments and evidence from stakeholders, including consumers and appraisers like you.
Standing unified in opposition to the proposal, a coalition of nationally recognized professional appraisal organizations will be submitting comments on the proposal. These organizations encourage you to do the same by the Feb. 5 comment deadline.
Besides the Appraisal Institute, other organizations opposing the proposed increase in residential appraisal thresholds are: American Society of Appraisers; American Society of Farm Managers and Rural Appraisers; MBREA, The Association for Valuation Professionals; American Guild of Appraisers, OPEIU, AFL-CIO; Appraisers’ Coalition of Washington; California Coalition of Appraisal Professionals; Illinois Coalition of Appraisal Professionals; Louisiana Real Estate Appraiser Coalition; National Association of Realtors; North Carolina Real Estate Appraiser Association; Northern Colorado Association of Real Estate Appraisers; North Dakota Appraiser Association; Ohio Coalition of Appraisal Professionals; RICS; South Carolina Professional Appraisers Coalition; Tennessee Appraiser Coalition; and Utah Coalition of Appraisal Professionals.
You can learn more by reading the federal banking agencies’ proposed rule.
If you have an “opinion of value,” please share your comments.