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AI among groups opposing federal banking agencies' action.

The Appraisal Institute on Feb. 4 was one of six organizations that signed a comment letter that "strongly opposed" a proposal from the Federal Reserve, the Federal Deposit Insurance Corp. and the Office of the Comptroller of the Currency to raise the residential appraisal threshold from $250,000 to $400,000.

If the proposal is approved, nearly threequarters of residential real estate loans held in portfolio by depository institutions would be exempt from appraisal requirements. A high percentage of those loans are from rural areas.

The same proposal was evaluated in 2017 as part of the process of the federally mandated Economic Growth and Regulatory Paperwork Reduction Act --a regulatory relief effort that encompassed four different notice and comment periods and six public hearings. At that time, the same agencies that are now proposing the increase said it "would not be appropriate" to increase the residential threshold.

The about-face is an apparent attempt by the agencies to pacify rural community banks that received discrete relief from Congress through EGRPRA.

The valuation organizations that signed the comment letter also requested a hearing on the proposal, but the agencies denied that request, stating: "After reviewing your letter ... we do not believe that holding a public hearing would elicit relevant information that could not be conveyed through the comment process. While the agencies are, therefore, declining your request for a public hearing, we will carefully consider your written comments."

The comment period closed Feb. 5.

Voicing concerns to Congress

Appraisal Institute President Stephen W. Wagner, MAI, SRA, AI-GRS, and staff from Al's Washington office on Jan. 15 participated in bipartisan meetings with members of Congress, urging them to review a proposed increase to the residential appraisal threshold. Representatives from the American Society of Appraisers, the American Society of Farm Managers and Rural Appraisers, and MBREA | The Association for Valuation Professionals also participated in the meetings.

Joining forces

In addition to the Appraisal Institute, the comment letter was signed by:

* American Guild of Appraisers, OPEIU, AFL-CIO.

* American Society of Appraisers.

* American Society of Farm Managers and Rural Appraisers.

* MBREA | The Association for Valuation Professionals.


> Read the comment letter at

> Read the federal banking agencies' proposed rule at

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Publication:Valuation Magazine
Date:Jan 1, 2019
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