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Regulatory Proposals


AI ACTION ALERT

Express Your Views In Support of Sound Collateral Valuation

Under the auspices of a once every 10 year review of the “Paperwork Reduction Act,” the federal financial institution regulatory agencies are accepting comments on interagency regulations relating to safety and soundness, including real estate appraisals. In outreach meetings hosted by the agencies during 2015, the agencies received suggestions by some segments of the banking community to increase the current appraisal threshold levels in support of regulatory relief.

The Agencies open comment request is your opportunity to express your view on the appraisal thresholds. AI professionals – particular those working for banks and financial institutions - are encouraged to express opposition increases in the appraisal threshold levels to support safe and sound lending. 

Click here to view the Notice of Regulatory Review.

To leave a comment on the Federal Banking Regulators Proposed Rule, please take the following easy steps:

1.     Click here.

2.     Please copy & paste the text below into the section marked “Comment”.

The Agencies have received suggestions by some representatives of the banking industry to increase the current threshold levels for when appraisals are required under federal law. I believe such a move would increase risk to regulated banks and consumers. This is confirmed by a recent survey of bank chief appraisers and appraisal managers, which indicted:

·         A strong majority (76.6 percent) of chief appraisers/appraisal managers strongly or somewhat disagrees with raising the $250,000 threshold level.

·         An overwhelming majority (87.5 percent) of chief appraisers/appraisal managers strongly or somewhat disagrees with raising the $1,000,000 owner-occupied commercial real estate threshold level.

·         An overwhelming majority (89.1 percent) of chief appraisers/appraisal managers strongly or somewhat agrees that raising threshold levels could increase risk to lenders.

·         A strong majority (80.5 percent) of chief appraisers/appraisal managers strongly or somewhat agrees that raising threshold levels could increase risk to borrowers.

3.     Supplement this information with any personal observations or anecdotes which may be beneficial to the financial institution regulatory agencies.

4.       Submit your comment following instructions found on the page.

 

 

 

 

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