On September 25, 2017 NAR submitted a comment letter to Acting Comptroller of the Currency Keith Noreika, Federal Reserve Chair Yellen and FDIC Chair Gruenberg. The letter addreses the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, and the Office of the Comptroller of the Currency (collectively, the Agencies') Proposed Rule to increase the current appraisal threshold for federally related commercial real estate transactions from $250,000 to $400,000. NAR agrees with the Agencies that an increase to the commercial appraisal threshold is appropriate at this time. Appraisals are integral to the safety and soundness of the real estate industry. As NAR states in its Responsible Valuation Policy, a trustworthy valuation of real property ensures the real property value is sufficient to collateralize the mortgage, protect the mortgagor, allow secondary markets to have confidence in the mortgage products and mortgage-backed securities, and build public trust in the real estate profession.
NAR Comment Letter to OCC, FDIC, and the Board of Governors on a Proposed Rule regarding Real Estate Transactions Appraisals
Issue Date: September 25, 2017
On September 25, 2017 NAR submitted a comment letter to Acting Comptroller of the Currency Keith Noreika, Federal Reserve Chair Yellen and FDIC Chair Gruenberg. The letter addreses the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, and the Office of the Comptroller of the Currency (collectively, the Agencies') Proposed Rule to increase the current appraisal threshold for federally related commercial real estate transactions from $250,000 to $400,000. NAR agrees with the Agencies that an increase to the commercial appraisal threshold is appropriate at this time. Appraisals are integral to the safety and soundness of the real estate industry. As NAR states in its Responsible Valuation Policy, a trustworthy valuation of real property ensures the real property value is sufficient to collateralize the mortgage, protect the mortgagor, allow secondary markets to have confidence in the mortgage products and mortgage-backed securities, and build public trust in the real estate profession.
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