Federal Banking Agencies Propose Raising Threshold for Requiring Appraisals for Certain Types of Loans

State regulators appreciate the opportunity to comment on the proposed rulemaking introduced by the OCC, Board and FDIC ("the Agencies") to amend the Agencies’ regulations requiring appraisals of real estate for certain transactions. The proposal does not increase the threshold for residential real estate transactions, but solicits.

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Raising the Appraisal Threshold for commercial real estate Loans. In July 2017, the agencies issued a notice of proposed rulemaking to raise the threshold for commercial real estate transactions requiring appraisals from $250 thousand to $400 thousand. The comment period closed in September 2017. The agencies are reviewing

Federal Banking Agencies Propose Raising Threshold for Requiring Appraisals for Certain Types of Loans. If approved, this would be the first increase in the threshold since 1994 but would only be applicable for commercial real estate loans. The thresholds for consumer real estate loans and commercial business loans where real estate collateral is taken would remain unchanged.

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For the payment of compensation, benefits, and expenses (except administrative expenses) accruing during the current or any prior fiscal year authorized by 5 U.S.C. 81; continuation of benefits as provided for under the heading “Civilian War Benefits” in the Federal Security Agency Appropriation Act, 1947; the Employees’ Compensation.

In accordance with the EGRPRA, the Federal Reserve, the other federal bank regulatory agencies, 4 and the FFIEC have launched a review to identify banking regulations that are outdated, unnecessary, or unduly burdensome.

 · July 26, 2017 Federal Banking Agencies Propose Raising CRE Appraisal Threshold The Federal Reserve Board, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency on July 19 issued a notice of proposed rulemaking to increase to $400,000 the threshold for commercial real estate transactions requiring an appraisal.

Federal Banking Agencies Propose Raising Threshold for Requiring Appraisals for Certain Types of Loans. If approved, this would be the first increase in the threshold since 1994 but would only be applicable for commercial real estate loans. The thresholds for consumer real estate loans and commercial business loans where real estate collateral is taken would remain unchanged.

On December 4, the three federal banking agencies requested comment on a proposal to raise the threshold for residential real estate transactions requiring an appraisal from $250,000 to $400,000. In lieu of an appraisal, an evaluation consistent with safe and sound banking practices would be required.