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On February 5, 2018, NAR submitted comments to the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (collectively “the Agencies”) on the threshold for requiring an appraisal in commercial real estate transactions to $400,000 from the current level of $250,000. NAR urged the Agencies that any appraisal threshold be tied to an area's real estate market, and that a national appraisal threshold level is inappropriate given the wide discrepancy in home values across the country. Specifically, NAR suggested the agencies set the appraisal threshold level to 50 percent of the GSE conforming loan limits. This would allow high value areas more room for other forms of valuations without putting undue risk in many other markets that would no longer require an appraisal for the majority of home sales.
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