On December 3, 2018, NAR submitted comments to the National Credit Union Administration (NCUA) in response to a proposal to raise the threshold for requiring an appraisal in commercial real estate transactions to $1,000,000 from the current level of $250,000.
NAR believes an increase to $500,000 would be appropriate at this time. This would align the NCUA policy with that of the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation. This increase would only apply to Federally Related Transactions (FRTs) within NCUA's member institutions. FRTs do not include any loans sold to Fannie Mae or Freddie Mac, nor those under government programs, such as loans insured by the Federal Housing Administration, the Department of Veterans Affairs, and the US Department of Agriculture.