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30 State Appraisal Organizations Respond to the proposed rule change of raising the De Minimis.
The Louisiana Real Estate Appraisers Coalition in collaboration with 29 other state appraiser organizations engaged Constantine and Cannon a highly respected Governmental Affairs firm in Washington D.C. to submit comments on the proposed rules change. 

Constantine and Cannon has extensive experience representing clients before government legislatures and agencies and TODAY o n behalf of the thirty listed state appraiser organizations they  respectfully submitted comments in opposition to the Notice of Proposed Rulemaking by the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation ("the agencies") to raise the de minimis exemption for appraisals for federally-related residential real estate transactions from $250,000 to $400,000. 

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The Following States are part of the Network of State Appraiser Organizations that supported this letter: 

Louisiana Real Estate Appraiser Coalition 
Appraiser's Coalition of Washington New York Coalition of Appraiser Professionals
Association of Georgia Real Estate Appraisers North Carolina Real Estate Appraiser Association
Arizona Association of Real Estate Appraisers North Dakota Appraisers Association
Arkansas Appraisers Association Northern Colorado Association of Real Estate Appraisers
California Coalition of Appraisal Professionals Ohio Coalition of Appraisal Professionals
Coalition of Appraisers in Nevada Oklahoma Professional Appraisers' Coalition
Delaware Association of Appraisers Professional Appraisers Association of South Dakota
Georgia Coalition of Appraisal Professionals Real Estate Appraisers Association (CA)
Idaho Coalition of Appraisal Professionals Real Estate Appraisers of Southern Arizona
Illinois Coalition of Appraisal Professionals Rhode Island Real Estate Appraiser Association
Kentucky Association of Real Estate Appraisers South Carolina Professional Appraisers Coalition
Tennessee Appraiser Coalition
Maryland Association of Appraisers United Appraisers of Utah
Michigan Coalition of Appraisal Professionals Virginia Coalition of Appraiser Professionals
Mississippi Coalition of Appraisers 
West Virginia Council of Appraiser Professionals

The Appraiser Organizations believe that, for the reasons set out in the attached letter, the NPRM's
proposal to increase the de minimis exemption to $400,000 should not be adopted. 

The NPRM attempts to justify increased use of evaluations as a cheaper-faster means of ordering valuations.

Such a justification disregards the Dodd-Frank Act's consumer protection mandates and puts at
risk the very low-income and first-time buyers who most deserve the informational benefits and
USPAP assurances that appraisals provide. Moreover, the agencies' efforts to reduce the number of required appraisals is part of a misguided effort to deal with a claimed appraiser shortage by reducing appraisal demand. Such efforts could more appropriately be focused on agency outreach to the lender and appraiser communities to better understand potential concerns over cost and time for home valuations.

The Appraiser Organizations further request that a hearing be held to more fully explore
these issues prior to the agencies finalizing this rulemaking proceeding. As set out above,
alternatives that could be considered include developing regional de minimis standards that
reflect the wide variations of median home prices, for example, among metropolitan areas and
between urban and rural parts of a state.

Call To Action
Today is the last day to comment personally on this proposal to increase the residential threshold level  from $250,000 to $400,000 that   would not requi re a real estate appraisal. The more comments they received the better.  
From OCC and FDIC
The OCC, Board, and FDIC (collectively, the agencies) will be inviting comment on a proposed rule to amend the agencies' regulations requiring appraisals for certain real estate-related transactions. 

The proposed rule would increase the threshold level at or below which appraisals would not be required for residential real estate-related transactions from $250,000 to $400,000. 

Consistent with the requirement for other transactions that fall below applicable thresholds, regulated institutions would be required to obtain an evaluation of the real property collateral that is consistent with safe and sound banking practices. 

The proposed rule would make conforming changes to add transactions secured by residential property in rural areas that have been exempted from the agencies' appraisal requirement pursuant to the Economic Growth, Regulatory Relief and Consumer Protection Act to the list of exempt transactions. 

The proposed rule would require evaluations for these exempt transactions. Pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act, the proposed rule would amend the agencies' appraisal regulations to require regulated institutions to subject appraisals for federally related transactions to appropriate review for compliance with the Uniform Standards of Professional Appraisal Practice.

This proposal could have a tremendous impact on the safety & soundness of the banking sector, housing sector and consumer protection. The comment period is open now.


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