Bank Appraisers: Raising Appraisal Limits Could Harm Consumers – NMP Skip to main content

Bank Appraisers: Raising Appraisal Limits Could Harm Consumers

Dec 02, 2015
More than 80 percent of bank appraisers think reducing the number of loans requiring an appraisal could increase risk to borrowers

More than 80 percent of bank appraisers think reducing the number of loans requiring an appraisal could increase risk to borrowers, according to a survey of its professionals released by the Appraisal Institute. The Appraisal Institute’s research also showed that nearly 90 percent of chief appraisers and appraisal managers surveyed think raising the threshold level of loans that require an appraisal could increase risk to lenders.

Overall, more than three-fourths of chief appraisers and appraisal managers surveyed disagree with raising the $250,000 threshold for real estate financial transactions, and nearly nine out of 10 disagree with raising the $1 million threshold level for certain business loans. 

The nation’s banking regulatory agencies—the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC) and the Federal Reserve—on Dec. 2 completed a year-long series of public meetings as part of a review of federal banking regulations. That review is required every 10 years by the federal Economic Growth and Regulatory Paperwork Reduction Act of 1996.

“As part of its mission to serve the public interest, the Appraisal Institute continues to oppose any changes to the threshold levels,” said Appraisal Institute President M. Lance Coyle, MAI, SRA. “Appraisals serve a vital role in risk mitigation, and lenders and borrowers benefit from the role appraisals play.”

The Appraisal Institute previously has provided its recommendations to the regulatory agencies, including:

►Cautioning against an increase of the appraisal threshold levels to the federal bank regulatory agencies during the official EGRPRA comment period in 2014.
►Educating Congressional oversight committees on the importance of the current appraisal threshold levels during regulatory oversight hearings in 2015.
►Attending all of the Economic Growth and Regulatory Paperwork Reduction Act outreach meetings held in 2015, encouraging bank regulatory agencies to maintain the current threshold levels and putting more resources toward educating examined banks about existing exemptions to appraisal requirements.

The federal agencies are expected to produce a joint report to Congress in 2016 and potentially to undertake regulatory changes thereafter.

The Appraisal Institute conducted a study Nov. 23-30, when 8,000 randomly selected AI professionals were emailed an online survey questionnaire; 941 individuals completed the survey. Based on the total study sample size and the approximate total number of AI professionals (20,000), the margin of error is +/- 3.1 percentage points at the 95 percent confidence level.

About the author
Published
Dec 02, 2015
Jobs Report Comes In Weak After Mortgage Rates Surge

Employers added just 29,000 jobs in September, sending Treasury yields lower and offering a potential counterweight to the recent rise in mortgage rates

Oct 02, 2026
Price Cuts Hit Four-Year High As Mortgage Rates Top 7%

More than one in five listings took a price cut in September, but pending sales still posted their sharpest annual decline since March 2025

Oct 01, 2026
Serious Mortgage Delinquencies Rise 19% After Five Months Of Improvement

ICE data shows 574,000 mortgages were at least 90 days past due in August, while early-stage delinquencies remained below year-ago levels

Sep 29, 2026
Smaller Down Payments Give Buyers More Room, But Rates Limit The Savings

The typical down payment fell 9% from a year ago, while shifting market conditions are giving originators different affordability conversations across the country

Sep 25, 2026
Mortgage Rates Break 7% Just As Builders Find A Way To Move Buyers

New-home sales rose 6.4% in August as builders cut prices, offered incentives, and sold more lower-priced homes. Now mortgage rates are moving against buyers again

Sep 25, 2026
Borrowers Want Digital Closings, But Some Originators Remain Hesitant

ServiceLink finds 45% of surveyed LOs cite borrower reluctance as a barrier, even though most recent buyers say digital options would influence their choice of mortgage provider

Sep 23, 2026