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 InstituteThe 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
June Jobs Report Improves Mortgage Rate Outlook

Slower hiring strengthens bonds and eases concerns over additional Fed tightening

Jul 02, 2026
NEXA Founder Mike Kortas Launches evoLend To Help Originators Retain Borrowers

New Fannie Mae-, Freddie Mac- and Ginnie Mae-approved mortgage servicer aims to keep originators connected to borrowers through servicing data, payoff visibility and retention tools

Jul 02, 2026
President Trump Cancels 21st Century ROAD To Housing Act

Trump cancels signing the bipartisan housing bill, leaving affordability package in limbo

Jun 24, 2026
Commercial, Multifamily Mortgage Debt Tops $5 Trillion In Q1

MBA says outstanding debt grew by $26.3 billion in the first quarter, led by multifamily lending and increased holdings from banks, agencies, and life insurers

Jun 18, 2026
Fed Holds Rates Steady, But Outlook Dims For Mortgage Rate Relief

The Federal Reserve left rates unchanged but updated projections show more policymakers expecting additional hikes

Jun 18, 2026
Congress Nears Final Vote On 21st Century ROAD to Housing Act

Senate voted 87-8 to advance House-amended package, with final votes expected in coming days

Jun 17, 2026