Federal Agencies Approve Rule Raising the Appraisal Threshold for CRE

On March 20, 2018 the Federal Deposit Insurance Corporation (FDIC) approved a final rule that will double the required appraisal threshold for commercial real estate transactions. The Office of the Comptroller of the Currency and the Board of Governors of the Federal Reserve System are expected to adopt the rule soon. The federal banking agencies maintained the $250,000 threshold level for 1-4 unit single-family residential loans and also maintained the $1 million threshold level for business (owner occupied) commercial real estate loans.

“The agencies should be applauded for their restraint and focus on safety and soundness in residential and business lending,” said Appraisal Institute President James L. Murrett, MAI, SRA.

The agencies’ final rule stated, “The OCC, Board and FDIC (collectively, the agencies) are adopting a final rule to amend the agencies’ regulations requiring appraisals of real estate for certain transactions. The final rule increases the threshold level at or below which appraisals are not required for commercial real estate transactions from $250,000 to $500,000. The final rule defines commercial real estate transaction as a real estate-related financial transaction that is not secured by a single 1- to 4-[unit] family residential property.”

For commercial real estate transactions exempted from the appraisal requirement as a result of the revised threshold, regulated institutions must obtain an evaluation of the real property collateral that is consistent with safe and sound banking practices.

Murrett acknowledged that the agencies’ decision to increase the commercial real estate threshold levels was not unexpected. However, he said, “It is confounding given pricing and risk management concerns expressed about the commercial real estate market by leaders of the agencies themselves. Without a doubt, the final rule increases risk to the commercial real estate lending system.”

He also noted that as more evaluations are allowed, one likely result is a return to the loan production-driven environment seen during the leadup to the financial crisis, where appraisal and risk management were thrust aside to make more – not necessarily better – loans. Smaller institutions, in particular, which are less likely to maintain in-house appraisal departments, are more likely to be susceptible to breakdowns in appraisal independence with fewer controls in place.

“Seen through the lens of loosening regulations, the final rule may make sense,” Murrett said. “But from a safety and soundness perspective, the final rule raises significant concerns.”

Adapted from an article published by the Appraisal Institute


mm Written by: Sandra & Bill Willard H. Langhenry, MAI and Sandra Poe, MAI, AI-GRS own and manage National Appraisal Review & Compliance Group based in Dallas, Texas. In addition to providing commercial appraisal report review services to financial institutions, National Appraisal Review & Compliance Group has the expertise to handle the appraisal bid and engagement process, oversee appraisal compliance and appraisal regulatory issues and assist in the bank audit/loan review process. Additional services include appraisal review audits and forensic appraisal analyses, as well as development and coordination of approved appraiser panels for lending institutions.

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