Appraiser Shortage Myth Used to Raise De Minimis Value
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I know everyone is busy right now, but this cannot wait. This may be the most important blog post affecting appraisers this year. I don’t think it is an exaggeration to say that if something is not done, it really COULD lead to the end of ALL residential appraisers for federally regulated transactions under $500,001.
FFIEC under the Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA), is considering raising the de minimis lending level from $250,000 to $500,000, because the local community banks are complaining that they cannot find enough appraisers in rural America to handle the volume! If you do not write one letter this year, THIS is one you should write.
We all know this has been a topic for discussion for over a year, but it’s coming to head NOW.
If the de minimis value is raised from the current $250,000, it may cause serious disruption to appraisers and the appraisal profession.
We ALL have only 6 days to read, investigate and respond, from a CONSUMER benefit perspective to the following. This was sent to me by someone in one of our federal oversight agencies:
“…However, I thought it was important and did pass your email along to the banking agencies. Evaluations are a hot topic right now as the banking agencies consider raising the $250,000 appraisal threshold. I too have significant concerns about evaluations such as this Pace Pro product and evaluations in general. The agencies are accepting comments on this topic as part of the Economic Growth Reduction Paperwork Reduction Act (EGRPRA) process that takes place every 10 years. Comments can be submitted through the FFIEC website at http://egrpra.ffiec.gov. In fact, the agencies are considering comments on any aspect of federal banking regulations as they apply to appraisals. A list of those regs can also be found on the FFIEC website. I encourage you and others to submit comments prior to the March 22 deadline. Customary and reasonable fees is another important topic on which you can comment. If you have any questions please do not hesitate to ask.”
I added the bold face type for emphasis. What they are NOT kidding about is RAISING THE DE MINIMIS level, through the actions of a committee, to reduce the paperwork burden!
Again, we only have DAYS to comment, not weeks. We need to write to them and point out the benefit/risk to CONSUMERS & taxpayers. They couldn’t care less about individual appraisers. THAT interest is appraiser competency versus the inability of Big Data or alternative products, such as evaluations or BPOS, to be a reliable alternative or substitute.
There is no shortage of appraisers as we have all noted. There is a shortage of appraisers willing to work for $25 a pop, for a BPO product review!
Please submit your comment here and share this post with your colleagues.