Commercial Appraisers Livelihood Threatened

Commercial Appraisers Livelihood Threatened by NCUACommercial appraisers may want to open this link, and read it. Your livelihood is possibly threatened by the National Credit Union Administration (NCUA).

You may want to send a letter to the NCUA Board of Directors.

Proposed Appraisal Rule Provides Relief, Clarity
As part of the NCUA’s regulatory relief agenda, the Board approved a proposed rule (Part 722) to amend the agency’s real estate appraisal requirements for certain transactions.

The proposed rule would provide a measure of regulatory relief and increased clarity by:

  • Increasing the threshold for required appraisals in non-residential real estate transactions from the current $250,000 to $1 million;
  • Reorganizing the appraisal regulation to make it easier to determine when a written estimate or an appraisal is required; and
  • Incorporating the rural exemption contained in the Economic Growth, Regulatory Relief, and Consumer Protection Act, S. 2155.

Comments on the proposed rule must be received within 60 days of publication in the Federal Register

Comments on the NCUA’s proposed rules should be mailed or hand-delivered to:

Gerard Poliquin, Secretary of the Board,
National Credit Union Administration,
1775 Duke Street,
Alexandria, Virginia 22314-3428
Comments can also be sent by fax to 703.518.6319 and by email at

Please send comments by one method only.

Excerpt from the article “NCUA’s appraisal plan ignores lessons of last crisis” by Stephen S Wagner

The National Credit Union Administration’s board of directors is about to take radical action that could significantly damage the nation’s commercial real estate market — and many bankers aren’t aware of it.

The NCUA board may take up this topic as early as its next monthly meeting, scheduled for May 23. Regulators will consider quadrupling — from $250,000 to $1 million — the appraisal threshold for nonresidential real estate loans…

Raising the threshold to such a high level will result in a dramatic loss in appraisal independence and risk mitigation…


Dave Towne
Image credit flickr - andeecollard
Dave Towne

Dave Towne

AGA, MNAA, Accredited Green Appraiser - Licensed in WA State since 2003. Dave Towne on

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6 Responses

  1. Ross Grannan on Facebook Ross Grannan on Facebook says:

    Great, round 3 of the Real Estate bait and switch

  2. Avatar Gadda Gow says:

    Welcome to the world of residential appraisers

  3. Avatar Carl says:

    Commercial appraisers are now in the same boat as residential appraisers!

  4. Avatar Ex appraiser says:

    I have been appraising commercial and residential property for 40 years. I warned other commercial appraisers to pay attention to what was happening to residential appraisers but most of them don’t think this will happen. Well, they are engineering the next bailout. There appears to be nothing we can do, but I will make comments to the NCUA.

  5. Baggins Baggins says:

    Well, there appears to be no end in sight to how many fiat dollars they’ll roll off those printing presses, and most of the ‘new money’ never even sees the light of paper stock, being nothing more than bits and bytes in digital form. It’s all relative. Erosion of additional fundamental checks and balances systems further down the supply chain has always been the inevitable conclusion to a fiat currency. Missing the gold window yet?


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Commercial Appraisers Livelihood Threatened

by Dave Towne time to read: 1 min