Feds Deny Public Hearing
The Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency have denied the request for a public hearing on raising the appraisal minimum threshold for residential real estate transactions from $250,000 to $400,000. See the “agencies” rejection letter here.
…we do not believe that holding a public hearing would elicit relevant information that could be conveyed through the comment process described above. While the agencies are, therefore, declining your request for a public hearing, we will carefully consider your written comments…
The American Society of Appraisers, The Appraisal Institute, The American Society of Farm Manager and Rural Appraisers, MBREA, The American Guild of Appraisers, RICS, and the National Association of Realtors, all requested a public hearing on the proposal. All of these organizations have raised concerns about the safety and soundness of the real estate market and consumer protection. These organizations are a strong representation of industry stake holders that have been ignored!
To see the joint comment letter from these organizations, click here.
The comment letter from the National Association of Realtors can be found here.
The ASA issued a press release describing the “agencies” actions in detail. From the press release:
The denial of a public hearing is not only inherently undemocratic, but makes it appear that the Agencies’ mind was set on the increase even before their solicited written comments. Despite myriad good reasons NOT to increase the threshold, the Agencies will instead enact a regulation that harms homebuyers and runs directly counter to Congressional intent. This, to me, is the definition of an agency acting in an arbitrary and capricious manner.
The Federal Agencies and our Representatives work the taxpayers. Contact the White House and your Federal Representatives. Demand action to be taken.
- AMC Engagement Letter: Appraisers Do Not Include Your Invoice - July 28, 2023
- We the People… - April 9, 2023
- Federal Valuation Agency Impact on Appraisers & the Public - July 22, 2022