ASA Takes Issue with Bank Agency Refusal to Hold Public Hearing on Regulation Affecting Homebuyers

RESTON, Va., Feb. 22, 2019  /PRNewswire/ -- The American Society of Appraisers (ASA) is deeply disappointed to learn that the Federal Reserve, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, "the Agencies") have rejected a reasonable request by numerous groups – including ASA – to hold a public hearing regarding the Agencies' proposed increase in the residential appraisal threshold from its current level of $250,000 to $400,000, thereby exempting over seven in 10 Federally Related Transactions from Title XI appraisal requirements.

This decision is made worse when compared to the last time the Agencies considered the same question less than two years ago, as part of the Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA) process. After four rounds of written public comment and six rounds of public hearings, the Agencies reached the following conclusion: "Based on considerations of safety and soundness and consumer protection, the agencies do not currently believe that a change to the current $250,000 threshold for residential mortgage loans would be appropriate."¹

When asked about the Agencies' decision, ASA International President Robert Morrison said, "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."

To read the Agencies' letter rejecting the hearing request, click here. To read ASA's comment letter regarding the proposal, click here. To read the prior letter requesting a hearing, click here.

American Society of Appraisers
The American Society of Appraisers is a world renowned and respected international organization devoted to the appraisal profession. As the oldest and only major appraisal organization representing all appraisal specialists, ASA is devoted to providing the highest possible standards in all areas of ethics, professionalism, education and designation criteria. For more information about the American Society of Appraisers, the ASA designation program for appraisers or the Society's free "Find an Appraiser" Referral System, visit www.appraisers.org or call (800) 272-8258.

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Media Contact:
Todd Paradis
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703-733-2124

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1} See p. 44, Joint Report to Congress, Economic Growth and Regulatory Paperwork Reduction Act, published March 2017.

SOURCE American Society of Appraisers

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