ASA says the agencies’ plans to increase the residential appraisal threshold go “beyond the intent of legislation”
The Federal Reserve, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency rejected the American Society of Appraisers’ (ASA) request to hold a public hearing regarding the agencies’ proposed increase in the residential appraisal threshold.
ASA, along with other groups, requested a public hearing about the proposed $150,000 increase of the residential appraisal threshold. From its current level of $250,000, the threshold will go up to $400,000 – exempting over seven in 10 federally related transactions from Title XI appraisal requirements.
The regulators have already solicited public comment on the proposal, and they maintained that process was sufficient for gauging reaction.
“After reviewing your letter and considering the discussion in our conference call, we do not believe that holding a public hearing would elicit relevant information that could not 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. As mentioned on the conference call, agency staff is available to meet with representatives of your organizations,” the agencies wrote.
The ASA wrote back saying that they “strongly opposed” the proposed increase and doubt whether “the Agencies’ planned implementation of congressionally authorized discrete relief in certain rural markets goes beyond the intent of the legislation.”
"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,” said ASA International President Robert Morrison. “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."
