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.
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.
This need to go back to when appraiser’s could collect their own fees. Appraisers are adult business people and should be given the opportunity to run their respective businesses as they wish. Why do our fee need to be collected from a third part(ies) that have proven over and over again their inability to act in a professional and ethical manner.
Not only that let’s just have borrowers get their own appraisal performed and take it to the lenders of their choice. Consumers can fix this problem so much better than regulators
C’mon fellow appraisers! This is easy and now is the time to speak up! Look at the list of like-minded advocates we have on this critical issue, and join in by demanding action. It takes only 5-10 minutes to contact the White House and appropriate representatives.
When do we sue them for constitutional violations?
This is not good news. I see a giant bubble forming. The next bubble burst will be “heard round the world”
How about letting borrowers get their own appraisal and take it to the lenders of their choice to get a loan. Let consumers fix this mess. That’s a quick and easy fix then all this other stuff regulators are trying to do to fix their own mess will be fixed over night
The request for a public hearing on the issue was ‘worth a shot’ but was never a realistic expectation. Federal rulemaking agencies already have policies and procedures in place for mandatory public input. It’s unrealistic to expect them to make special exceptions. Especially when existing lobbyists that promoted the short-sighted policy changes in questions so strongly oppose having their issues exposed to the light of day.
Far more important is the letter authored by John Russell of ASA which was signed by all the appraiser peer groups and state coalitions (including AI, AGA and at least 30 state coalitions). That eleven-page letter was sent to the appropriate federal agencies in a proper format specifically addressing each of the issues for which comments were requested. John did a brilliant job composing that letter. Anyone that helped him research the issues is also to be commended.
The American Guild of Appraisers was also pleased to see that the AFL-CIO representing financial interests of over Twelve and a Half Million Union Members and their extended families as taxpayers and consumers also wrote an outstanding letter opposing the proposed increase in the deminimis limit.
The AFL-CIO was also joined by the Americans For Financial Reform Lobby which represents many famous national civil rights and diverse social and consumer interests groups representing millions more citizens and taxpayers. (Look them up…I’ll be posting a copy of their letter shortly in AppraisersBlogs).
While we all like to believe it was ‘our’ voice that tips the scales (as collectively it truly is), I’ll be very amazed if regulators and bureaucrats are able to ignore the views of so many union members and American Citizen/taxpayer interests. The numbers involved in just these two groups are enough to sway national elections.
I’ll be watching this one closely.
Youre doing it wrong-you are applying logic dangit.
Bummer.
(small crying noise)