In a February 5 comment letter to the Office of the Comptroller of the Currency, Federal Reserve Board of Governors, and Federal Deposit Insurance Corporation, BPI argued that the appraisal requirement threshold for residential real estate-related transactions under Title XI of the Financial Institutions Reform, Recovery and Enforcement Act of 1989 (FIRREA) should be raised from its current level of $250,000 to $500,000, rather than the agencies’ proposed increase to $400,000. A $500,000 threshold, the letter contends, is supported by the data cited in the agencies’ proposal and would appropriately reflect appreciation in housing prices since the current $250,000 threshold was established in 1994. The letter also encourages periodic review and, if appropriate, adjustment of the threshold to account for future such property value changes.
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