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Commercial De Minimus $400,000

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Terrel L. Shields

Elite Member
Gold Supporting Member
May 2, 2002
Professional Status
Certified General Appraiser

the OCC, Board, and FDIC (collectively, the agencies) are inviting comment on a proposed rule to amend the agencies' regulations requiring appraisals of real estate for certain transactions. The proposal would increase the threshold level at or below which appraisals would not be required for commercial real estate transactions from $250,000 to $400,000.​

Mike Kennedy

Elite Member
Sep 28, 2003
Professional Status
Certified Residential Appraiser
New York
1994 Residential/
"Required for all real estate-related financial transactions except those in which: (1) The transaction value is $250,000 or less.(7)

"Over the past year, federal banking agencies(1) completed a series of changes to regulations of concern to real estate professionals. Appraisers focused on allowed exceptions, particularly the "threshold level." Few appraisers understood that the new regulations would include more than this single exception. In fact, there are now twelve exceptions to the requirement to employ state certified or licensed appraisers.

Threshold" is the issue that attracted the attention of appraisers. The first set of Financial Institutions Reform, Recovery and Enforcement Act of 1989 (FIRREA)(8) regulations included a $50,000 threshold. That level was later raised to $100,000, and in June 1994 it was increased to the current level, $250,000. Transactions at or below this amount are not required to be supported by appraisals completed by state certified or licensed appraisers."

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