I hope these guys get 20,000 signatures- And if I had an-appraisal blogging site or newsletter I would be doing the same thing. I would create a crisis and recruit and capture all those names, E-mails and phone numbers and interrogate them into my data base. My Newsletters and Blogging Sites would expand rapidly, and even though I may not be able to get any direct monetary support from my new caravan of petitioners I would certainly expand my on-line advertisers and sponsors. Nothing wrong with this in fact I have a whole new respect for these "Appraisal-Warriors" because the day after the deminimus is passed and signed the Warriors will simply get their Caravan on another bus and on to a new battle. Appraisers love nothing more than being victims and like my Slovakian friend says when you haven't won a war in over 400 years you start celebrating your losses and the community treats you-like celebrated martyrs. .
The main appraisal organizations want the deminimus kept at $250,000 because it benefits their Made to Order members, because Certified Residential are prohibited from doing any non-complex and non-residential which exceed the $250,000 threshold. Many Certified Residential Appraisers have the skill and ability to complete small commercial, industrial and income but the $250,000 limits have been restrictive.
In the market I work it's rare to find any small commercial or non-residential properties worth less than $500,000 -except in the high deserts or badlands BUT If I lived in a lower cost State I could expand my business model rapidly because there is a ton of work out there. The AI and other organizations offer courses teaching small commercial and non-lending. The CR that already has commercial experience should start brushing up because this is a door opener for many. BUT if your Certified residential don't be fooled because many of the organizations will continue to tell their residential members that commercial can only be done with either their Designation or a CG license, and most of the form-filling loan production appraisers will never take advantage of this new opportunity.
Summary:
The FDIC, the Board of Governors of the Federal Reserve System, and the Office of the Comptroller of the Currency (the Agencies) are jointly issuing a notice of proposed rule-making titled Real Estate Appraisals (Appraisal NPR) that will be published in the Federal Register for a 60-day comment period. The Appraisal NPR proposes to increase the current appraisal threshold for commercial real estate (CRE) transactions from $250,000 to $400,000. The Appraisal NPR addresses comments received during the Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA) review process, which requires that, not less than once every ten years, the Agencies, along with the Federal Financial Institutions Examination Council, conduct a review of the Agencies' regulations to identify outdated or otherwise unnecessary or burdensome regulatory requirements.
The Appraisal NPR creates a new definition of, and separate category for, commercial real estate transactions and proposes to raise the threshold for requiring an appraisal from $250,000 to $400,000 for those transactions.