The Office of the Comptroller of the Currency (OCC), The Federal Reserve Board, and the Federal Deposit Insurance Corporation (FDIC) recently invited comment on a proposed rule change governing when appraisals are required for certain residential real estate transactions. The proposed rule would increase the threshold level for when appraisals are required from $250,000 to $400,000, meaning transactions at or below $400,000 would not be required to conduct an appraisal.
CHAPA submitted comments ahead of yesterday’s deadline and argued that increasing the threshold would negatively impact low and moderate income homebuyers. Appraisals play a critical role in ensuring fair transactions. Even a slight difference between the appraised value and the sales price could put a buyer’s financial ability to pay their mortgage in jeopardy.
CHAPA’s interest in this proposed rule change stems in part from the Massachusetts Homeownership Collaborative. CHAPA supports the Collaborative with technical assistance and training for over 20,000 low and moderate income homebuyers throughout the year. Read CHAPA's full comment letter here.