What the EGRPRA hearings said about appraisal and valuation

The OCC, the Federal Reserve and the FDIC are reviewing their regulations under the Economic Growth and Regulatory Paperwork Reduction Act of 1996 (EGRPRA), which requires the review at least once every 10 years. As part of it, the agencies held public outreach meetings where bankers, trade groups and community organizations could comment on rules they consider outdated or burdensome. This article summarizes what those meetings said about appraisal and valuation, and where the larger appraisal record sits instead.

We read the transcripts of the first meeting (September 2024, virtual), the second (March 6, 2025, virtual) and the fourth (March 26, 2026, at the Federal Reserve Board in Washington). The third meeting, held October 30, 2025 at the Federal Reserve Bank of Kansas City, is not covered because we did not have its transcript. The agencies’ closing remarks in March 2026 described the fourth meeting as the final one in the series. The agencies publish transcripts and recordings on the FFIEC’s EGRPRA outreach page.

1. Sept 25, 2024VirtualNo appraisal comments found
2. Mar 6, 2025VirtualNo appraisal comments found
3. Oct 30, 2025Kansas CityTranscript not reviewed
4. Mar 26, 2026WashingtonAppraisal and valuation comments from three speakers

The first two meetings

We found no appraisal discussion in either transcript. Both meetings were organized around six categories: consumer protection, applications and reporting, powers and activities, international operations, directors, officers and employees, and money laundering. Appraisal rules were not among them.

The March 2026 meeting

Panels covered consumer regulations, capital, supervision and innovation, followed by an open comment session. Most open-comment speakers addressed the Community Reinvestment Act. Three speakers touched valuation.

Keith Thornberg, general counsel of the Missouri Bankers Association. He was the only banker to address appraisal rules directly. He said a recent executive order instructs the banking agencies to review appraisal regulations, including reducing unnecessary appraisal requirements for low-risk transactions. He asked the agencies to raise the thresholds at which a licensed or certified appraisal is required. He said the cost of outside appraisals “has increased dramatically” and is passed through to consumers and small businesses, and that for many community-bank loans the bank can evaluate value at lower cost or with alternative valuation models.

AI-generated illustration.

Thaddius Dawson, an appraiser of 40 years and head of 10KBA and the 10,000 Appraisers Foundation. He was the only appraiser in the session we read. His requests:

• Codify reconsideration of value, which he called the top consumer protection and said the VA has handled since 2003.
• Support the executive order’s appraisal modernization, including a national license, which he said the Appraisal Foundation lobbies against.
• Abolish the Appraisal Foundation, which he described as lacking disciplinary authority and accountability.
• Adopt a “land grant reconstruction appraisal program,” described in a white paper he said he submitted to the record.

He also said an FHFA paper he identified as “2407” shows only 10% of appraisals use market conditions adjustments. We did not locate that paper and have not verified the figure. Our article on reconsideration of value covers the uniform ROV standard.

Jamie Woodwell, Mortgage Bankers Association. His comments concerned collateral risk on income-producing commercial property. He said banks hold 38% of the roughly $5 trillion of commercial mortgage debt outstanding. He asked the agencies to revisit the guidance that gives extra attention to banks with commercial real estate at 300% of total risk-based capital, saying the attention “can morph into de facto barriers.” He also asked that modified, performing loans not draw added scrutiny and that loans be evaluated on current standing rather than an outdated plan. He also said MBA was reviewing the new capital proposals’ risk weights for commercial mortgage loans, including multifamily, and thanked the agencies for removing the cross-default provision that was in the 2023 proposal.

The executive order behind the comments

The order Thornberg and Dawson referred to is Executive Order 14393, “Promoting Access to Mortgage Credit,” signed March 13, 2026. Section 6(a) tells the Federal Reserve, CFPB, NCUA, FDIC, OCC and FHFA to consider modernizing appraisal regulations to expand alternative valuation models, desktop and hybrid appraisals and AI valuation tools, simplifying appraiser qualification requirements, and reducing appraisal requirements for low-risk transactions. Our article on the letters behind appraisal modernization traces who asked for what afterward, including the August 3, 2026 joint letter from the ABA, Housing Policy Council and ICBA asking the bank regulators to raise the residential threshold from $400,000 to $625,000 and index it annually.

1994Original threshold

$250,000

2019After the last review

$400,000

Aug 2026Proposed by ABA, HPC and ICBA

$625,000

The written record

AI-generated illustration.

The fullest appraisal argument in the EGRPRA record is a March 7, 2025 comment letter from the Appraisal Institute, the American Society of Appraisers, the American Society of Farm Managers and Rural Appraisers, and MBREA. It makes four points:

1. No threshold increase. The organizations see no justification for raising the $400,000 residential threshold, which was raised from $250,000 after the previous review.
2. Evaluations. Below the threshold, lenders can use evaluations, and the letter says AVMs, broker price opinions and competitive market analyses do much of that work, sometimes done by staff with a stake in the transaction. The letter says evaluations carry no licensing or disciplinary process. It asks the agencies to reassess the allowance or, failing that, exempt appraisers from USPAP when they perform an evaluation. The agencies’ 2010 interagency appraisal and evaluation guidelines do set expectations for evaluations, so the dispute concerns who may perform them and who answers for the result.
3. The GSE exemption. The letter states that nearly 90% of residential transactions at regulated institutions are exempt from FIRREA appraisal requirements, that Fannie Mae’s Value Acceptance and Freddie Mac’s ACE programs waive the appraisal on about 15.5% of loans sold to the GSEs, and that waivers reached around 60% during the pandemic. It asks the bank regulators to reexamine the GSE exemption after the end of Chevron deference. We have not verified these figures.
4. Appraiser selection. Lenders should choose appraisers on competency and professional designations rather than fee and turnaround time.

Takeaways

• The spoken record on appraisal is thin. In the three meetings we read, two comments addressed appraisal rules directly. One raised cost and thresholds, and the other raised standards, reconsideration of value and licensing.
• The bank-side ask is a higher, indexed threshold. The appraiser-side ask is no increase and tighter limits on evaluations. Both are now on file with the same three agencies.
• A threshold change requires a rulemaking by the bank regulators. EGRPRA itself ends with a report to Congress, and the agencies said in March 2026 that comments will be considered. They did not give a date for any proposal.
• Collateral-risk comments from commercial lenders, such as the concentration guidance and the treatment of modified loans, bear on how banks use valuation for existing loans.