WBA submitted comments to OCC, FRB, and FDIC supporting an increase in the threshold level at or below which appraisals would not be required for commercial real estate transactions, which has remained at $250,000 since the inception of the threshold. However, WBA strongly advocated for an increase to at least $1M, calling the proposed $400,000 increase inadequate to relieve regulatory burden, especially in small market areas. Click here to read the letter.