Banks are currently facing unique challenges in light of appraiser shortages in many regions of the country, but more specifically in small urban and rural areas for real estate transactions. Our members report there is a limited number of qualified appraisers willing to accept assignments in many of their markets – even when the bank is willing to pay a premium for the assignment. This shortage negatively impacts borrowers as it extends turnaround times, extends rate locks and delays closings. In certain cases, members report that they are unable to finance loans and compete in more rural markets.

ABA's Position

ABA believes that there are multiple issues affecting appraisal availability. Urgent measures are needed now to allow banks to process existing financing needs, while long-term changes will be required to address more fundamental problems. We encourage workable solutions that ensure the continued safety and soundness of the banking industry, including:

  • Raising the threshold level for commercial real estate transactions from $250,000 to $400,000, in order to relieve appraiser shortage pressures in rural and other areas.
  • Reviewing the appraisal threshold for residential real estate transactions.
  • Easing qualification criteria for real property appraisers, as adopted by the Appraisal Qualification Board in early 2018. Changes include removal of the required bachelor’s degree for Licensed Residential appraisers, and decreasing timeframes for experience hour requirements.

The ABA Appraisal Working Group discusses appraisal issues and the impact on lending at the bank level. To join the Appraisal Working Group, please contact Sharon Whitaker.




 Comment Letters


 ABA Analysis


Rules & Guidance

Agency Resources


 ABA Staff Contacts

  • Sharon Whitaker,
    VP, Commercial Real Estate & Finance, Mortgage Markets, Financial Management & Public Policy

 ABA Resources