CUNAwrote the Federal Reserve Board on Dec. 22 asking it to raisethe asset threshold for the small institution safe harbor in itsinterim final rule on appraisal independence under RegZ.

CUNA said the threshold should be raised from $250 million to $1billion since "the reasons cited by the Board in the interim finalrule's preamble for differentiating between small and largeinstitutions apply equally to institutions with up to $1 billion inassets."

For example, CUNA said, like those with assets below $250million, many institutions at the $1 billion mark "may decreasetheir consumer lending operations due to an inability to complywith the rules, such as the firewalls requirement, because oflimited staff resources and similar factors."

CUNA did, however, express agreement with the rule's approach todefining "reasonable and customary fees" for appraisers. "Thisapproach provides relevant weighing factors and other guidance forsetting appraiser compensation without micromanaging financialinstitutions' appraiser compensation processes," CUNA said.