CUNA wrote the Federal Reserve Board on Dec. 22 asking it to raise the asset threshold for the small institution safe harbor in its interim final rule on appraisal independence under Reg Z.

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

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

CUNA did, however, express agreement with the rule's approach to defining "reasonable and customary fees" for appraisers. "This approach provides relevant weighing factors and other guidance for setting appraiser compensation without micromanaging financial institutions' appraiser compensation processes," CUNA said.