Regulators are laying the base for what they believe to be a legal battle over the raising of the real estate appraisal threshold. The regulating agencies have requested comments on supplemental information added to the proposed that includes a deluge of surveys. studies and comments that favor the hike.

The decision to raise the limits to $250,000 from $100,000 appears to be a lock. But requesting comments on the supplemental information is an important formality for regulators' who are being careful to ensure they are standing on firm legal ground before approving the final rule. The information in the supplemental data constitute "the reasoning we used to justify raising the threshold," said Richard Spillenkothen, director of banking supervision and regulation for the Federal Reserve Board. Comments are due by Dec. 10.

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