Comment on OMB-2026-0034-0001

Summary: The Appraisal Institute, representing professional real estate appraisers, supports the OMB's continued reliance on independent appraisals to determine the fair market value of donated real property for federal grant programs. They argue that independent appraisals provide a more reliable, transparent, and auditable record than property tax assessments, which can be inconsistent or outdated. They also recommend strengthening language to recognize state-certified appraisers and considering enhanced reviews for high-value property contributions.