If I am making a second mortgage loan (1st and 2nd loans > 250M)in an amount less than $250,000, do we have to comply with appraisal requirements under FIRREA

Yes, you would have to combine the liens to determine whether you were over the $250,000 trigger. Otherwise banks could structure multiple loans under $250,000 secured by a single property and duck under the requirement.

I tend to disagree. FIRREA exception rules talk about transaction value of less than $250,000 are exceptions to appraisal requirements. Your loan is less than the required amount