Exactly my point. Anything under $1 million generally does not require an appraisal.
I doubt Trump did not deal in commercial properties under $1 million, so unless the New York Attorney General decides to go after pre-1989 transactions with banks domiciled in her state. Trump had a substantial relationship with Deutsche Bank, which is headquartered in Germany. If Deutsche Bank had an affiliate with a charter issued in New York, loans made by the American affiliate would be subject to U.S. bank regulation. However, this relationship was established well after the adoption of FIRREA.