VaCAP has just been made aware of a Sunshine Act Meeting that will take place on Tuesday August 20th.
We have been told that the FDIC meeting on Tuesday will vote with no discussion to raise the residential de minimis. This is scheduled to happen despite the volumes of opposition and in the wake of a similar act by the FFIEC to grant appraiser waivers in North Dakota.
The Federal Financial Regulators are changing FIRREA through rules an bypassing Congress in doing so. FIRREA was put in place for a reason and is being reduced to rubble by agencies that do not want to deal with its guidance. See the attached memo dated just four months ago clarifying that Federal Agencies can not rewrite laws with rules.
See the FDIC announcement @ https://www.federalregister.gov/d/2019-17955
VaCAP is asking each and every appraiser to contact there Federal Representatives and ask that this ruling by the FDIC be reviewed by Congress.