Federal Agencies Changing FIRREA
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VaCAP has just been made aware of a Sunshine Act Meeting that will take place on Tuesday August 20, 2019. 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 appraisal waivers in North Dakota.
The Federal Financial Regulators are changing FIRREA through rules and 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 here.
Pursuant to the provisions of the “Government in the Sunshine Act” (5 U.S.C. 552b), notice is hereby given that the Federal Deposit Insurance Corporation’s Board of Directors will meet in open session at 10:00 a.m. on Tuesday, August 20, 2019, to consider the following matters:
No substantive discussion of the following items is anticipated. These matters will be resolved with a single vote unless a member of the Board of Directors requests that an item be moved to the discussion agenda…
Memorandum and resolution re: Final Rule to Increase the Appraisal Threshold for Residential Real Estate Transactions, Implement the Rural Residential Appraisal Exemption, and Require Appropriate Appraisal Review…
The meeting will be held in the Board Room located on the sixth floor of the FDIC Building located at 550 17th Street NW, Washington, DC.
This Board meeting will be Webcast live via the internet and subsequently made available on-demand approximately one week after the event. Visit http://fdic.windrosemedia.com to view the event. If you need any technical assistance, please visit our Video Help page at: https://www.fdic.gov/video.html.
VaCAP is asking each and every appraiser to contact there Federal Representatives and ask that this ruling by the FDIC be reviewed by Congress.