Virginia Regulatory Town Hall
Agency
Department of Professional and Occupational Regulation
 
Board
Real Estate Appraiser Board
 
chapter
Appraisal Management Company Regulations [18 VAC 130 ‑ 30]
Action Initial Appraisal Management Company Regulations
Stage Proposed
Comment Period Ended on 3/28/2014
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3/13/14  3:55 pm
Commenter: Stephen R. Blue

AMC Regulation
 

As a state Certified Residential Appraiser, I fully support the regulation of Appraisal Management Companies in the Commonwealth of Virginia. I would like to see the implementation of reasonable regulation regarding "customary and reasonable fees" for AMC's. In addition, consideration must be given to Lenders and Management Companies charging appraisers "back door" fees for the privilege of receiving assignments under the name of portal maintenance, technology and review fees that are deducted from the fee agreed upon in the letter of engagement. The charging of fees circumvents the disclosure of the true amount paid to the appraiser for services rendered and defrauds the reader of the report in which fee disclosure is made.

CommentID: 31293