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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3/20/14  7:46 am
Commenter: Roger Blaha

Proposed AMC regulations
 

Many thanks to the Board for their consideration and commitment to this important matter. Until recently AMC's were the only participants in the appraisal process void of any regulation.  Successful lobbyist have help create an entity which adds no value to the borrower. AMC's do nothing that  professional appraisers have not or  can not do for themselves. Appraisers are regulated at every turn and there is no logical reason to extend a free pass for AMC's to conduct business as freely as they wish.

In addition to the regulations set forth by the state of Louisiana I ask the board to also consider additional measures. An AMC should be required to provide a copy of their registration with the Commonwealth of Virginia's State Corporation Commission with the engagement letter for every assignment, since it is customary that most appraisers include a copy of their license and E&O insurance with every submitted report. Secondly, require that an AMC provide a current copy of their Dun & Bradstreet comprehensive report and a letter of credit from their bank or financial institution allowing appraisers to attach that account in the event of unpaid invoices. Too many appraisers have been harmed by fraudulent or defunct AMC's. I fully support the regulation of AMC's in the Commonwealth of Virginia and implementation of regulating customary and reasonable fee similar to that of Louisiana.

CommentID: 31450