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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3/24/14  4:12 pm
Commenter: Virginia

Reasonable and Customary
 

Regulations should protect appraisers at all product levels. This includes not only traditional GSE work but also alternative valuation desktop products and IAG evaluations for federally regulated institutions that USPAP also advises us on. Desktop and Evaluation 'clients' (and the third parties to those clients) often take significant advantage of appraisers thinking that only GSE products are covered under the Dodd-Frank Act and the AMC Act, which is not true. A $25 desktop and a $175 URAR are both disgraceful and harmful, not only to our profession but ultimately to the consumer who we are suppose to provide a high level of public trust to. As of 8/2015 the HUD form will be no more, as per the new servicing requirements; the new 'disclosure statement' will list the Appraisal Fee but is not required to list the AMC Fee; yet. When the consumer and the Title Companies are forced to show the AMC Fee on the new disclosure statement all will see how appraisers are taken advantage of on all levels. Let us all stand up and fight to regain our profession through appropriate regulation that protects all those involved.

CommentID: 31470