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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3/25/14  3:41 pm
Commenter: Rusty Gwaltney - Sinnen-Green and Associates

AMC Regulations, Reasonable & Customary Fees
 

I fully agree with the regulation of AMCsFrank was implemented, the cost to the consumer tended to increase while the collected fee to the Appraiser tended to do the opposite. The AMCs taking their piece of the pie resulted in an even lower fee for the men and women doing the actual work. There is now a used car buyer mentality among the AMCs when shopping for an Appraiser. We look to USPAP every day and abide by it. ~ 2 inches thick and an Appraiser's Bible of sorts, guiding us in ethics and performance of our profession so as to create a credible product for the client. Add to this a 5-12 page engagement letter full of hoops to jump through, automated emails waking you at 2am, and a hoop jumping "scorecard" for your file with the AMC, and the end result is more work and less pay for the Appraiser and a higher "APPRAISAL FEE" for the consumer. We should not be paying 35% of the "APPRAISAL FEE" to a third party regulator that isn't regulated themselves. More quality Appraisers are leaving the profession, and fewer are coming in. I personally would not come fresh out of four years of college tomorrow and look at a profession that requires the additional hours it takes to become certified as an Appraiser for the pay currently offered in my state. It is my love for what I do that has kept me hoping the profession would eventually see a turn around with the AMCs understanding the long term need for quality work and fair pay to the people that provide that quality work to them. Please consider the impact on Real Estate and the economy of Virginia if we do not have quality Appraisers providing this very important element of the mortgage process in the coming years. Thank You. Rusty Gwaltney

CommentID: 31501