The Appraisal sub-committee has just published final rules regarding AMC regulation that are now open for public comment.  The proposed rules clarify an individual states’ RIGHT (and in my view, RESPONSIBILITY) to enact regulation that exceed the minimum requirements of Dodd-Frank.  In addition, the proposed rules clarify that states may also enact their own laws/rules to reasonably enforce the C & R fee requirements spelled out in the Truth in Lending Act Sec 129 (e). I would like the Virginia’s AMC regulations to quote VERBATIMLY the following from LA AMC regulations and Dodd- Frank; an appraisal management company shall compensate appraisers at a rate that is customary and reasonable for appraisals being performed in the market area of the property being appraised, consistent with the presumptions of compliance under federal law. Evidence for such fees may be established by objective third-party information, such as government agency fee
schedules, academic studies, and independent private sector surveys. Fee studies shall EXCLUDE assignments ordered by known appraisal management companies” An appraisal management company shall not include any fees for appraisal management services performed by the company in the amount the company reports as charges for the actual completion of an appraisal by the appraiser. Considering what we’ve gone through since HVCC, it would be ideal for the board to specifically reference acceptableor relevant fee surveys that AMC’s can reference so they can be sure they are in compliance. This will ultimately protect the interest of the Virginia consumers and the appraisal industry.