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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3/28/14  10:29 am
Commenter: James Loizou,Suburban Appraisers

AMC regulation
 

I strongly support AMC regulation in Virginia.  The AMCs have been thrust into the market as a middle-man, increasing the cost to the consumer and offering no added value to the consumer or to the industry. AMCs are notorious for hiring appraisers for the lowest fee and quickest turn-around, not necessarily for their expertise or knowledge.  Furthermore, I fear that unregulated AMCs will have a long-term negative impact upon the appraisal industry due to barriers to entry for the profession.  There are very few entering into the profession, and many appraises are retiring due to the increased workload and lack of adequate compensation.  As an appraiser for over 20 years with an Economics degree from Duke and MBA from Vanderbilt, the current fee structure of most AMCs is no longer commensurate with the work and liability demanded.  There is a mandated minimum level of compitency required to be an appraiser, and I believe a minimum fee schedule should be established commensurate with those professional requirements. I appreciate the opportunity to comment on this pending regulatory action.

CommentID: 31521