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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Next Comment     Back to List of Comments
2/13/14  4:00 pm
Commenter: Candice Krasovec, Appraiser

Approve AMC regulations
 

As an appraiser I feel that it is very necessary to regulate the AMCs.  They are in control of our fees and do not pay us fairly nor do they pay us in a fair amount of time.  I appreciate the begining works of requiring AMCs to regulate and registar. I would appreciate there is very clear writting that states that they must pay us within 2 weeks or max 30 days.  They often times hold onto our fees and collect intrest for up to 90 days.  I have some AMCs that just shut down and start a new one under a new name and still owe us thousands of dollars.  Also I have some that havent paid in 6 months.  I would approve of the proposed regulations however ask that you take a state poll asking the appraisers candidly what their NON-AMC fee is.  I say non-AMC fee because amcs threaten no work or take the least amount in splits of our own fee.  Alot of appraisers need the option to all collectively set an average or bar of reasonable customary fees.  Please defend our small industry from appraisers being forced out of the  business because we cant simply take on the liability of doing appraisals for next to nothing after all our fees for E/O insurance, belonging to realtor boards and etc.  Keep us professional.  I think this is the first step to a few necessary ones.  I highly encourage our state to get this in the right direction as soon as possible, to protect the economy, our consumers and our working appraiser professionals here in the state of Virginia.  Thank you. 

CommentID: 31019