Southwest Financial Services, Ltd., an Appraisal Management Company, urges the Real Estate Appraiser Board to reconsider the fee schedule for registration of AMCs as set forth in 18 VAC 130-30-60. This regulation would require each AMC to submit a National Registry Fee of $50.00 per appraiser working for or contracting with an AMC. The regulation states that this $50 fee per appraiser is required pursuant to Section 1109 of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (12 USC §§ 3331-3351). Such Section 1109 mandates that states collect fees for submission to the Appraisal Subcommittee to maintain a registry of individuals who are qualified and eligible to perform appraisals in connection with federally related transactions.

 As part of the licensing regulations for appraisers, appraisers themselves are already required to submit fees for submission to the Appraisal Subcommittee for the same purpose of being listed on the National Registry. Pursuant to 18 VAC 130-20-90, appraisers are assessed an $80.00 National Registry fee when applying for a permanent license in Virginia. Appraisers then pay $80.00 of the appraiser biennial renewal fee of $150.00 for submission to the Appraisal Subcommittee. 18 VAC 130-20-130. AMCs are only permitted to contract with licensed appraisers in accordance with Section 54.1-2022 of the Code of Virginia. Therefore, since each of the licensed appraisers working for or contracting with an AMC must pay a National Registry Fee, it is duplicative to collect an additional $50 fee per appraiser from each AMC. Furthermore, many appraisers work for or contract with multiple AMCs. The proposed regulation will cause Virginia to collect the same National Registry fee from an appraiser and then from each AMC which that appraiser works for or contracts with. Additionally, collecting a National Registry fee from each AMC for each appraiser is unnecessary because the Appraisal Subcommittee only maintains one national registry of individuals who are qualified and eligible to perform appraisals in connection with federally related transactions, and the National Registry only tracks appraisers, not AMCs.

For these reasons, Southwest Financial Services, Ltd. asks the Real Estate Appraiser Board to remove the requirement that AMCs must submit a fee of $50 per appraiser working for or contracting with an AMC.