In my 20+ years appraising real estate within the Great State of Virginia the last 5-7 years in my opinion have been negatively affected by the AMC's business model which more and more lenders are utilizing. The fee's are lower, turn times are often requested within 24-48 hours and often appraiser's are selected from out of the area because of their low fee's. The consumers have no idea they how much they are paying for our appraisal services because the AMC'S do not have to disclose this information. I would strongly urge the Board to review the Louisiana AMC License and Regulation Act- below are just a few of the most important issue's. In closing I would like to think the Board for considering the following information.

Louisiana “AMC License and regulation Act” reads;

§3415.15. Fees; customary and reasonable; disclosure

A. 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.

B. An appraisal management company shall separately state to the client all of the following:

(1) The fees paid to an appraiser for appraisal services.

(2) The fees charged by the appraisal management company for services associated with the management of the appraisal process, including procurement of the appraiser's services.

C.(1) An appraisal management company shall not prohibit any appraiser who is part of an appraiser panel from recording the fee that the appraiser was paid by the appraisal management company for the performance of the appraisal within the appraisal report that is submitted by the appraiser to the appraisal management company.

(2) 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.