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
spacer
Previous Comment     Next Comment     Back to List of Comments
3/25/14  10:37 am
Commenter: Jeffrey D Ellington, Sinnen-Green & Associates

AMC Regulation/Customary Fees
 

I fully support the regulation of Appraisal Management Companies in Virginia.  Having been in the appraisal business for 20 years, I have seen these companies take full advantage of hard-working appraisers by paying lower than normal fees and placing undue pressure on the appraiser in the form of quick turn times, constant updates, etc.  When you combine these factors, what happens is that experienced appraisers opt out of doing these appraisals for end users that were often times former clients and the AMC's choose less experienced and less qualified appraisers, often times from outside the immediate market area, to perform these appraisals. Ultimately, the consumers are the ones being harmed in this situation. Ironically, the consumers (American tax payers) were the ones trying to be protected with all of the Dodd Frank, HVCC, etc. legislation. Other professions are not subject to these actions, as the best of other professions are compensated as such.  In addition to the appraisers being hurt, the consumers are paying higher fees, and receiving lower quality appraisals.  Some AMCs will shop an appraisal at a low fee until someone will accept the assignment.  This isn't the way the business should work, and quality work should be compensated fairly. We appreciate any and all consideration by the Board to help protect our profession. A review of the State of Louisiana's new AMC License and Regulation Act should be done by the Board. Thank you again for your consideration. 

CommentID: 31497