Summary
In 2011, the division received one public comment on a proposed rule amendment which would require disclosure by an AMC of any charges of costs or fees to an appraiser at the time the assignment is offered and such costs or fees could not be inflated above the actual cost of a service provided by a third party and could not be charged for a service not actually performed. The commenter suggested that the amendment should be changed to distinguish general fees from transactional fees. In response to an amendment filed 07/09/2012, which would require that AMCs obtain a $25,000 surety bond, the division received 11 public comments, six in favor of the amendment, two against, two that thought the bond amount should be higher, and one neutral comment. In response to an amendment filed 03/06/2012, which would clarify the administrative procedures for adjudicating a matter involving an AMC, the division received one public comment recommending changes to the proposed amendment including a requirement of a formal adjudicative proceeding in certain circumstances. In response to a proposed amendment filed 05/31/2013, the division received four comments on a proposed rule amendment which would clarify the unprofessional conduct provision relative to the use of an employee to complete an appraisal assignment. All of the comments expressed concern about the effective of the proposed rule amendment or were opposed to the proposed amendment.