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On July 18, 2016, NAR submitted comments to the Appraisal Subcommittee (ASC) on a proposed rule concerning the annual Appraisal Management Company (AMC) registry fees. NAR urged the ASC to adopt the proposed Third Option for determining the number of appraisers considered to be “working for or contracting with” an AMC for the purposes of calculating the annual registry fee. Unlike the First and Second Options, the Third Option will consider only those appraisers that fulfill an assignment for the AMC, rather than requiring a fee based on appraisers who simply are on members of an AMC panel or were only engaged for an AMC assignment. NAR also urged the ASC to add language stating that fees cannot be passed onto the appraiser and must be paid directly by the AMC.
Sehar Siddiqi, ssiddiqi@realtors.org, 202-383-1176