I wanted to give my support for the proposed change, which is:

"A Virginia licensee that is also licensed in another state with which the board shares a reciprocal agreement may use board-approved continuing education in that state to meet the required six hours of continuing education for Virginia, provided that the reciprocal jurisdiction affords the same privilege to Virginia licensees."

Some states require that an auctioneer travel to their state in order to physically sit in a classroom and sit through required continuing education.  It's expensive, time consuming, and unnecessary.  Not only can quality education be delivered via the internet (rendering travel unnecessary), but I believe lenient, open door policies are more conducive to encouraging business in our state.  And furthermore, I don't want to require a non-resident auctioneer to travel to Virginia to take continuing education because I'm personally annoyed when I am required to do that myself for another state.

One of our members identified a potential issue regarding the contract required to conduct as auction.  For your consideration and review the comment follows below:

After a review of the propsed reguations, we believe that there is a conflict in the Proposed 18VAC25-21-10.
Page 4, 18VAC25-21-110 Contracts; Paragraph 1.a. regarding providing an adequate description of the property.  1.a. says that if the description list cannot be given at the time of the contract, then it must be delivered before the sale and attached to the contract before the sale.
 
In paragraph 8 below, it is stated that in 8.b. (top of page 5) .... "A legible executed copy of the contract and any addendums shall be given to the owner at the time of execution."
 
The 1.a. implies that you can commit the seller to a contract, but you do not have to deliver a description of items for sale until a later date, but before the sale.  In 8.b. you must provide a description at the time the contract is executed.  This is difficult where many items are to be sold and an inventory might take a week to produce. 
 
Also, 8.b. needs to have inserted. "of the contract" at the very end of the sentence or else it becomes  humorous implying that the owner of the goods will be executed.  8.b. probably should be removed and allow 1.a. to remain.

The proposed regulations revise the fees for examination and reexamination by authorizing the board to adjust these fees in accordance with contracts with which the Commonwealth has entered into to provide these services.

We oppose this proposal to the regulations.  As well meaning as this proposal may seem, it would provide the board with the authorization to revise fees, outside of notice and comment rule making, to a level that may prohibit individuals from taking the exam.  Basing fees upon contracts that are still to be negotiated in the future is troublesome because of the potential for unknow future contract issues that could cause excessive fee increases.

We request that the board revisit this matter and provide safeguards which will prevent uncontrolled increases in the auctioneers licensing fee.