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.