<HTML> <HEAD> <title>WebForm1</title> <meta name="GENERATOR" content="Microsoft Visual Studio .NET 7.1"> <meta name="CODE_LANGUAGE" content="Visual Basic .NET 7.1"> <meta name="vs_defaultClientScript" content="JavaScript"> <meta name="vs_targetSchema" content="http://schemas.microsoft.com/intellisense/ie5"> <META http-equiv=Content-Type content='text/html; charset=UTF-8'> </HEAD> <body > <TABLE id="Table1" cellSpacing="1" cellPadding="1" width="100%" border="0"> <TR> <TD><b>Comment Number:</b></TD> <TD>518795-00257</TD> </TR> <TR> <TD><b>Received Date:</b></TD> <TD>10/24/2005 10:09:49 PM</TD> </TR> <TR> <TD><b>Organization:</b></TD> <TD>Intero Real Estate Services</TD> </TR> <TR> <TD><b>Commenter:</b></TD> <TD>Pope-Handy, Mary</TD> </TR> <TR> <TD><b>State:</b></TD> <TD>CA</TD> </TR> <TR> <TD><b>Agency:</b></TD> <TD>Federal Trade Commission</TD> </TR> <TR> <TD><b>Rule:</b></TD> <TD>Competition Policy and the Real Estate Industry</TD> </TR> <TR> <TD><b>Docket ID:</b></TD> <TD>To Be Added</TD> </TR> <TR> <td colspan='2'>No Attachments</td> </TR> </TABLE> <hr/> <b>Comments:</b><br/><br/> I'm writing in response to the Department of Justice's contention that the real estate industry is not competitive enough. This is badly off-mark. Please allow me to explain. My "market" is Silicon Valley, with about 1.2 million people and about 12,000 real estate licensees (of which approximately 8,000 are Realtors, meaning that they are members of the national, state, and local boards who abide by a code of ethics). At this writing we have approximately 4 licensees per listing - so the number of agents vastly outweighs the number of homes for sale. This alone tells you that the industry, at least where I work, is tremendously competitive. (Part of the inflation of the number of agents has to do with the high-tech job losses and the mistaken idea that real estate sales is easy money. Half of the practicioners will leave within 18 months, though, usually because they simply cannot survive the high expenses and even higher level of competition.) The public often perceives all licensees as pretty much the same - sort of like shopping for apples in the produce section. Experienced agents will tell you that they learn something on every transaction, though, and try to make a point to the public that knowing what you're doing (and being able to try to dodge pitfalls as well as make the seller the most money) has a value. So we as a group are constantly trying to improve our skills and our services to differentiate ourselves and to improve the client's experience - which usually results in better referral and repeat business. To lay open my own books with you on this point, each year I spend appx. $2200 on memberships (to the real estate associations/boards, the MLS, to groups with offer designations and ongoing training). Additionally I take extra classes each year and attend conferences to improve my knowledge and skills - usually running about $300 per course and about a thousand if I attend a conference. My web presence alone runs me $5000 a year (I have two sites of my own but also place my listings on a half dozen other sites, and enhance them with virtual tours, audio tours, online transaction management, online disclosures and reports, multiple still photos, etc.). Most agents spend 30-50% of their income on expenses (marketing, education, memberships, insurance, office fees), and then pay taxes after that - so take home pay can be 30-50% of the original commission check. The public does not see this but has the wrong idea that we are all making money hand over fist. That just isn't the case for the vast majority of full-time practicioners. My point in the frank discussion of costs is that if it were NOT so competitive, we would not kill ourselves with the expenses to begin with but would increase our take-home by lowering our expenses. But we cannot do that and stay competitive. Because it's an open market, we have to do what it takes to stay alive in this business. I've been in it 12 1/2 years and am constantly having to improve myself, adapt and learn to keep up. Best Regards, Mary Pope-Handy www.PopeHandy.com and www.ValleyOfHeartsDelight.com co-author, "Get The Best Deal When Selling Your Home In Silicon Valley" email:&nbsp;&nbsp;<A name=RDACT1></A> </body> </HTML>