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The authors did not determine the source of the U.S. commission information. See NAR, Public Comment 208, at 15-16; Delcoure & Miller, supra, at 15. 173. Approximately half of the general public comments sent to the Agencies in action to their ask for public remarks were some variation of a kind letter that NAR made up, posted on its site, and encouraged its 1.
This letter praised the competitive nature of the genuine estate market. Commenters utilizing this kind highlighted regional competition between specific representatives as an impressive example of strenuous competition to which the remainder of the economy need to aspire - how to start real estate investing. In addition, they declared that the 10s of countless brokerages, more than 2 million licensed realty professionals, and different organization models across the nation provide consumers with a good deal of option.
realtor.org/law_and_policy/mls/ild/regulator_letters. html) for more information on the association's guidelines and suggested content. 174. NAR, Public Remark 208, at 1 (remark). 175. Id. at 2. 176. Blann, Public Comment 250, at 1. But see NAR 2006 STUDY, supra note 100 money back guaranteed 4, at 74 (69% of sellers gotten in touch with just one representative; 74% of sellers found their agent through either a referral or a previous relationship with the representative).

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Reppert, Public Remark 294, at 1. See also Tradii, Public Comment 340, at 1; Wharton, Public Remark 179, at 1. 178. See, e. g., Earman, Public Comment 73, at 1-2 (average commission is "well under 6%"); Giorgianni, Public Remark 200, at 1 (" My average commission has actually dropped over the last ten years from 3% to about 2.
179. Paulsen, Public Remark 364, at 1. Numerous panelists and commenters cited Genuine Trends estimates of commission rates. See, e. g., Kunz, Tr. at 81-82; Lewis, Tr. at 172; NAR, Public Comment 208, at 12 (comment). 180. Lord, Public Remark 254, at 1. 181. Id. at 1. 182. Dwyer, Public Comment 55, at 1.
There are a variety of options offered to buyers and sellers from complete service representatives to extremely restricted service agents with a wide range of cost structures."); Big, Public Remark 241, at 1 (" our typical commission per transaction side has actually dropped 13% this year compared to in 2015 as a result of competitors from discount brokerage business models running in our market").

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GAO REPORT, supra note 3, at 12. 184. As discussed in Chapter I of this Report, the commission "rate" is the percentage of the home list prices that the broker maintains as a commission, and commission "costs" are the overall dollar quantity paid by customers for real estate brokerage services.
185. Weicher, supra note 167, at 121. what does a real estate broker do. 186. NAR a sensible source of commission data, offered its size and access to MLS data through its regional associations does not study or report commission rates. A NAR economist explained at the workshop that any typical commission rate reported by a popular entity such as NAR might be utilized by market participants as a centerpiece for collusion on commission rates.
at 225-26. See also NAR, Public Comment 208, at 12 (comment) (" [NAR] does not conduct research on commission rates out of concerns that the research results have the impact of setting a 'centerpiece' for professionals to set their commissions."). 187. Weicher, supra note 167, at 124. Weicher's computations use average house list prices, not mean house list prices.

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Id. 189. See Hearing, supra note 1, at 5 (testament of David G. Wood), offered at http://financialservices. house.gov/ media/pdf/072506dgw. pdf. 190. Id. at 6. 191. See Realogy Corporation 10-K for ending Dec. 31, 2006, readily available at http://www. sec.gov/ Archives/edgar/data/ 1355001/000095012307003335/e31090e10vk. htm #tocpage. 192. A detailed evaluation of the empirical research study conducted in the property brokerage industry is beyond the scope of this Report.
Turnbull, Trends in Property Research Study, 1988-2001: What's Hot and What's Not, 29 JOURNAL OF REAL ESTATE FINANCING AND ECONOMICS 47 (2004 ); John D. Benjamin, G. Donald Jud & G. Stacy Sirmans, What Do We Understand About Property Brokerage?, 20 JOURNAL OF PROPERTY RESEARCH STUDY 5 (2000 ). 193. 1983 FTC STAFF REPORT, supra note 9, at 45.
Id. 195. Id. at 46 (49. 6% of sample paid 6%, while 27. 9% paid 7%). 196. Id. at 48. 197. Id. at 52. 198. See Michael Carney, Costs and Prices of Home Brokerage Solutions, 10 JOURNAL OF THE AMERICAN REALTY AND URBAN ECONOMICS ASSOCIATION 331 (1982 ). 199. Id.

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200. Id. at 336. 201. Id. at 348 (" [O] n average, a $100,000 increase in the rate of the home reduces the commission rate by about 0. 5 portion points"). The typical prices of an existing house in 1980 was $72,800. See U.S. Department of Housing and Urban Advancement, U.S.
2006) [hereinafter "HUD REPORT"], offered at http://www. huduser.org/periodicals/ushmc/fall06/USHMC_Q306. pdf. At that price, the study's statistical results forecast a matching commission rate of 6. 25%, causing a commission cost of $4,550. A house selling for $100,000 more, or $172,000, would pay a commission rate of 5. 73%, for a commission charge of $9,901.
Carney, supra note 198, at 339 (omitting 5 areas with inadequate observations for brand-new homes, in 59 percent of the remaining selling timeshare scam market locations the mean commission rate paid was statistically considerably greater for existing homes than for new homes). 203. Id. 204. Id. at 248. 205. See William C. Goolsby & Barbara J.

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206. Id. at 84. 207. This finding was considerable at the one percent level for each of the formulas evaluated. See id. at 83. However, Weicher notes that the magnitude of the prices effect seems small. See Weicher, supra note 167, at 121 (" Goolsby and Childs discover that the commission rate decreases about 0.
11 percentage points for each $10,000 boost in house rate, e. g., from 5. 90 percent to 5. 84 or 5. 79 percent."). 208. Goolsby & Childs, supra note 205, at 85. Because the authors only observed the cooperative commission rate, they note that their conclusion rests on the assumption that the cooperative split is a fixed share of the overall listing commission.
See id. at 81 n. 1. 209. See C.F. Sirmans & Geoffrey K. Turnbull, Brokerage Rates under Competition, 41 JOURNAL OF URBAN ECONOMICS 102 (1997 ). This study obviously includes the information and timeshare donations to charity relevant findings of an earlier research study carried out by the authors. See C.F. Sirmans, Geoffrey K. Turnbull & John D.

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210. Sirmans & Turnbull, supra note 209, at 111. 211. Id. at 113-115. 212. Id. at 113-14. The authors performed regressions examining how the contract commission rate was affected by numerous market conditions and real estate variables. As the authors explain, the commission rate caught in the sample is "the contract rate and therefore does not show any adjustment or modifications that might be renegotiated between your house seller and the agent at the time of sale." Id.
213. While it is not possible to measure the relative inflexibility based upon info reported by the authors, additional details can be used to compute a rough approximation. Weicher, supra note 166, at 121, reports that Sirmans and Turnbull calculated an average contract commission rate of 5. 8% in Baton Rouge over the period 1985-1987.