<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>518795-00150</TD> </TR> <TR> <TD><b>Received Date:</b></TD> <TD>10/21/2005 7:31:23 PM</TD> </TR> <TR> <TD><b>Organization:</b></TD> <TD>West Teays Realty</TD> </TR> <TR> <TD><b>Commenter:</b></TD> <TD>Belfield, Alexander</TD> </TR> <TR> <TD><b>State:</b></TD> <TD>WV</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/> October 21, 2005 Ref: Competition in the Real Estate Business. Ladies and Gentlemen: Please be advised that as a member of the National Association of Realtors since 1971, I believe that the real estate trade is and has been amply competitive, proactively consumer friendly, and requires no additional legislation or legal adjudication. It has been stated in many recent public media that multiple listing systems, MLS s, are  a collection of listing data. In fact, such a simple statement is both deficient of relevant information and short sighted in understanding. In fact, MLS s, most of who but not all, operate as members of the National Association of Realtors. As such they are a group of cooperating and competing brokerages of various business models that lead to a voluntary listing data base focal point that significantly enhance the purchase and sale of real estate in their respective market areas. Furthermore, the National Association of Realtors has stated the following accurate description of MLS s:  The MLS is a cooperative, broker-to-broker offer of cooperation and compensation that help both brokers and consumers buy and sell homes. It is not a public utility, nor should it be. The beauty of the MLS is that it allows real estate brokerages of every size to compete on a level playing field. It gives all of us access to an inventory of property listings that we are able to show and sell to our clients. The MLS doesn't discriminate. All MLS members are treated equally, regardless of their size or their business model, and yet the rights of property owners and their listing brokers are respected. The rules of the MLS achieve a delicate balance between respecting the rights of listing brokers so they will continue to be willing to contribute their inventory of listings and permitting cooperating brokers the ability to show those listings and be assured of receiving compensation if they bring about a successful sale.  Though my market area of Charleston, West Virginia is known to be more of an  estuary market that is one of the last to see the changes of larger and more test market prone areas, I am aware in our market of much competition between  traditional full service brokerages and of one national franchise brokerage offering unbundled services that is doing very well under present West Virginia State Real Estate Commission regulations and National Association of Realtors MLS regulations. I therefore respectfully request your favorable consideration of my initial statement as you consider testimony, documents and depositions relevant to this issue. Respectfully yours, Alexander B. Belfield III West Teays Realty Hurricane, West Virginia&nbsp;&nbsp;2005 President: kanawha Valley Board of Realtors <A name=RDACT1></A> </body> </HTML>