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comps within 90 days? -Newsletter

Discussion in 'Illinois' started by Tony Bamert, Jul 4, 2011.

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  1. Tony Bamert

    Tony Bamert Junior Member

    2
    Jan 26, 2010
    Professional Status:
    Certified Residential Appraiser
    State:
    Illinois
    As I read the newsletter article on "comps within 90 days" I flashed back to a recent FHA CE course where we talked about the HUD guidelines that came out in Mortgagee letter 2009-09. Here is the exact language from that letter:


    "Appraisals of properties located in declining markets must include at least two comparable sales that closed within 90 days prior to the effective date of the appraisal."
     
  2. Tony V

    Tony V Elite Member

    66
    Mar 29, 2005
    Professional Status:
    Certified Residential Appraiser
    State:
    New York
    It goes on to say
    Appraisal Reporting Requirements in Declining Markets

    Appraisals of properties located in declining markets must include at least two comparable sales that closed within 90 days prior to the effective date of the appraisal.
    In some markets compliance with this requirement may be difficult or not possible due to the lack of market data and, in these cases, a detailed explanation is required. The appraiser is expected to include at least two sales that are as similar as possible to the subject and which settled within 90 days of the effective date of the appraisal in order to show recent market activity.
     
  3. leelansford

    leelansford Elite Member

    45
    Mar 29, 2002
    Professional Status:
    Certified Residential Appraiser
    State:
    Illinois

    An important distinction, no doubt.

    "Guidelines", if the market does not allow the appraiser to comply, can be appropriately explained away and that's that.

    "Requirements" of the assignment: These must be adhered to if the appraiser accepts the assignment.

    The referenced FHA statement ("preference" might be a better description) request is a "guideline".
     
  4. AnonApprsr

    AnonApprsr Elite Member

    0
    Jan 21, 2008
    Professional Status:
    Certified Residential Appraiser
    State:
    Massachusetts
    If there are "comps" that sold within 30 days I'm using them. That's explained in my report, if there are Comparable Sales that have sold recently, they will be used. If there are not, there will not.
     
  5. RSW

    RSW Elite Member

    73
    Feb 18, 2002
    Professional Status:
    Certified Residential Appraiser
    State:
    Tennessee
    I do rural FHA appraisals all the time where the market is declining and I don't have two closed sales within 90 days. I explain my efforts in trying to locate sales that meets the 90 day requirement and that I could not provide sales that have sold within the last 90 days. I've never had a problem with the DEU on them.
     
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