Revision Request

[DWiley]

@DWiley
In case you missed this: Do you think D-F intent is to give an exception to the law for value pressure in regards to ROVs? Is it ok to send over comps because they're higher price to try to get the appraiser to raise the Market Value?

DF recognizes something that you seem to not understand (or perhaps "accept" would be the better term) - Providing sales and asking an appraiser to address why those sales were not used is not, in and of itself, pressure. That is why the law that prohibits appraiser pressure is also the law that specifically says that asking an appraiser to address alternative sales data is OK. Pressure can only truly be exerted by a party with the position/leverage to exert it. Most buyers/sellers/agents are in no position to exert any real pressure (though they certainly used to be prior to AIR).

You also seem unwilling to acknowledge that what is considered legitimately "appropriate" to a buyer/agent/seller/etc. might be very different than what is considered "appropriate" to one with the specialized knowledge and training that appraisers possess. It takes years of experience, education and training to become an appraiser. To expect a party to a transaction to be able to screen and select sales in the same manner an appraiser would minimizes what we do as professional appraisers. Yet, you would impose a monetary penalty overt that.

As Denis noted, with the wording in DF, responding to requests to consider alternate sales data should be viewed as a standard part of the SOW. We try to make sure that is understood (on the front end) by addressing it in our appraiser agreements.

 

[residentialguy]

You also seem unwilling to acknowledge that what is considered legitimately "appropriate" to a buyer/agent/seller/etc. might be very different than what is considered "appropriate" to one with the specialized knowledge and training that appraisers possess.

When it comes to law, you seem to think that ignorance is a defense. It's not. You need to know if it is appropriate. You need to know if it is value pressure.
Here's a good test. Send a bunch of high priced sales that target the contract on your appraisal orders. If that's appropriate there shouldn't be a problem.

To expect a party to a transaction to be able to screen and select sales in the same manner an appraiser would minimizes what we do as professional appraisers.

FNMA expects it from you with their comps.

 

[DTB]

Has anyone ever received lower sold comps than used in a sale appraisal?

 

[residentialguy]

with the wording in DF, responding to requests to consider alternate sales data should be viewed as a standard part of the SOW.

as he also said...within limits. Sorry, but you have skin in the game, so we'll have to take your view on SOW with a little SALT.

 

[residentialguy]

Providing sales and asking an appraiser to address why those sales were not used is not, in and of itself, pressure. That is why the law that prohibits appraiser pressure is also the law that specifically says that asking an appraiser to address alternative sales data is OK. Pressure can only truly be exerted by a party with the position/leverage to exert it. Most buyers/sellers/agents are in no position to exert any real pressure (though they certainly used to be prior to AIR).

So, in other words, it's not value pressure for the lender to send over comps because they're higher price to try to get the appraiser to raise the Market Value.
Ookie dookie!

Let's see what the verdict is when appraisers start reporting Lenders for value pressure they're feeling from that. Should be no problem.

 

[timd354]

Has anyone ever received lower sold comps than used in a sale appraisal?

If the loan was sent to my company for Mortage Insurance, there is a very good chance that has happened as we regularly ask urlender to request the appraisers to include certain sales that sold lower than the sales price (that appear to be possibly superior comps) in the appraisal report or to provide a narrative explanation of why such sales are not appropriate to include in the report..

 

[ucbruin]

Has anyone ever received lower sold comps than used in a sale appraisal?

I have a couple of times that I can remember....

I assumed my appraised value was considered high...

Obviously I didn't employ any...

 

[DWiley]

Has anyone ever received lower sold comps than used in a sale appraisal?

Sure. That is not nearly as rare as most would think. Especially from a lender review team.

 

[Mr Rex]

Has anyone ever received lower sold comps than used in a sale appraisal?

I just had one that the RE agent presented that sold higher, but was larger GLA, had 1 more garage bay, an additional screened porch and a few other superior features etc that made it adjust lower than my value. I had gridded it originally but tossed it as the net and gross were the highest of the available comps. Now they are "requiring" that I include it. I just sent an e-mail asking if they also "require" that I reduce my opinion of value?

 

[DWiley]

So, in other words, it's not value pressure for the lender to send over comps because they're higher price to try to get the appraiser to raise the Market Value.
Ookie dookie!

Again - not what I said. This will be my last post in this thread, because I am done with you putting words into my mouth.

Did you even see the assumption you made about lender motives? The reality is that lenders often know that ROVs will not result in any change, but they also know the wording in DF regarding a seller submitting alternate sales. And, they know that agents and sellers are aware of it as well (trust me, agents make sure sellers are aware). So, they send the sales to appease their client - the borrower. If they don't send them, the agent will throw that DF language right into the lender's face.

I get to see the deal from both sides now, and I can tell you first hand that there is a LOT less pressure than there used to be. I can also say with 100% certainty that there will always be appraisers who treat any question, any at all, as pressure. That is just reality.