IMO, and I base this on 100's of residential appraisals I've reviewed, this is the situation as I see it:
Pre-1004mc:
Two groups of reports:
A. Those who did an adequate or better level of market analysis and included it in the report that met the minimum standard requirements
and
B. Those who did not
Group #B was, relatively speaking, very large.
Post-1004mc:
C. Those who do an adequate or better level of market analysis which, for GSE-guideline required work includes the 1004mc, and it meets the minimum standard requirements
and
D. Those that do not meet the minimum standards even with the 1004mc
My observation is that the size of group #D is smaller relative to what group #B's size pre-1004mc.
I don't like the form (never have). It doesn't change what I do think is necessary and it really doesn't add that much more work to what I do. That could be a function of my market and the tools I use (and pay for) to automate the form-filling function of the 1004mc. My fees reflect that.
But I do think it has reduced the number of reports, based on
my observations, that fail to provide an adequate market analysis necessary to meet the minimum requirements.
IMO, it has moved the needle toward "better" vs. what was before. But "better" overall isn't where we should be.
Many reports still have a long way to go. But at least many report writers are now starting to move in that direction. And, as evidenced by this thread, what constitutes the necessary market analysis is a hot topic.
This was never a residential discussion (that I recall) pre-bust and only appeared on the radar screen at the bust.
And, I would venture to predict that if a market starts to significantly shift in one direction or another, those who do a sub-adequate job in their 1004mc reliance and presentation will start to see requests for additional, supplemental information.
So my point is this (and is based on my observations):
1. The 1004mc form in many cases is inadequate but clearly the instructions to use the form take into account that contingency (supplement as necessary)
2. With the introduction of the 1004mc, what exists now as far as market analysis and reporting, on average, is better than what existed before, on average
3. While the level of analysis has, on average, improved, it is no where near where it should be
#1 is a fact.
#2 is my observation (but the GSEs report the same thing)
#3 is not a GSE issue but an appraiser issue. The appraiser can always supplement the 1004mc to do what is necessary for the market analysis to be relevant.
UAD didn't change the condition of the homes nor should it have impacted how we analyze those conditions. It merely required us to present the data a certain way. It doesn't change the way we analyze the data to make comparisons and adjust for differences.
The 1004mc doesn't change what the market is or impact how the market is reacting. It merely requires us to present the data a certain way. It doesn't change the way we analyze the market to make comparisons and adjust for changes in condition.
Sometimes I have an assignment where I need to go into detail about the strengths and weaknesses of the data, how that may impact the analysis, and what I did to overcome those weaknesses.
I just do that often and specific to the market analysis when I'm analyzing market conditions and the 1004mc is part of that analysis. The 1004mc might cost me an extra $3 in the report and an extra 5-minutes for the automated process to populate the data fields and for me to comment on that specific data and for me to reference the intended user to the supplemental data. I've factored that into my fee.
If it is factored into my fee, it isn't extra work.
Like I said to another poster:
If the argument is that 1004mc takes additional time that I don't find necessary or useful (but the client requires it) so we should factor that into our fee, I'll join in on that argument all day long.
What I won't let myself do (regardless of the satisfaction it may bring or the ease in getting on to the next assignment) is to complete it incorrectly contrary to what the instructions (expectations) require. The whole point of my supplemental market analysis is to do what I think is necessary to make a credible conclusion; my supplemental will either confirm the 1004mc's indication or conclude a more credible conclusion.
The same goes for the cost approach. Just because I don't think it is necessary, if I do it, I'm going to do it correctly. A client or state auditor isn't going to accept,
"You did this wrong. Why?"
"Because it is meaningless, no one looks at it, and so who cares!"
I'll do it correctly and address the reliability of my results in my value reconciliation:
The data considered and analyzed in the sales comparison approach is superior to that of the cost approach and therefore I'm relying on the SCA.
I do the same for the 1004mc
:
The data considered and analyzed in my supplemental market analysis is superior to the 1004mc and therefore I am relying on my supplemental analysis to make my market condition conclusions.
After 7 years of having this form, are we really still arguing about it and how to deal with it (
This question is not directed at you HSH but to all of us collectively)?
I can think of a lot of other areas where I'd like to vent my frustration. The 1004mc isn't one of them because there is a workaround that addresses all of its shortcomings.