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Bankruptcy Court Part 3 - Motivation of distressed sale, typical = predominate

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Randolph Kinney

Elite Member
Joined
Apr 7, 2005
Professional Status
Retired Appraiser
State
North Carolina
UNITED STATES BANKRUPTCY COURT
NORTHERN DISTRICT OF CALIFORNIA

Case No. 10-50394-ASW
Chapter 13


In r e: VICTORIANO AND ANNALIZA DUARTE, Debtors.

http://www.bankruptcymastery.com/wp-content/uploads/2011/07/duarte-dueling-appraisers.pdf



Before the Court is the motion ("Motion") by debtors Victoriano and Annaliza Duarte ("Debtors") to determine the value and status of the second priority deed of trust held by creditors Duane E. Gifford and Marilyn L. Gifford ("Giffords") against the Debtors' primary residence located at 767 Lakehaven Dr. Sunnyvale, California 94089 ("property").


This Memorandum Decision constitutes the Court's findings of fact and conclusions of law, pursuant to Rule 7052 of the Federal Rules of Bankruptcy Procedure.

At the September 2, 2010 hearing, each party offered an expert witness to opine as to the value of the Property at the time of Debtors' bankruptcy petition. Both experts prepared written reports and those reports were entered into evidence. Debtors'expert witness Daniel Ordaz is an independent contract appraiser of real property specializing in Santa Clara County. The Giffords' expert witness Boris Chtchetinin is an owner and principal appraiser for his own appraisal business, that operates throughout the entire Bay Area but specializes in Santa Clara County. Both appraisers were qualified to testify as experts concerning the value of the Property.

Ordaz testified that Ordaz believed the fair market value of the Property was $370,000.00 as of January 17, 2010. Ordaz based that conclusion upon a sales comparison analysis of four comparable properties. Three of the properties were bank-owned properties, i.e., the respective banks obtained these properties through foreclosure and now offer the properties for sale. One of the properties was a short sale. Ordaz determined that the value of the Property was $370,000 based on the sales comparison approach and $371,723 based on the cost approach. Ordaz testified that the Property was in average condition. The sales prices of the Ordaz comparables ranged from $366,860 to $395,000 and were sold between September 25, 2009 and January 13, 2010. The comparables were located from .14 miles to .80 miles away from the Property. Ordaz explained that Ordaz was unable to find any private sales (i.e., sales that were not bank owned) or short sales among the comparables in his research that were applicable and relevant. Ordaz further stated that bank-owned property sales and short sales were the predominant form of sale within the area of the subject property and thus are valid comparables when those sales are the dominant sales mode within the neighborhood. Ordaz did not make adjustments in sale price based on whether the comparable consisted of a bank-owned property or short sale because Ordaz testified that it is not standard industry practice to make such adjustments due to the difficulty in objectively determining the value of the adjustment.

Chtchetinin testified that Chtchetinin believed the fair market value of the Property was $395,000 as of January 17, 2010. Chtchetinin based that conclusion upon a sales comparison analysis based on comparable properties — all of which had sold prior to the court hearing but none of which had closed escrow at the time of Debtors' bankruptcy petition. Chtchetinin reviewed three comparable properties between .11 and .49 miles from the Property — two of the comparable properties were bank owned properties sold after a foreclosure and one sold through a private sale. Chtchetinin determined that the value of the Property was $395,000 based on the sales comparison approach and was $381,200 based on the cost approach. The adjusted sales price of the three comparable properties Chtchetinin used in his report ranged from $387,000 to $403,000. Chtchetinin testified that these three comparables in his report represented the mid-range of value where the Property fit based on condition; some other properties of superior quality were selling for $420,000 while some properties of lesser quality were selling for $360,000. Chtchetinin described the Property as average condition with some interior updates.

Chtchetinin used sales which had not yet closed as of the petition date in Chtchetinin's retrospective appraisal explaining that while the sales did not close before the petition date, Chtchetinin verified that the contract prices of the comparable sales were also the final sales prices by cross checking the contract price with the post bankruptcy petition property closing price on the Multi Listing Service' website. Chtchetinin stated that the Multi Listing Service search function did not have a feature to filter out properties that had not closed escrow prior to the bankruptcy petition date. Chtchetinin testified that if such filtering were necessary, it would need to be done manually by the appraiser. Chtchetinin acknowledged that it is possible for events to occur between the date of contract and the date of closing that could change the final closing price. However, Chtchetinin stated that those events did not occur here and that the contract prices were representative of the market prices at the time of Debtors' bankruptcy petition.

Bankruptcy Code section 506(a)(1) instructs that when a court is requested to determine the value of collateral, "such value shall be determined in light of the purpose of the valuation and of the proposed disposition or use of such property..." 11 U.S.C. § 506(a)(1). When the debtors intend to stay in their house, the proper valuation of the house under Bankruptcy Code section 506(a) is the fair market value. Taffi v. United States of America (In re Taffi). 96 F.3d, 1190, 1192 (9th Cir. 1996).

The fair market value is "the price which a willing seller under no compulsion to sell and a willing buyer under no compulsion to buy would agree upon after the property has been exposed to the market for a reasonable time." Taffi, 96 F.3d at 1192. Debtors intend to stay in the Property, cure the loan owed to US Bank, and treat the Giffords as general unsecured creditors.

Both parties' expert witnesses used the sales comparable method to estimate the fair market value of the Property at the time of Debtors' bankruptcy petition. The hearing on the matter lasted roughly four hours wherein both experts and Debtors testified. The Court considered all the evidence admitted at trial, including the testimony of both experts. In addition, the Court prepared its own statistical analysis based solely upon the appraisal reports submitted by the two experts.

Debtors' expert, Ordaz, analyzed four comparable properties that were located between .14 and .80 miles from the Property. The properties Ordaz included in Ordaz's report were all sold between September 25, 2009, and January 13, 2010. Three of Ordaz's properties were bank-owned properties and one was sold through a short sale. Ordaz emphasized during his testimony that all of his comparables had closed escrow at the time of Debtors' bankruptcy petition. Based on these comparables, Ordaz concluded that the Property had a fair market value of $370,000 on the petition date. The Court calculated the average sales price of Ordaz's four comparable properties and found the average to be $375,091.00. The Court does not imply that the fair market value of any property is purely a statistical calculation, but it recognizes that such analysis can be instructive when confronted with conflicting and multifaceted data.

Debtors' have presented evidence sufficient to overcome the presumption of value within the Giffords claim.

Giffords' expert, Chtchetinin, analyzed three comparable properties that were located .11 and .49 miles from the Property. The properties Chtchetinin included in Chtchetinin's report were all sold in December 2009. However, unlike Ordaz, none of Chtchetinin's properties closed before Debtors' bankruptcy petition date. Two of Chtchetinin's comparables were bank-owned properties and one was a private sale. The private sale sold for the highest price. Chtchetinin concluded that the fair market value of the Property was likely $395,000 on the petition date. The Court notes that the average of Chtchetinin's comparables was also $395,000.

The difference between the first lien holder's proof of claim and both appraisers' estimates of fair market value is very narrow. Debtors contend that the fair market value, based on the sales comparison approach, was $370,000; $17,435.68 below the amount owed to the first lien holder. The Giffords respond that the fair market value was actually $395,000; $7,564.34 above the amount of the first lien holder. The Court's statistical analysis of the combined data presented by the experts proved to be even closer with an average of all comparables of $383,623.43, an average excluding the highest and lowest comparables of $383,100.80, and a median of $387,000 leading differences of $3,812.20, $4,334.83, and $435.63, respectively.

The average of all comparables, the average excluding the highest and lowest comparables, and the median are all below the first lien holder's proof of claim. Moreover, the Court found the average selling price of the three closest properties by distance to be $383,953.33 and the three properties with the sales date closest to the petition date to be $383,548.00 leading to differences of $3,482.30 and $3,977.63, respectively.

Again, both of these averages are below the first lien holder's proof of claim. Thus when the comparables are analyzed statistically as a whole, the comaparables generally indicate average and median values below that of the first lien holder's proof of claim. Based on the testimony at trial and this additional analysis, the Court finds that the Giffords' expert's testimony insufficient to persuade the Court that the preponderance of the evidence supports a value above that of the first deed of trust holder. Rather, it appears based on the fact four of the seven comparables are below the value of the first lien holder's proof of claim and the averages and medians of the data as a whole are below the first lien holder's proof of claim, the preponderance of the evidence demonstrates that the value of the Property was below the first lien holder's proof of claim.

The Giffords rely on a decision of the Bankruptcy Court for the Eastern District of California which expressed concerns regarding the inclusion of bank-owned properties within appraisal reports for determining the fair market value of property. See Serda, 395 B.R. at 454. The Court in Serda noted the potential different motivations for sale between private party sales and bank-owned sales, stating that banks had the motivation to liquidate inventory quickly for low prices whereas private parties had the motivation to wait for higher prices. However, the Ninth Circuit in Taffi stated, "Valuation must be accomplished within the actual situation presented." Taffi, 96 F.3d at 1192. Debtor's expert, Ordaz, testified that bank-owned property sales and short sales were the predominant form of sale within the area of the Property. Giffords' expert, Chtchetinin, also included two bank-owned properties -- out of the three comparables he used within his appraisal report.

Based on Ordaz's testimony that bank-owned property sales were the predominant form of sale within the area and the fact that two out of three of Chtchetinin's comparables were bank owned properties, the Court finds there is sufficient evidence to conclude that bankowned property sales are relevant in determining the fair market value of the Property at the time of Debtors' bankruptcy petition. Allowing the sales prices of bank-owned properties to be considered as comparables does not require any subjective determination of the motivation of the parties. The advertised prices of bank-owned properties would have been available to potential buyers and would have shaped buyers' price expectations because bank-owned properties are also competing against owner occupied properties within the real estate market. The appraiser merely includes the bank-owned property sales along with any other relevant properties in the appraiser's value analysis. This is analogous to how bank-owned properties are equally available on the real estate market for buyers. Because bank-owned properties were the predominant form of transfer of real estate within the area of the Property, willing buyers would have considered these properties within buyers' purchase calculations. Therefore, it is appropriate to include bank-owned properties in determining the fair market value of the Property because these types of properties were available on the market and were actively competing against private sales in the real estate market.

Even though there is the potential argument that bank owners of foreclosed property are under different motivations than private party owners of owner occupied homes, there is no objective method to determine the value of the potential difference of motivation. Ordaz testified that it is not common appraisal practice to make adjustments based on whether a home is owner-occupied or bank-owned because of the impossibility of making an objective valuation of the different motivations of the parties. A valuation of an adjustment for the different motivations of the parties would require the appraiser to devine the subjective intentions of the parties. Such an adjustment is unworkable in appraisal practice and cannot be used to adjust value here. Moreover, two out of three of Chtchetinin's comparables were also bank-owned properties indicating that Chtchetinin believed bank-owned properties were highly relevant to the valuation of the Property. Therefore, based on testimony that bank-owned properties predominated in the subject real estate market and that both appraisers included bank-owned properties in their respective appraisal reports, the Court finds sufficient evidence to conclude that willing buyers would have certainly considered bankowned properties in their purchase calculations and making objective adjustments for differences in sellers' motivations is not practical or even possible.

Debtors raised additional issues claiming that these issues could have influenced the fair market value of the Property. The expert appraisers differed on the appropriateness of using comparable sales that did not close prior to the bankruptcy petition. As the two experts disagreed, the Court frankly does not know whether it is appropriate in the appraiser profession for Chtchetinin to rely on these properties as comparables. However, for the purpose of this decision only, with no precedential value intended, the Court will assume that the use of these properties as comparables is allowed in the profession.

Neither party cited, and the Court did not find any law expressly permitting or prohibiting such use and it appears that the Serda decision may have used such sales. The Giffords' expert testified that all of the sales used in his report did eventually close for the prices stated in the appraisal report. Debtors argued that Debtors would not have known that these homes were sold for these prices at the time of the bankruptcy petition and thus would not have known -- in deciding how to price Debtors' home for sale -- to consider those homes.

Based on the evidence admitted at the hearing and the arguments of counsel, the Court finds that the fair market value of the Property at the time of Debtors' bankruptcy petition was less than $387,435.63, the amount of the senior secured debt owed to US Bank.

CONCLUSION

For the foregoing reasons, Debtors' Motion to determine the value and status of the Giffords Lien as wholly unsecured and void is granted. The Court finds that the value of the Property was less than the amount secured by the first deed of trust. Accordingly, the Giffords' secured claim is wholly unsecured and is not entitled to the protection of Bankruptcy Code section 1322(b)(2). Counsel for Debtors shall prepare a proposed form of order, serve it on counsel for the Giffords, and submit it to the Court.
 
TY Mr. Kinney. Well done!

Put that in your interpretation of Distress Sale pipe and smoke it, people!
 
Anyone want to highlight the relevant parts of that ugly blue text, it's hard to read so early in the morning.
 
If I read this right, and I'm no bankruptcy expert, the court has deemed the
debtor's first mortgage as an unsecured debt and therefore not subject to
repossession. Just like that big screen TV that you bought with a credit card
the day before you filed for bankruptcy.

Which will all make the battle for market value more interesting with so many
homes underwater. I see both sides doing appraiser shopping and the bankruptcy
court deciding which are the most appropriate comparables in the future.
 
Lets start with the title of the thread - Typical = Predominant

Here’s my summary:

So called distressed sales should not be discriminated against because of social, cultural or historic prejudices, but have earned their place in a free and fair market valuation among all transactions throughout every state, every city and every neighborhood across this great land!

That all appraisers should set aside old biases, leaving ignorance and hypocrisy at the failed front doors of Fannie Mae and Freddie Mac and judge each and every individual listing--be it active, expired, withdrawn, pending OR closed, within a fair and open context!

It's time for all appraises to come together and seek to bridge the differences between individual vs. corporate motivations and raise our voices in unison, together and as one --WE WILL NO LONGER TOLERATE THOSE WHO WISH TO DIVIDE US AND ADVANCE OLD AGENDAS!

That every property, and every market participant be fairly and justly evaluated not on the outdated interpretations of others, but solely on the content of their characteristics!! <raises and shakes fist, points to the heavens for visual impact>

:peace:

I HAD A DREAM and apparently this bankruptcy judge had the same one.

Does anyone know if it’s possible to Map Quest myself back to the Reservation?
 
This case went to court over a 6.3% difference of opinion. The question for the judge to decide was whether the value was less than $387,000, which would entitle the debtor to treat their creditor's 2nd as an unsecured creditors.

The appraisers for both sides included REO sales in their analyses. The debtor's creditor also included a short sale and the creditor's appraiser included a private sale. The debtor's creditor used all closed sales, whereas none of the creditor's sales were closed as of the date of the petition (they were all pendings).

The judge went at the data presented with his own statistical analysis, running averages and medians, and basically found an average and median price below the $387k.

The court also commented that as far as the use of REOs to indicate to value it "could not find any law expressly permitting or prohibiting such use". Nobody else seems to be able to find such a reference, either.


I take issue with a comment the debtor's appraiser made to the effect that it's uncommon or impossible to isolate an adjustment for seller motivation when such differences are present. I'm also a little leery of the creditor appraiser's use of all pendings during that particular period in time, when the feds were giving out those tax credits. In my region prices were increasing during that time frame.

However, the value itself or the differences in value between these two appraisals or the applicability of the FMV definition they were required to use aren't the topic of this discussion. It's the judge's rationale and ruling with the respect to the weighting of REO sales in situations where they are predominant that pertains to this discussion.

The argument that REO seller motivation is either atypical or indicative of "compulsion" within the context of these REO-saturated markets has been argued in at least a couple of these cases but the judges apparently aren't buying it and they also aren't finding any laws that directly address that question.

I think that all that's left for them is to read the laws they do have in front of them on a WYSIWYG basis using either the legal definitions that apply or when those aren't present the common meaning of the other definitions. The term "compulsion" that's used in the definition of FMV has a legal definition that in turn refers to a forcible inducement to act by lawful authority and which doesn't appear to reference economic or social inducements.

It may very well be that the "no compulsion to act" clause of FMV does not directly relate to the "no undue stimulus" or "typical motivations" clauses of the definition of MV used in mortgage appraisals.
 
I was just about to post a completely different post. But I decided to refresh the thread first and saw the post by George and decided not to post due to the similarities of the two. Good post, George.

Wake me up when there is a Federal Case against an appraiser over MV in a mortgage transaction.
 
I reckon the motivations of the various advocates for the opposing viewpoints is more closely related to trying to identify the appropriate course of action and what these definitions really mean. The various exchanges might resemble a struggle for domination, but in the end I'd rather end up with the correct understanding of the issue that try to "win" with an incorrect understanding.

I might be stupid and stubborn but I'm not a liar.

If I can find the reference or rationale that works better I'll change or adapt and I'll tell all my friends. There's no future in being wrong for the sake of popularity.

I think I'm going to spend some time with a couple legal dictionaries.
 
"Allowing the sales prices of bank-owned properties to be considered as comparables does not require any subjective determination of the motivation of the parties. The advertised prices of bank-owned properties would have been available to potential buyers and would have shaped buyers' price expectations because bank-owned properties are also competing against owner occupied properties within the real estate market. The appraiser merely includes the bank-owned property sales along with any other relevant properties in the appraiser's value analysis. This is analogous to how bank-owned properties are equally available on the real estate market for buyers. Because bank-owned properties were the predominant form of transfer of real estate within the area of the Property, willing buyers would have considered these properties within buyers' purchase calculations. Therefore, it is appropriate to include bank-owned properties in determining the fair market value of the Property because these types of properties were available on the market and were actively competing against private sales in the real estate market."

Common sense in a court of law.
 
FYI,
"CHAPTER 13 ELIGIBILITY
Any individual, even if self-employed or
operating an unincorporated business, is
eligible for chapter 13 relief as long as the
individual’s unsecured debts are less than
$360,475
and secured debts are less than
$1,081,400. 11 U.S.C. § 109(e). These
amounts are adjusted periodically to reflect
changes in the consumer price index. A
corporation or partnership may not be a
chapter 13 debtor. Id.

"Many people looking to stop foreclosure or avoid repossession file Chapter 13 bankruptcy because it
allows them to catch up past due payments over a period of three to five years while keeping current payments up to date.
When a person officially files Chapter 13 bankruptcy, they typically receive the protection of the automatic stay,
which is a court order that prohibits further collection efforts from creditors.
That means the calls stop and most legal action (like foreclosure, repossession, lawsuits or wage garnishment) is ceased.

http://www.totalbankruptcy.com/chapter-13/overview.aspx


So appraisals on the edge of qualifying value could determine if foreclosure proceedings
would stop. "You ruined my deal" "Your appraisal got me thrown out of my house you
SOB."
 
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