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Can you use the subject as a comp?

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Sophomore Member
Jan 17, 2002
Professional Status
Licensed Appraiser
Appraisal for a refi; subject sold within past 12 months; verified details of sale; used as Comp #1 - no adjustments and no increase in value over the sale price.

Underwiter calls and says I can't use subject as comp. This came as suprise to me as I've done it on several occasions, including a couple of very high-end homes. No one has ever complained before. In fact, one reviewer called just to complement the way I handled some post-sale improvements to the subject. I may have been a bit testy :evil: by the time I asked the underwriter to refer to the section of USPAP or FNMA guidelines prohibiting the use of the best comp available.

I guess I should have double-checked the texts before asking such a question :oops: , but I still can't find any rule / law / suggestion against using the best comp available, even if it is the subject itself.

Is there such a rule? Has anyone had similar questions from the UW? Suggestions?

Bemis Pownall

Fannie Mae, Appraisal and Review Appraisal Guidelines

Section 406.03

Sales Comparison Approach

Second Paragraph
Subtopic A. Next to last sentence....
"In addition, the appraiser may use the subject property as a forth comparable sale or as supporting data if the property previously was sold (and closed or settled)

Me, I mention it in final recon. "consideration was given subject's recent sale, x/01 $zzz,zzz".

Hope that helps

Mountain Man

Elite Member
Jan 15, 2002
Professional Status
Certified General Appraiser
There is a recent post on the same subject from about a month ago. It is okay to use the subject sale as a comp for extra support. But the problem comes when a value increase is expected. You know how every owner got a great deal and they just know it is worth more. :roll:
But like Bemis, I just state the last sale and say it was given consideration.
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