I recently completed an FHA assignment...with 6 comps (all with my own original photos). However when I was completing the assignment (the next day...after the effective/inspection date), I decided to add one additional closed sale to further bracket a subject feature. I therefore used an MLS photo for that additional comp.
Now lender is asking for an original photo.
My question is...as an appraiser who wants to further/better support their report...is there any flexibility on these MLS photos with FHA? With all the unknowns we run into during inspections...are we really expected to have pre-selected the perfect comps prior to inspection in order to meet this requirement every time?
I would think there needs to be some flexibility here with being able to use a single MLS photo for a comp added after the effective date here and there. It's not like I used MLS photos for all 7 comparables.
What are you doing? 7 comps? You do this every time? What's a matter with you? Why not upload the entire MLS then?
You dug that hole, go clean it up. O, and thanks for helping to dig a bigger hole for all of us too.
Three comparable sales is the recognized number of sales that are adequate to provide reasonable market evidence in a mortgage appraisal and most all appraisals. USPAP does not require any number of comparable sales, only that we provide market evidence. You are not doing yourself or anyone else any favors by giving your services away for free. It is a farce that your extra efforts will equate to higher earnings as our fees are set from the borrowers ability/willingness to pay, not from a relation between what we do and how much that ought to pay. Think about it. All you are doing is setting a higher standard for
everyone to follow and once it in fact becomes the standard, the gains in volume you think you are getting now will disappear and what you will be left with is less money per hour and, so will all of us.
USPAP says you must first identify the subject property. Then you must research and analyze the relevant market data. You are trying to save a few minutes/hours by not driving the comps out later and selecting them prior to identifying the subject. It is possible you are not in compliance with USPAP when you do this because, you might be trying to make your subject fit the comps instead of selecting your comps to fit the subject. As an attempt to fix this, maybe you are putting more comps in your report likely because, the comps you picked ended up not being the most physically, functionally and locationally similar. Sound about right? Or are you going to go back to the argument you are simply trying to provide a better product?
What I would suggest, is you charge more for starters and stop giving away services for free. Get a laptop, go find some wi-fi near your subject and search comps after you inspect the subject. It's nice, you might like it. Have a bit of lunch and work. Then put no more than the three best comps you can in the report and tell the client to pound sand when they ask for more, unless they agree to pay you MORE for the ADDITIONAL service BECAUSE, it is expensive to drive out new comps.
O and by the way, unless your comps are different from each other in only one aspect, bracketing features does not support the rate of an individual adjustment. Whoever came up with that should be tarred and feathered. Bracket the opinion of value with closed sale prices, hopefully yes. Bracket each and every feature, gfys. That last one aint even a matter of money, just a matter of being impossible more than 99% of the time.
The problem is, the low fee structure does not support the requirement to inspect the comparable sales from the street IF, we are also to select and use the comparable sales that are the MOST physically, functionally and locationally similar to the subject. To truly make this work, we have to do the comp search after we inspect the subject in most all cases. The alternative would be to select a bunch of possible comps and then pick the best three, but we all know that does not work all the time and it always requires more work on the front end.
The other alternative would be to remove the requirement to inspect the comparable sales from the street. This was a good requirement 30 years ago, but is mostly a moot exercise in today's digital world. Then, appraisers could select the best three comps from their desk after they get back from the inspection. Not everyone agrees with this, but there is no arguing the current requirement is expensive and the money to pay for it is not there.
