FHA Reconsideration Of Value

[Deleted member 80407]

I have been receiving reconsideration request for FHA reports. A wondering mine inquires if they should be coming from the DE Underwriter?

 

[Deleted member 80407]

I have been receiving reconsideration request for FHA reports. A wondering mine inquires if they should be coming from the DE Underwriter?

For those that viewed my response and are not sure of the answer! Here is what was sent to be by FHA:

FAQ: What is the procedure for increasing a value determination of an FHA appraisal?

The lender may request reconsideration of the appraised value from the appraiser when new market data exists that may not have been reflected in the appraisal. The lender should provide additional comparables or sales to support the reconsideration request.

However, effective for case numbers assigned on or after February 15, 2010, no members of a lender’s loan production staff or any person who is compensated on a commission basis upon the successful completion of a loan or reports, ultimately, to any officer of the lender not independent of the loan production staff and process, shall have substantive communications with an appraiser relating to or having an impact on valuation, including ordering or managing an appraisal assignment.

The Direct Endorsement (DE) Underwriter who has responsibility for the quality of the appraisal report is allowed to request clarifications and discuss with the appraiser components of the appraisal that influence its quality.

ML 09-28
http://portal.HUD.gov/hudportal/HUD?src=/program_offices/administration/hudclips/letters/mortgagee

Handbook 4155.2 4.1
Handbook 4150.2 4-9
http://portal.HUD.gov/hudportal/HUD?src=/program_offices/administration/hudclips/handbooks/hsgh

 

[Meandering]

So did they send you "better" comps, or just more expensive ones?

 

[Deleted member 80407]

So did they send you "better" comps, or just more expensive ones?

Of course, better ones!!!! **^^%%$$@@#^^ (see below)


FIRST CONSIDERATION: 4 bedroom house.

Even though the house has a room with a closet on the first floor, it was not counted as a bedroom due to the lack of a full bath on the first level.


SECOND CONSIDERATION: All new flooring as of April 2015:

I am wondering if the author of this reconsideration inspected the subject house or just read the verbiage on the listing sheet.
It is my call as an appraiser to state what is new and what is not. Furthermore, the verbiage on the listing sheet read " **ALL NEW FLOORING, CARPET AND PAINT** with no mention of tile flooring.


THIRD CONSIDERATION: Reconcile 3 sales & 1 listing.

ARMLS# .......
The sale occurred after the effective date of the report. Furthermore, the sale price of this property was known by me prior to closing. If the author of this reconsideration of value would have read the entire report, they would have seen this property was presented as Listing Comp 1: It must be noted that this listing has 1 full BA down and 2 full up. Therefore, the additional room on the first level was considered a bedroom. Furthermore, the indicated adjusted value of this listing (at time of effective date of this report), supports my concluded value.


ARMLS# ........
: Again, if the author of this reconsideration of value would have read the entire report, they would have seen this property was presented as Comp 2. The indicated adjusted value was slightly above my opinion of value. It must be noted that this listing has 1 full BA down and 2 full up. Therefore, the additional room on the first level was considered a bedroom. For this reason, I did not award an opinion of value matching the indicated adjusted value of this comp.


ARMLS# .......
: I am wondering who chooses the comparable's, the appraiser or the concerned party? This sale is about 400 square feet smaller than the subject and was selling above all of the sales presented. As an appraiser with 22 years experience, I choose the most comparable properties and not the highest non-comparable sales. If the author of this reconsideration of value would have read the entire report and understood the report they would have observed the following:

* Sales 2 thru 5 were of model matches with county reporting the same square footage (2,221 sq ft) as the subject house.
* The differential in GLA between sale 1 & the subject was less than 50 feet.
* The differential in GLA between the subject and sale 6 was just over 200 feet.

ARMLS# .......
: Again, I am wondering who chooses the comparable's, the appraiser or the concerned party? This listing could have been considered, however, I did not think it had enough exposure time to present (41 days as of the effective date of this report).

After reconciling the above supplied data (it must be noted than 2 of the 4 supplied sales/listings were already in my report), I stand on my opinion of value as of 4/30/3015.

 

[Meandering]

Well, alrighty then.

They gave you 4, you already used two of the 4 they sent, you did not think the other two were better comparables than what you had already used.........seems like you've answered their question nicely.
.

 

[Mike Kennedy]

Attitude determines Altitude. As long as ROV is permitted to exist, replying professionally absent the emboldened personal observation statements (if they were in fact included in the ROV response) is the way to go. Fact, they are legally allowed to ask; a professional response from the Appraiser is appropriate.

 

[Deleted member 80407]

Attitude determines Altitude. As long as ROV is permitted to exist, replying professionally absent the emboldened personal observation statements (if they were in fact included in the ROV response) is the way to go. Fact, they are legally allowed to ask; a professional response from the Appraiser is appropriate.

Mike, you may missed my point. I know they have a right to ask. However my point is..................."WHO IS PERMITTED TO ASK". My above 2nd post was received by HUD. The verbiage suggests only the bank's underwriter has the right to ask if they think there is an issue with value.