I'm one year in to being certified here in the middle Tennessee area and I'm starting to see this more and more as lenders come into the market. I have spoken with my old supervisor about this but I'm curious what other people with years of experience comment/reply to revision requests like these:
first revision request:
Please comment on the value estimate being lower than the sale price. Please comment as to how the quality of construction adjustments were derived. Please comment as to why no adjustments were applied for differences in condition. Sales #2 & #3 were over one mile distant and located in a different town than the subject. Please provide market data which demonstrates the locations are similar to the subject with no adjustments warranted.
second revision request:
Please further discuss your analysis of the purchase agreement. Given that this represents a meeting-of-the-mind of buyer and seller for the subject's characteristics, how was this factored in the opinion of subject value. Per MLS comments multiple offers were received, please advise if the appraiser was able to confirm multiple offers 3.) please expand commentary on your reconciliation to value.
Now all of these things/adjustments are summarized in my supplemental addendum (which is almost two full pages of commentary). I have never seen such ridiculous revision requests and it seems as if they want the report to be specific as opposed to a summary report and put all legal onus on the appraiser. I replied with a polite decline and a suggestion that if these revisions were needed the fee would need to be increased and reminded them about the summary requirements of USPAP. Anyone else dealing with this bs? They also requested comps that have no quality adjustments, and it feels like they're pushing a value.
Oh and I've had multiple lenders/underwriters send me specific comps and a request to comment as to why these comps were not considered. This seems to be a violation of FIRREA to me.
I think its best to learn from multiple old-heads in the business and fight the good fight against underwriters and lenders together!
It may be a case of not thoroughly addressing what the underwriter is looking for. At the risk of sounding pretentious, over time you find it is an art form.
Sales price vs. OOV- Technically, we don’t have to address this. However, what we
need to do and what we
should do for doing a thorough job can be 2 different things. I always address it the best of my ability. The best way is to derive from the listing broker where they came up with the asking price and how the “meeting of the minds” came to be…..all the while not looking like you are asking, “what the hell were they thinking?!” Many times I say, “there were multiple offers that drove up the offers but market data indicates that x is the true market value.” This answers the questions without looking like you are “justifying“going under SP. It also shows that you considered what buyers and sellers are thinking.
Regarding commenting on adjustments, we need to
summarize “ what we did. All too often, appraisers state, “comps 1 and 2 adjusted for quality”. Well, duh! We see that! Instead, say, “upon examining the exterior and photos and comments in the MLS listing and conversations with the listing brokers, comps 1 and 2 are adjusted for being superior in quality. Support for the adjustment is derived from comparison with comp 3, which is similar to the subject property.” Boom! You answered the question before it became a request for a revision!
Same with going outside of town, which always begs questions. You went outside for a reason. Explain why. No location adjustment? Explain that the subject and comparable town is similar in appeal and market values. If you explain thoroughly, they won’t ask for market analysis. They will assume you already did it.
Them asking to “expand commentary on your reconciliation of value” means just that,
you didn’t sufficiently explain how you arrived at the value! In the Sales comparison comments, you summarize not just the adjustments but how you got there. Many appraisers say nothing and put down the number or just end with, “comp 1 weighted most” or my favorite, “all comps considered”. Explain the strengths and weaknesses of each comp,
why a certain comp is (or isn’t) weighted most. Many times I also explain that I weighed the actual sales prices to determine a supportable range. You put thought into your number. Explain it!
Another thing that jumped out at me was your “supplemental addendum”. Do you lump all comments onto one addendum and the underwriter has to fish for what they are looking for? Make sure your comments have a title, such as “Comments on Sales Comparison Approach” and “Comments on Final Reconciliation “, etc.
Hope this helps.