Nathan --
Anytime an appraiser gives an opinion of value, whether it is a range of value or a hard value, USPAP considers that to be an appraisal -- which means the appraiser is required to maintain a workfile.
So if a realtor can give my lender his opinion of value on my home "CMA" why can't an appraiser that has a realtor license do it to not acting as an appraiser?
Can an appraiser/broker take off their appraiser hat, and do a non USPAP compliant CMA? Does USPAP super glue the appraiser hat to our heads, so we can never take it off? Good question.
In a Certified Residential class 4 years ago, one of the instructors offered the opinion that if an appraiser responds to a comp request by supplying the sold data for a given neighborhood and time period
without interpreting the data, that does not constitute an appraisal -- and does not require maintaining a workfile. This instructor served on the Colorado BOREA for many years, and is considered one of the most knowledgeable appraisers in the state.
Yesterday an LO was referred by one of my best clients -- this was my response:
According to the public records, the subject property is a 1939 sf ranch, with a full unfinished basement and a 3 car garage. It was purchased from the builder in July 2006 for $313k.
The two most recent MLS comps on this street sold for $336k net in May, and $316k net in July. These are both sightly larger ranches, but otherwise seem to be comparable. There are other sales on the street, but they are larger two stories, and not comparable.
There are two under contract ranch homes in the sub area from a different builder, with list prices of $318k and $324k.
This is newer subdivision, and the data is very sketchy -- the LO ordered a COD appraisal, without any preconditions.
Comp checks are permitted by USPAP, if you treat them as an appraisal and maintain a workfile.
It is a business decision as to whether an appraiser chooses to offer them, and whether they will be offered for free.