• Welcome to AppraisersForum.com, the premier online  community for the discussion of real estate appraisal. Register a free account to be able to post and unlock additional forums and features.

More On Free Comp Checks

How often do you actually get an appraisal order if they want a free comp check first and you won&#3

  • Never

    Votes: 207 30.8%
  • Maybe 1 out of 100 calls like that

    Votes: 107 15.9%
  • About 1 out of 50 calls like that

    Votes: 94 14.0%
  • About 1 out of 10 calls like that

    Votes: 117 17.4%
  • About 1 out of 5 calls like that

    Votes: 94 14.0%
  • I ALWAYS talk them into the order without giving a value first

    Votes: 53 7.9%

  • Total voters
    671
Status
Not open for further replies.
There's nothing "phased" about this assignment.
There are two different assignments, two different purposes, two different intended users, two different scopes of work, two different effective dates, and a host of different EAs.

What surprises me is this: Many who rightfully point-out that changing the name of a client on a report when nothing else changes constitutes a new and different assignment will argue that a desk-top vs. a 1004 is not a different assignment. I find no logic to the reasoning and no citation (as in USPAP, Fannie, court cases, etc) to support it.:shrug: Even the state regulatory agencies, such as Oregon (which is one of the better, IMO) states what is required if one does complete a desktop. So, there is no fancy footwork required here to dance around USPAP; this dance is done within and to the music of USPAP, like it or not.

For some, it has been pre-determined that anyone who does a desktop appraisal does not have the ethical wherewithal to stand up to demanding B/C clients. Such a generalization reflects a narrow viewpoint, and I find it sad. I conclude two things from such views:
A. Such a person hasn't met an ethical appraiser who can stand-up to B/C clients.
B. Such a person fears he may not be able to stand-up to B/C clients if pressured.


Others have brought into the discussion something I really didn't think about, and that is because I've had my license since 1992 at the beginning of mandatory licensing: A desktop appraisal was something that was routinely done prior to licensing by many appraisers who, I would argue, were (and remain) ethical and upstanding. They didn't fall victim to some "dark-side" of mortgage lending pressure. But, again, the narrow view is that it is impossible for such a person to do so today. Perhaps Joyce and TC should be considered heroes for being able to navigate such treacherous waters and maintain their ethics; apparently, according to some, that ability no longer exists.


The best reason I've ever heard against the desktop appraisal is the return on investment argument. This is one I agree with. When it is busy, we don't have the time to do these, and we don't. When it is slow, if we have the time and the inclination to do them, we do. If it takes more than 10-minutes to complete the valuation from the desk, I'll usually stop and tell the client a mortgage appraisal is needed; no credible desktop valuation is possible. Ditto for 2-4's or vacant land. Ditto for complex assignments. But, I work in a urban/suburban market, so data is plentiful and most value questions are not the complicated.

My comments should not be construed as saying that there is no such thing as comp check abuse. I am not saying this, and agree 100% with those who have this concern.
Some appraisers use a "comp check" as a way to bid on a job. This is wrong. I regularly review appraisals for clients where the only reason I can see that the particular value was concluded was that it achieved some pre-determined requirement.
And, there is a danger that the honest appraiser, unwittingly, may fall into a pressure-trap by a client if a desktop appraisal is completed and the mortgage finance appraisal is less than the first assignment; that scenario is real. But, my horse isn't so high that because I fear this, I will make a general statement,
"No one has the ethical ability or moral backbone to withstand such pressure. Therefore, if you do a desktop, you must be doing it because you want to be unethical! You are a disgrace!"


As this topic goes, I think this was one of the better discussions, so I am encouraged.


Lastly, Mark R.-
I treat a desktop the same as I do any other appraisal, with complete record retention, etc. etc. I also require the client to order the service on one of my pre-printed order forms which outlines the assignment engagement and what it can and cannot be used for. I do not provide a written reply; it is an oral report, with the summary retained in the work file. Pam's observation of the desktop + AVM showing up as lending valuation has merit. Give your valuation as a verbal, and you make it difficult for anyone to use your results for fraudulent purposes.
In fact, here's a bit of my general experience. It isn't that easy to get a desktop valuation from me. You have to:
A. Call, fax or email the office.
B. You have to hear from the office that such requests need to be made on our engagement form.
C. You have to then get our engagement form (from us) and fill it out and re-send it to us. In the meantime, you are told that-
(i) All orders are paid prior to or at inspection time.
D. You may have to wait a day (sometimes two) to get your answer.
E. When you get your answer, it is verbal and expressed as a range.

How many crooked loan agents are going to go through this process to get a value bid when others will just tell them in 20-minutes what the value is that they can hit with no, "fuss or muss"? Not many, for a fact. Long term existing (or potential) clients will go through this process because their intention is not to achieve something that isn't legitimate. It is to obtain a restricted-use valuation so they can determine if it makes sense (at the begining) to start the loan application and submission process. My point being is that if you set of the procedure where the client (or potential client) has to invest some of their time into the process as well as making it clear that all orders are to be paid up-front regardless of what the valuation result is of the mortgage finance lending appraisal, you are not going to have to deal with the fraudsters who are out there trying to shop for a value. For some, this simple fact may be too far removed from the perch they've placed themselves on when judging others, that they've never considered it; but, this is consistent with "narrow mindedness".:new_smile-l:

Good luck!
 
Last edited:
If I were a lender and was being gouged and paying for appraisals that I could not use on a regular basis I would probably be clamoring for full disclosure and valuation machines. If other states are an indication, 50% of the appraisers in New Mexico will lose their jobs if we go full disclosure.

I have several issues with your position but will limit myself to these:

1. Lenders can use your report regardless of the value. They use it to make a decision whether or not to lend their money.

2. AVMs are not reliable even in full disclosure states and I think more and more lenders are realizing this.

3. Your signature "The Loan Appraiser" insinuates advocacy. You may want to reconsider that.
 
How many crooked loan agents are going to go through this process to get a value bid when others will just tell them in 20-minutes what the value is that they can hit with no, "fuss or muss"?

Well said, Dennis (your entire post). However, I feel that this quoted statement is the crux of the matter. It is why I posted my incredulity as to Mark and others who posted that they do these routinely (maybe they operate in different markets and something there is different than in Joplin). I have offered similar service to yours for many years (coincidentally, I've been licensed for about the same length of time). In the last five years, I cannot remember a single taker for the service of desktop appraisal. Every single MB I can remember talking to who started out wanting a comp check really wanted pre-determined value. In my experience, I either turn these into a legitimate order or I lose them altogether. Over the last few years, I have not met a single mortgage broker who wanted the desktop product.
 
Good morning Otis,

The great comp search debate generally comes down to “how can you work for free”. I can see where this would be a problem to you, as people who provide a greater service will probably end up taking business from those that do not.

In your case and for New Mexico I believe it goes farther. Right now in New Mexico we are a non-disclosure state. We have a very active appraisal community that fairs pretty well and at present is not being inundated by valuation machines.
Actually, I think you'll find that we're a "LIMITED DISCLOSURE" state. That was changed a few years ago - guess you kind of missed that part along the way while you were doing your "comp checks" as a service.
I recall from your past posts that you have bragged about gouging lenders who ask for changes to the appraisal.
Would you show me one of my posts where I "BRAG". I provide a service, appraisal service, and when the report is completed and delivered, the service has been completed. As such, when they come back and back and back and back for more and more stips, that really don't have a thing to do with my work product or the appraisal itself, then YES I will charge for additional services required that were not part of the original scope of work or assignment request. But I don't "gouge" anyone for my services. They're far too many here in town and this state that actually "gouge" clients. But not me. I have a good varied supply of clients who like my work - it reflects the facts and the market without "comp checking".
If I were a lender and was being gouged and paying for appraisals that I could not use on a regular basis I would probably be clamoring for full disclosure and valuation machines. If other states are an indication, 50% of the appraisers in New Mexico will lose their jobs if we go full disclosure.
I think you're going to see a rather large "clearing of the flocks" in the next few years, but not for what for the reasons you're indicating, IMHO.
We are a service industry. We have the ability to provide a superior service then that of a machine.
Yes we are and yes we do. We reflect the facts about the property and the market. A machine cannot do that sitting in cyberspace. That is the biggest difference between me (an appraiser) and the machine. I reflect the facts. And I don't have to do that by giving them a minimum guarantee by comp checking them into an order.
I suggest that you lighten up on people who wish to do so, let us who wish to do so, improve the industry before it is too late for all of us. You might even consider getting on board. Remember work ethics go beyond what is mentioned in USPAP.

This will be my last post on the subject, I have enjoyed talking with you.
See ya at the next rodeo.

The Loan Appraiser
"Do so"? "Do so" what? Work for free? Go ahead, just be sure to add all those free work products into your file system for 5 years. Just in the case the board should decide to investigate a complaint whereby you gave someone a "free appraisal" in that comp check scenario. It wouldn't take too many "comp checkers" to be called to say the property is worth between $zzz,k and $YYY,k and they've made the loan for free of charge of an appraisal.

BTW, USPAP is the minimum requirements and ETHICS is mentioned right at the start. Considering that I've been appraising longer than you've thought about it, I'd say my "work ethics" are pretty well established and known. And FWIW, USPAP does not mention "work ethics", it mentions ETHICS!
 
The real test is if you provide a comp check, get the order, and the appraised value is lower than your comp check, what happens? If the lender accepts it with a smile, then there was no pre-determined value. If they call up howling and demanding refunds then they thought you promised them a guaranteed minimum value.

Like many things it is all in the presentation.
 
If they call up howling and demanding refunds then they thought you promised them a guaranteed minimum value.

Chuck, I don't think it is the responsibility of the appraiser to make sure a LO doesn't just hear what they want to hear. That is a perception problem on their part, if they were not told what they thought they heard.
 
That much is true. A statement such as homes in that neighborhood are selling from $155,000 to $205,000 is instantly misconstrued as all houses are selling for at least $205,000.

That is exactly my point. If you give them any help at all, it comes back to bite you on the butt. The bottom line is that these LO's want a guaranteed value before they order an appraisal. I refuse to do that. I'll bet I have lost three orders this week that way. One was sweet. Two blocks away, cash COD. Doesn't get much better. But I had to guarantee $260,000. There were comps to support it if I used the three highest comps. But I don't know if those comps are applicable until I inspect.

The LO actually got snippy with me. Big mistake. I told him to STFU and I was reporting him for mortgage fraud. Not sure who to report to. We have a pretty tough predatory lending law, but I have yet to see a single person go to court over it.
 
Report that and anything else you find 'not right' at:

www.MortgageFraudWatchList.org

Please do report ALL those comp check faxes, emails, phone calls.

Get the address of the subject property and report it.

If nothing is wrong, nothing wrong will be found with the review/audit of that loan file. If the property was appraised with 'cherry picked sales' that ignored the most relevant sales, the review/audit will find that. Those that deal in the mortgage broker comp check games typically have numerous items in the loan file, not just the 'inflated' appraisal, that are found 'wrong'.

Simply: The mortgage brokers that insist on 'comp check appraisals' are typically finding, and only using, the appraisers that WILL inflate the value and/or ignore negative conditions - AND typically have other items involving the qualifications of the borrower that are 'not quite right'. The names of the appraisers involved with these MBs/LOs that have higher default rates are being matched up and both will eventually get nailed.

The mortgage fraud investigators ARE looking more closely at the relationships of MBs/LOs and the appraisers they use most often. That is a fact told to me by many.

We have a MAJOR problem in the residential mortgage lending world that does have a direct relationship to the appraisers used in the residential mortgage lending world. USPAP was / is written for ALL appraising applications. The vast majority of the problems and the frauds are in residential appraising for residential mortgage lending. THAT is where we NEED a separate section of USPAP specifically written for the residential mortgage lending appraisals. This is where we NEED a very specific RULE regarding the comp check issue - as in: "THERE IS NO ACCEPTABLE WAY TO DO A 'COMP CHECK' FOR A RESIDENTIAL MORTGAGE LENDER / BROKER. THERE IS NO USPAP COMPLIANT ORAL REPORT FOR ANY RESIDENTIAL MORTGAGE LENDER / BROKER. AN APPRAISER CAN DO A DESKTOP APPRAISAL FOR A RESIDENTIAL MORTGAGE LENDER / BROKER, BUT MUST COMPLETE AND DELIVER IT ON A SPECIFIC DESKTOP APPRAISAL FORM FOR THIS PURPOSE. ALL ORDERS FOR ANY TYPE OF APPRAISAL WHERE THE CLIENT IS A RESIDENTIAL LENDER / MORTGAGE BROKER MUST BE REPORTED TO THE ASC DATABASE STATING THE ADDRESS OF THE SUBJECT PROPERTY AND THE NAME OF THE PERSON, COMPANY, AND THEIR CONTACT INFORMATION."

No, I don't like any of this. But, the residential mortgage world along with the residential mortgage appraisal world are beyond out of control now and I don't know how else to fix it.

NO GOVERNMENT BAILOUTS!!!
 
Last edited:
Denis,

From what I have been told by some (more than one) mortgage fraud investigator, there ARE oral appraisal reports documented by the MBs/LOs with the appraiser's name and contact information, license information, etc., written by the MB/LO and attached to one or more AVM, used to close mortgages. Appraisers ARE being held liable for these. If you deal in doing comp check desktop appraisals, it would be wise to deliver the desktop appraisal report to that 'client'. I don't know about you, but if my work is going to be used to close a loan, I ain't about to give it away for free! If you are delivering these appraisals via an oral report, that can come back to bite big time. That MB/LO can write down any value they want and claim you said it. VERY dangerous territory!!!!! At least I do believe YOU are one of the exceptionally rare ones that will have a USPAP compliant workfile to document what you did. This IS a very dangerous slippery slope where even with your USPAP compliant workfile and documentation, it will be difficult to prove who said what. If you are going to do this, I would suggest it would be best to deliver a written report with proof that it was delivered.
 
Actually, the debate usually comes down to "how can you violate USPAP rules against providing pre-determined value." At least, as far as I'm concerned.

If you can do what you're doing without doing that, then more power to you. From the discussions I've had with many mortgage brokers, I don't really believe you can.

My experince is similar to your's Steve adn I agree.

I dont see how they are profitable. I attempted to try and give the desktop for the small fee of $35.00 pre-paid. No Takers! I also prepared a preprinted SOW to include in a file to help be more efficient. I tossed it, because it no one wanted the desktop in the time it takes to do one, even if it was free!

So you comp check/desk top providers, please post an example your compliant report.
 
Status
Not open for further replies.
Find a Real Estate Appraiser - Enter Zip Code

Copyright © 2000-, AppraisersForum.com, All Rights Reserved
AppraisersForum.com is proudly hosted by the folks at
AppraiserSites.com
Back
Top