Not only is this not a frivolous question for the reviewer to ask but it indicates that the original appraisal report failed to adequately convey the point that the beachfront location is the single dominant attribute of the subject property and that it's market segment is limited to other *beachfront* homes in this location and in other nearby beachfront neighborhoods.
It doesn't matter what the homes on the inland side of the street or the rest of the neighborhood are selling for because none of those properties are comparables to the subject. Nor does it matter what the other areas of this neighborhood are selling for because they're even more disconnected from the subject's market segment.
If the structure is old/small for the area then there's a *distinct* possibility that it's an underimprovement for the site and also a possibility that the structure has no contributory value to the site and that it might be marketed for land value. A land sale analysis - using actual land sales data - is definitely in order in this scenario if for no other reason than to address the HBU issue. It is highly likely that some of those land sales will have old/small homes onsite that are an underimprovement for the site and have no contributory value. In fact, if you have similar homes among your comparables some of those listings may include a "value is in the land" or "sold for land value" comment in them.
The overwhelming majority of the new SFR construction appraisals I've performed on beachfront parcels in the last 20 years have had older homes onsite that - physical condition notwithstanding - had no contributory value to the site and were therefore demolished to make way for bigger and better.
So yeah, if a lender is asking whether or not you're signing off on what amounts to a 90% land loan that is not a frivolous question.
George gave the best answer....like George said about including the site/land analysis would have probably staid off the request. So to be even
more proactive to prevent the inevitable future stip, you should in the neighborhood section have an
extensive description(assuming 1004 format)
See Addendum in great detail describing the neighborhood. This is
setting up the Client/UW/checklist charlie for the
disappointing news they were going to be securing a loan on mostly land and the AMC checklist job security by denying them justification for the important job they think the have of Aggravating you with Stips.
i started doing the following quite awhile back, because I too along with all of you am suffering from the checklist charlie stipper & UW's.
We all are suffering from the Continuous Evolutionary process of USPAP a living document & the Stuck in Time FNMA series Report Formats.
Here is my page line up for all FNMA Series Report Format
I am doing this so they don't have to hunt for all of the below and resulting in them
having to hunt For Page one of the FNMA Series Report
This is what they see first before they ever get to Page one of the FNMA Series
This comes 1st & 2nd Page
1. Copy of State License if required
2. Copy of E&O if Required
Pg 3 - USPAP Addendum Very important to be 1st, 2nd or third page page of Report
All other addendum & exhibits i.e
not necessarily in this order But
always before page one of a FNMA Series Report
Flood Map, Aerials,
1004MC,
Supplemental Statistics
Subject photos,
Subject Interior Photos
comp photo pages
subject/comp Location Map
General comments addendum
Highest & Best Use analysis (if needed due to space limitations on URAR
Site Evaluation/value determination
Detailed Cost Approach(if needed)
Tax Card subject & comps
and Finally
Page one of the FNMA Series Report