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Revisions

Two points I would make:
1. “Comps not used” is a false term. Only you, the appraiser , can define a comp. A homeowner, client, AMC can question “sales not used”. By appraisal practice, if you determine a sale is not a comp, then you won’t use it. This is not nit-picking. It is the crux of what we do. If so asked, I tell clients why I did not use these (up to 6) sales as comps.

2. An AMC telling you to comment on “why you didn’t use comps from another appraiser” will prompt me to ask if “this is an ROV? If so, please provide it in the proper form.” By Fannie guidelines, it has to originate from the borrower. If they say, “no, we just have two appraisers using different comps and we want to know why.” The professional response is, “I don’t comment on another appraiser’s work unless I am doing a review assignment.” That is a way of telling them, that is a you problem not a me problem. You are paid to figure it out!
 
It's been my experience that, in the case of HV loans where two appraisals are procured, that the lender is primarily concerned with what the 'real' value of the subject is. I've always been intrigued at how differently two credentialed appraisers can report an appraisal on the exact same property with essentially the same effective date. Had one yesterday where one appraiser said the home had a basement and the other said it didn't (it clearly did). One measured the home at 4,400' and the other at just over 5,000'. One showed a site size of 2.97 acres and the other showed 2.62 acres. And these were theoretically developed by two credentialed appraisers. It's almost like they were appraising two separate properties.
One of these is likely valid, the other slop. Instead of pushing other valuation methods, the industry should focus on burning the chaff.
 
Two points I would make:
1. “Comps not used” is a false term. Only you, the appraiser , can define a comp. A homeowner, client, AMC can question “sales not used”. By appraisal practice, if you determine a sale is not a comp, then you won’t use it. This is not nit-picking. It is the crux of what we do. If so asked, I tell clients why I did not use these (up to 6) sales as comps.

2. An AMC telling you to comment on “why you didn’t use comps from another appraiser” will prompt me to ask if “this is an ROV? If so, please provide it in the proper form.” By Fannie guidelines, it has to originate from the borrower. If they say, “no, we just have two appraisers using different comps and we want to know why.” The professional response is, “I don’t comment on another appraiser’s work unless I am doing a review assignment.” That is a way of telling them, that is a you problem not a me problem. You are paid to figure it out!
1. There is no definition of what a comparble is. Also, there can be comps in the area that i didn't use. i am not required to use all the comps. I think the minimum number of comps is 3.

2. They said its not an ROV but this is part of the QC and i should comment, becaues the reviewer doesn't have data, like access to MLS. Bunch of BS.
 
If the range of adjusted sale prices is more than 100K it's wrong.
 
Depends % difference in the range, not the dollar amount. In some appraisals, a $100k difference is negligible.
Agree. The adjusted range should be roughly 5% to 7%. That said, in this stagnant market, easier said than done.

In the OP's case, if the original appraisal meets all components of bracketing, equality, and similarity in the subject's immediate neighborhood along with recent sales, I wouldn't acquiesce to the client's request. It's not the OP's job to line up his appraisal with somebody else's to "make it work".

Conversely, if the OP's report only has one sale in the immediate neighborhood and all the others are over a mile away. Or, all the comparables are four bedrooms and the subject is only three.... that would justify an explanation or an ROV.

I would wager the same request is being made of the other appraiser...." why aren't you using these sales that the OP appraiser is using?"

The AMC wants these two appraisals to come together to package up with a pretty bow to make the loan.

The AMC's have been running roughshod for so long that they feel safe from any repercussions.
 
I got a revision request from NAN asking me to comment why I didn’t use certain comps. 3 comps and 3 rental comps. They said that they had ordered two reports and the other appraiser had used different comps. I told them that I am not required to do that, and it might be a violation of confidentiality for them to share contents of the other report with me. Am I required to comps not used?

That's 100% not a "revision"
 
1. There is no definition of what a comparble is. Also, there can be comps in the area that i didn't use. i am not required to use all the comps. I think the minimum number of comps is 3.

2. They said its not an ROV but this is part of the QC and i should comment, becaues the reviewer doesn't have data, like access to MLS. Bunch of BS.
1. True! There is no formal definition. YOU and only YOU as the appraiser make that definition. Are there more than three comps? Certainly can be. YOU decide which three are the most reliable. Can you use more than three? Sure! You decide if using more will bolster your opinion.

2. Their QC is their concern, not yours. Their lack of data is their concern, not yours. Your concern is providing a well supported appraisal. If they have a problem with your appraisal, they need to specify EXACTLY what their concern is and address it. You are under no obligation or even, arguably, allowed to “help them out” with someone else’s appraisal.
 
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