Unreasonable revisions

[Andee]

I know there was a thread in June regarding ROV with Lenders using CU to send over 3 comps for consideration. Is there anything that says there is an "unreasonable" amount of comps to consider? I know the Lender/Underwriter didn't bother to review the list of 23 comps that were sent over that came from a local RE Agent, which included comps used in the report. I sent a nastygram to the AMC advising basically "I will not get to this within 24 hours because my priority is the two reports that I am currently working on and it will take longer than 24 hours to review 23 comps, or have the Lender narrow down to what they consider the MOST likely comparable properties". I wouldn't mind if it was 3 but this is just a joke, oh and of course, this was inspected almost a month ago and according to the date range on the information sent, they didn't bother to take into consideration some of those comps wouldn't have applied as "Sold Comps".

 

[Terrel L. Shields]

Tell them No. They need to explain why the comps they submit are "superior"...if they can't I would not do anything.

 

[Meandering]

https://singlefamily.fanniemae.com/media/20576/display

Q25. How should lenders use CU findings to inform conversations with appraisers?Fannie Mae expects lenders to use human due diligence in combination with the CU findings, and will actively follow up with lenders who ask appraisers to change their reports based on CU findings without any further due diligence by the lender.Fannie Mae encourages lenders to carefully review the appraisal report, including all commentary, before seeking clarification from the appraiser. Taking messages or alternative sales at face value and simply asking your appraiser to address them is neither effective nor efficient. After completing a thorough review, lenders should be able to have constructive dialogue with appraisers if needed to resolve specific appraisal questions or concerns. Specific information from CU may be shared with an appraisal management company (AMC) or appraiser, with appropriate context, but the legal terms and conditions for CU prohibit: using the licensed application in a manner that interferes with the independent judgment of an appraiser; providing access to CU’s web-based user interface to third parties (including AMCs and appraisers); and providing copies or displays of Fannie Mae reports that contain CU findings to AMCs and appraisers. (Note that AMCs who are registered to use UCDP as Lender Agents will see the CU risk score, flags, and messages available through UCDP.

https://singlefamily.fanniemae.com/media/15271/display

Fannie Mae does not instruct or suggest to lenders that they ask the appraiser to address all or any of the 20 comparables that are provided by CU for most appraisals. It is also not Fannie Mae’s expectation that appraisals should contain only CU’s top-ranked comparable sales. In the majority of cases, there may be no material difference between comparable sales utilized by the appraiser and those identified by CU. Before asking the appraiser to consider any alternative sales, it is imperative that the lender analyze the relevance of the sale and determine if the use of such sale would result in any material change to the appraisal report. If the lender determines that there would be no material change, then they should not ask the appraiser to make revisions. Fannie Mae expects CU to enable lenders to accept appraisals “as is” with greater confidence.

 

[Meandering]

But really what you want is this

12 CFR § 1026.42 - Valuation independence.

www.law.cornell.edu

But nobody really enforces it.

.

 

[Meandering]

However, it is a handy reference to use to call the local BOR office and file a complaint.

 

[Michigan CG]

the list of 23 comps

Why would you work for garbage clients like this? In this market where appraisers are in extreme shortage?

You need a better business model. Tell your client the following. BTW, I used this once about five years ago as I got rid of garbage clients.

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FNMA ML 2015-02 clearly states: "Before asking the appraiser to consider any alternative sales, it is imperative that the lender analyze the relevance of the sale and determine if the use of such sale would result in any material change to the appraisal report". Therefore, if the appraiser is requested to review any other sales after the effective date, the appraiser will only accept the order to review the sale(s) if the following two (2) conditions are met:

1) A summary submitted from the lender/client or AMC showing their analysis supporting the premise that their sales are superior to that of the sales used in this report, with the understanding that closer proximity or more recent date of the sale does not mean it is a better indicator of value, as clarified above.

2) The lender/client must agree to pay a fee of $50* per sale reviewed, plus a minimal $75* inspection trip fee, which may be greater depending on mileage and drive time incurred.

*These fees will be waived and the report will be revised to include additional sales IF they are found by the appraiser to be superior to the sales used in this report *and* their use results in a material change to the appraisal report.

https://www.fanniemae.com/content/announcement/ll1502.pdf

 

[J Grant]

I know there was a thread in June regarding ROV with Lenders using CU to send over 3 comps for consideration. Is there anything that says there is an "unreasonable" amount of comps to consider? I know the Lender/Underwriter didn't bother to review the list of 23 comps that were sent over that came from a local RE Agent, which included comps used in the report. I sent a nastygram to the AMC advising basically "I will not get to this within 24 hours because my priority is the two reports that I am currently working on and it will take longer than 24 hours to review 23 comps, or have the Lender narrow down to what they consider the MOST likely comparable properties". I wouldn't mind if it was 3 but this is just a joke, oh and of course, this was inspected almost a month ago and according to the date range on the information sent, they didn't bother to take into consideration some of those comps wouldn't have applied as "Sold Comps".

In order to stand up to a client, you have to be willing to lose that client. I've "lost" a share of them over the years when they pushed too far../wanted something not kosher ..but I always found replacements, usually for the better. This sounds like a scumbag client, or at least is behaving like one.

So you need to set a boundary, and either they will abide by it or not and if they continue to use you or not their call,...(likely they will )

Write them a second follow up that it you did a quick scan of the 23 sales and many of them do not fit the criteria of comps, and that it is normal practice for clients to limit a number of sales in an ROV to a select amount that might actually be comps , and custom is for clients to send 3 -4 in an ROV, so tell your client to please review them and re send the request with at max 4 sales. If they want you to review and analyze all 23 sales, you would do it at a cost of $X per sale . Thank you, name THE END.

 

[J Grant]

PS, do not refer to sales sent to you as COMPS, even if the sender calls them that. They are SALES, till you review them and decide if they are comps or not.

 

[Carnivore]

This is a good a place as any to post this Link to the Mythical One Mile.

You gotta love FNMA, they know that there is a lot of BS being spread around by Lenders and their AMC Surrogates. It gets worse because a little Knowledge in the hands of a Checker Dude really causes a lot of Delays. I have one Checker Dude that Harasses me by claiming I am inconsistent from one Report to another. He simply is incapable of understanding that All Assignments are actually different.

"It’s a longstanding myth that comparable sales used in an appraisal report must be within one mile of the subject property. That myth has now been vanquished by the Noble Appraiser, who is spreading the word that the best comparables are chosen using facts and data.

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Hopefully they will come out with another more detailed explanation of the Neighborhood High Low Predominate , That is a another Mythical limitation.

Its wrong for them to send over a huge list of Sale. They do it because its easy and its meant to punish you! We know the RE Broker and the LO are advocates!

I have had two ROV's this year. The last one I destroyed not only with a written description of the so called Comparable, I also included a 6 Pix addendum of each sale using the front Exterior and five Interior photos. The good news on Both ROV's is they did just send over four sale. I guess that's a win.

This has be going on forever and it will continue. Your best defense is try to anticipate it and deal with it on the Front End. Its much more efficient if you do.

 

[DTB]

I used the passive/aggressive method with success.

I received this email, in error apparently, as it includes a list of 23 properties for me to consider. If you would like me to consider some properties, please vett them and send over 3 max with your analysis as to why they are superior to the comps provided in the appraisal report.