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Verifying Financing And Comparable Sales Issue FHA

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Valueseeker

Junior Member
Joined
May 19, 2016
Professional Status
Certified Residential Appraiser
State
Massachusetts
Hello guys,

I got a notice from FHA that ""The data analysis presented in the Sales Comparison Approach is not complete and/or accurate and/or the adjustments are not resasonable and/or supported. "

The problem Im having is this.

I am stating in my report that the sources i am using are MLS/Deeds/Assessors.
When I go to verify this comp, it shows up as Conventional in MLS. Further, when I look at the mortgage docs on the registry of deeds, it shows up as a typical loan. (photo below is from MLS)

1.png

Now I am completely aware that MLS is data entered by realtors. I called the FHA help line and they said I should be using FHA connector to verify if any of the sales were FHA. Do any of you do this? I asked him to walk me through it and it appears I dont have access. He said you "may not have access but this sale does have FHA financing so your sources are wrong. Use the connector or use RealQuest.

I guess i have to sign up for realquest because my fear is that this will be a repeated occurance where some future appraisal may not have correct concessions. Any advice on this?

(This was not the sole issue that brought up the letter, there were a few issues but I want to rectify all of them and I just need tips on how you guys verify financing.


I also got in the same letter

"The prior sale or transfer history reported for the subject property and/or each of the comparable sales is not complete and/or inaccurate"
There is no analysis of the prior sale for comparable 3. Per public record, this was a transaction between two private parties. The appraiser must provide an analysis of the prior sale or transfer history of the subject property and comparable properties in the report. The analysis may address change in property conditions between saledates or verifying if a prior sale was an arms length transaction. Simply reporting a transaction is not a sufficient analysis or explanation. Refer to the FHA single family housing appraisal report and data delivery guide page 42".


The prior sale of this sale was within 3 years and not 1 year. Am I missing something. Do we check back three years? I thought it was set back to 1. I dont really get bullet #3 below but I assume #2 is correct.

2.png

Another no no is not to label neighborhoods by town or city lines. Im sure most dont do this but I always had seen that in reports and considered that a man made boundary. Any thoughts beside crapping on me? I am really trying to fix this issue and I am not getting anywhere with FHA. They claim my sources are wrong and it is a deficiency in my report. If my sources that I use do not show it as such is it really a deficiency. I really dont want to may for a subscription to realquest just for this.

Thanks guys :(
 

gregb

Elite Member
Joined
Sep 3, 2011
Professional Status
Certified General Appraiser
State
California
Realist is included in three of my MLS's. Is that an option for you?
 

CindyR

Senior Member
Joined
Oct 26, 2003
Professional Status
Certified Residential Appraiser
State
Arizona
i can click on the actual Deed of Trust in my county records. it will clearly show the FHA case # if there is one. Might be worth the time if that's an option for you.
 

Valueseeker

Junior Member
Joined
May 19, 2016
Professional Status
Certified Residential Appraiser
State
Massachusetts
Realist is included in three of my MLS's. Is that an option for you?

I dont believe it is. I called core logic. Im waiting to hear back to see whats the best route. Not sure how realist differs from realquest.
 

Don Clark

Elite Member
Joined
Jan 17, 2002
Professional Status
Certified Residential Appraiser
State
Virginia
Hello guys,

I got a notice from FHA that ""The data analysis presented in the Sales Comparison Approach is not complete and/or accurate and/or the adjustments are not resasonable and/or supported. "

The problem Im having is this.

I am stating in my report that the sources i am using are MLS/Deeds/Assessors.
When I go to verify this comp, it shows up as Conventional in MLS. Further, when I look at the mortgage docs on the registry of deeds, it shows up as a typical loan. (photo below is from MLS)

View attachment 32827

Now I am completely aware that MLS is data entered by realtors. I called the FHA help line and they said I should be using FHA connector to verify if any of the sales were FHA. Do any of you do this? I asked him to walk me through it and it appears I dont have access. He said you "may not have access but this sale does have FHA financing so your sources are wrong. Use the connector or use RealQuest.

I guess i have to sign up for realquest because my fear is that this will be a repeated occurance where some future appraisal may not have correct concessions. Any advice on this?

(This was not the sole issue that brought up the letter, there were a few issues but I want to rectify all of them and I just need tips on how you guys verify financing.


I also got in the same letter

"The prior sale or transfer history reported for the subject property and/or each of the comparable sales is not complete and/or inaccurate"
There is no analysis of the prior sale for comparable 3. Per public record, this was a transaction between two private parties. The appraiser must provide an analysis of the prior sale or transfer history of the subject property and comparable properties in the report. The analysis may address change in property conditions between saledates or verifying if a prior sale was an arms length transaction. Simply reporting a transaction is not a sufficient analysis or explanation. Refer to the FHA single family housing appraisal report and data delivery guide page 42".


The prior sale of this sale was within 3 years and not 1 year. Am I missing something. Do we check back three years? I thought it was set back to 1. I dont really get bullet #3 below but I assume #2 is correct.

Another reason I no longer do FHA appraisals.:shrug:

Send the FHA just what you have reported here. Also, if necessary, ask to speak to a supervisor.

View attachment 32828

Another no no is not to label neighborhoods by town or city lines. Im sure most dont do this but I always had seen that in reports and considered that a man made boundary. Any thoughts beside crapping on me? I am really trying to fix this issue and I am not getting anywhere with FHA. They claim my sources are wrong and it is a deficiency in my report. If my sources that I use do not show it as such is it really a deficiency. I really dont want to may for a subscription to realquest just for this.

Thanks guys :(
 

bnmappraisal

Elite Member
Gold Supporting Member
Joined
Nov 9, 2011
Professional Status
Certified Residential Appraiser
State
Florida
Honestly if the MLS data is incorrect, I dont think reaching out to them to confirm is going to help.
Generally true, but sometimes it is just a typo on their part. In which case, you can document the call/conversation and amend your report.
 
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