Where does the requirement to inspect comparable sales from at least the street arise from?

[sputnam]

It is a Fannie/Freddie requirement and it is part of the preprinted Scope of Work statement on Page 4 of 6 of the 1004 form.

I don't know how prevalent it is, but it is clear to me that many appraisers have never actually read the preprinted parts of the most commonly used appraisal report form.

 

[djd09]

independent means not controlled by others...

 

[George Hatch]

It is a Fannie/Freddie requirement and it is part of the preprinted Scope of Work statement on Page 4 of 6 of the 1004 form.

I don't know how prevalent it is, but it is clear to me that many appraisers have never actually read the preprinted parts of the most commonly used appraisal report form.

That's not all that they don't read.

 

[Mike Ault]

When I have a client that needs in-house valuations, I make sure to give it to them on a non-UAD form. That way, I can hold them to their promise to keep it "in-house", and not attempt to use it for GSE/secondary market purposes. You are free to "roll your own" report that way, using forms & certifications which are appropriate to the mutually agreed-upon assignment conditions.

 

[Joe Flacco]

Another question arises, if nothing more than to ensure that this isn't a completely useless thread. The 1004 form states that "This appraisal report is subject to the following scope of work, intended use, intended user, definition of market value, statement of assumptions and limiting conditions, and certifications. Modifications, additions, or deletions to the intended use, intended user, definition of market value, or assumptions and limiting conditions are not permitted. The appraiser may expand the scope of work to include any additional research or analysis necessary based on the complexity of this appraisal assignment. Modifications or deletions to the certifications are also not permitted. However, additional certifications that do not constitute material alterations to this appraisal report, such as those required by law or those related to the appraiser’s continuing education or membership in an appraisal organization, are permitted."

Some contend that the "are not permitted" phrase is absolute, and can't be modified if using this form, and by extension, the scope of work can only be expanded. I disagree. It is a requirement, in FHA assignments, to include a statement that FHA is an intended user of the report, but FHA is not the lender/client identified as the intended user by the form. The changes in the reporting of neighborhood trends, etc, with the introduction of the 1004MC also changes the usage of the form from its intended usage. I am sure there are others, including the changes implemented during Covid, that I haven't used, am not thinking of, or never heard of. But my position is that any part of the preprinted form can be overridden with agreement of the client and the necessary disclosure in the report, although I usually see the "FHA is an intended user" phrase without any qualification or recognition of the discrepancy created by that requirement. In other words, common usage of the form since its inception has been to modify the report to override preprinted verbiage as warranted, which negates any notion that the preprinted verbiage is absolute.

I'm in the same camp. Modifications, additions, or deletions are not permitted when being delivered to GSE's.

 

[Mark K]

Disclosure: I don't do F/F or GSE work of any kind.

I do narrative and occasionally a GP form. Neither states that I inspected the exterior of the comps from the street and accordingly, I haven't taken a comp photo in many years. If I feel a photo is necessary I'll use Google Earth street view, photos from the county assessor site, or MLS photos. I credit the appropriate source and move on.

But I do remember the pre-printed forms stating that I did take comp photos and so I took thousands of them, back in the day.

 

[djd09]

the 1004 is like a virus...making the independent appraiser sick...taf should have step in a long time ago to correct their neighbor

 

[George Hatch]

TAF has no say in how Fannie/Freddie do their forms. When TAF tried to correct Fannie's warped interpretation of intended user/intended use WRT C#24 Fannie just ignored it and did what they wanted to do anyway. When appraisers (like me) complained about C#24 and also about their form not addressing HBU or exposure time they proceeded to do what they wanted to do.

Fannie and Freddie are users, not appraisal entities. That's why appraisers have to do work-arounds with how they run their forms and a couple other aspects of their appraisal policies. We're LUCKY that Freddie wised up and hired a SME on USPAP because now appraisers have a shot at getting appraisal forms in their next revision that will require little/no gerrymandering in order to fit the requirements of USPAP. That could potentially lead to a reduction in the usage of addenda.

 

[djd09]

Fannie and Freddie are users, not appraisal entities

seriously how much do they pay you to post your garbage...the gse's and your buddy dw are waiving appraisals duh

 

[George Hatch]

I'm not saying anything in 2024 that I wasn't also saying in 2004. I stopped agitating against the (IMO) flawed interpretation of C&R once the feds committed to it but that doesn't mean I ever agreed with it. To this day I still favor forcing lenders into direct engagement even it looks like that will never happen, but my preferences and opinions don't stop me from recognizing and acknowledging why some of the lenders have gone with AMCs. That's what you're calling me a shill for.