Should CU be transparent? Poll results
Poll results from ICAP poll – Illinois Coaltion of Appraisal Professionals, a very active appraisal political action group. www.icap.com
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Excerpt:
A few of the results of the 10 questions:
Q1 Should Fannie Mae make CU transparent?
Yes – 89%
No – 6%
Uncertain – 5%
Q3 Will CU risk scores cause Lenders and AMC clients to request appraisers to fit comps to the CU model?
Yes – 69%
No – 5%
Uncertain – 26%
Q5 Do you think the intent of CU is to
replace the appraiser?
Yes – 53%
No – 25%
Undecided – 22%
Download the results
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Online petition to allow appraisers access to CU UAD data
ICAP also has a petition to Fannie Mae that created 11/10/14. “Online Petition to allow appraiser access to data they provided through the Uniform Appraisal Dataset (UAD).”
Excerpt:
The GSE’s have mandated that all appraisals be submitted in the UAD format; however, currently there are no plans to provide appraisers access to this data.
This data needs to be provided to appraisers at the beginning of the appraisal process; ensuring transparency, and improving the process by reducing risk to lenders and the general public.
Sign the petition at http://icapweb.com/petition.php Plus read the very interesting comments from appraisers!!
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My opinion: I support the petition asking Fannie to let appraisers get the data that we submitted!! CU transparency is more difficult, for various reasons.
Ann,
“My opinion: I support the petition asking Fannie to let appraisers get the data that we submitted!! CU transparency is more difficult, for various reasons.”
I disagree. First of all, you should already have the data that you submit and should not need Fannie to let you have access to your data. Second, since when are we supposed to have access to data from other appraiser’s reports? We aren’t.
I do not want the CU ahead of time. I want to do my report to the best of my ability and do not want the influence from who knows what appraisers applying pressure on my thought process to conform to whatever they did.
CU will NEVER work!
As an appraiser, I research, inspect and collect as much information on the subject property as is reasonably available, to define; the most significant value features, who would be the most likely buyers for this property and what comps would appeal to the same buyers.
After making adjustments, there are usually large differences between the comps’ adjusted prices.
Ideally, the three approaches to value should all be equal.
a) The Sales Comparison Approach:
– If all adjustments are correct, the adjusted values of all comps should be all be the same and would also be the indicated subject value (no “weighting”” required).
b) The Cost Approach should equal the Sales Comparison Approach.
c) The Income Approach should equal both.
When the comps are not equal to one another, usually the case in this area, I believe it is because some elements have not been adjusted appropriately or even considered. This, I believe is due to the “unknowables”. If the difference is significant, say…more than 10%, it calls into doubt the reliability of the indicated subject value.
I have tried several commercial Multiple Regression Analysis programs and, so far, they have all failed to indicate believable adjustments, probably because they appear to allocate the “unknowables” to other value elements.
Yes, we are most all in agreement that the CU is not what we want checking our work, but as a “training tool” for new appraisers, it would be a great reference of data! They can verify what comps they thought were good and compare them to what CU has! I haven’t seen anyone mention this as the perfect place for CU, but I think so!
CU is a complete disaster and should be trashed immediately. It is a deal killer run a muck. Here’s the senario, 8 months ago I appraised a house that was purchased as a initially as “rehab potential”; mt appraisal was for the sale as a gut job and total renovation. Everything was new except the brick walls. I had 4 good comps. that supported the sale price and NO problems with underwriting. A couple week ago the owners refinanced and I was assigned the appraisal order. I made the disclosure of the prior appraisal and provided 6 comparables because 2 were just beyond 6 months.
The MV was slightly less than the prior appraisal because we are in a Winter market. The following CU resulted in a poor rating of the appraisal and upon my review most everything was WRONG with the review. It is like they reviewed a completely different appraisal. Much of it refers to discrepancies with NCD database comparisons. With a 5 year database it is very likely in my market area that they could have 2 or 3 sales of the same property in the past 5 years and they will all have different NCD values because properties change over time, some are renovated, some are expanded, and some are a knockdown with new construction tripling the GLA. It is as nightmare and it will only get worse and CU unfolds. No only will appraisers be severely affected but, and loans will be lost in the process and areas of gentrification will be hit the hardest. This CU is insanity and it must stop before it destroys the housing market!!!
GAAR ® Activated Rule Alerts
Orange UAD Rules
GAAR ® Compliance
FNC-C-N-096-01 Market Conditions: Field contains term(s): “DECLINING”
FNC-C-IMP-009-01 GENERAL DESCRIPTION: Units: ONE WITH ACCESSORY UNIT box is checked
FNC-C-IMP-018-01 GENERAL DESCRIPTION: Type: ATT. Or S-DET./END UNIT box is checked
FNC-C-IMP-309-01 Describe the condition of the property (including needed repairs, deterioration,
renovations, remodeling, etc.): Field contains term(s): “DRYWALL ”
FNC-C-SCA-069-01 Sales Comparison Approach: Sales Price: The OPINION OF MARKET VALUE
(772500) is greater than the unadjusted sales prices of the settled (s)
Comparable Sales
FNC-C-SCA-099-03 Date of Sale/Time: Field for comparable 2 is more than 6 months old
(s08/14;c07/14)
FNC-C-SCA-099-03 Date of Sale/Time: Field for comparable 3 is more than 6 months old
(s07/14;c06/14)
FNC-C-SCA-327-01 Unlabelled Line 2: Extra Item Feature: Comparables: The field is blank and
Subject: Description field contains an entry for comparable 1
FNC-C-SCA-327-01 Unlabelled Line 2: Extra Item Feature: Comparables: The field is blank and
Subject: Description field contains an entry for comparable 2
FNC-C-SCA-327-01 Unlabelled Line 2: Extra Item Feature: Comparables: The field is blank and
Subject: Description field contains an entry for comparable 3
FNC-C-SCA-327-01 Unlabelled Line 2: Extra Item Feature: Comparables: The field is blank and
Subject: Description field contains an entry for comparable 5
FNC-C-SCA-348-01 Adjusted Sales Price of Comparables: The Net adjustment for comparable 6
exceeds 15 percent of the unadjusted sales price
FNC-C-SCAHIS-009-01 My research did/did not reveal any prior sales or transfers of the SUBJECT
PROPERTY for the three years prior to the effective date of the appraisal: DID
box is checked
FNC-C-SCAHIS-015-01 My research did/did not reveal any prior sales or transfers of the COMPARABLE
SALES for the year prior to the date of sale of the comparable sale: DID box is
checked
FNC-C-SCAHIS-021-05 Sales Comparison Approach: Date of Prior Sale/Transfer: Subject: The field
contains a date within the 3 years prior to the effective date of the appraisal
FNC-C-SCAHIS-024-01 COMPARABLES: DATE of Prior Sale/Transfer: Field for comparable 4 contains
date for the year prior to the date of sale of the comparable sale
FNC-C-SCAHIS-030-01 COMPARABLES: PRICE of Prior Sale/Transfer: Field for comparable 4 contains
sales price for the year prior to the date of sale of the comparable sale
FNC-C-SCAHIS-045-02 Analysis of prior sale or transfer of history of the SUBJECT PROPERTY and
COMPARABLE SALES: A box is checked to indicate a prior sale and field
contains NONE
GAAR ® Risk
FNC-R-SUB-081-01 Is the subject property currently offered for sale or has it been offered for sale in
the twelve months prior to the effective date of the appraisal? The YES box is
checked
FNC-R-SUB-081-02 Subject: Is the subject property currently offered for sale or has it been offered for
sale in the twelve months prior to the effective date of the appraisal?: The
Assignment Type is a Refinance and the YES box is checked
FNC-R-N-012-01 Property Values are marked as INCREASING and DATE OF SALE/TIME of 2 of
the first 3 comparables is greater than 90 days old
FNC-R-N-012-02 Property Values: INCREASING box is checked and DATE OF SALE is greater
than 90 days old for 2 of the first 3 comps and DATE OF SALE/TIME field does
not contain a positive time adjustment
FNC-R-N-027-01 Single Family Housing PRICE: The OPINION OF MARKET VALUE (772500)
and/or SALES PRICE () of the SUBJECT exceeds the predominant ONE-UNIT
HOUSING price (734) by more than 5 percent
FNC-R-IMP-027-03 GENERAL DESCRIPTION: Age: SUBJECT is greater than 60 years and the
difference between the ACTUAL (1900) and EFFECTIVE (0) ages is more than
20 years
FNC-R-IMP-043-01 Foundation: Basement: FULL BASEMENT or PARTIAL BASEMENT box is
checked and more than 1 of the first 3 comparables contains upward
adjustment for BASEMENT AND FINISHED ROOMS BELOW GRADE
FNC-R-IMP-309-01 Describe the condition of the property (including needed repairs, deterioration,
renovations, remodeling, etc.): Field contains term(s): “DRYWALL ” and AS IS
box is checked in RECONCILIATION
FNC-R-SCA-006-01 There are ______ COMPARABLE PROPERTIES CURRENTLY OFFERED FOR
SALE in the subject neighborhood ranging in price from $_____to $____: The
SUBJECT’S OPINION OF MARKET VALUE (772500) is outside (lower or higher)
the numeric entries in field for range of PROPERTIES OFFERED FOR SALE
(789,900 to 874,900)
FNC-R-SCA-069-01 Sales Price: Unadjusted sales prices of 1st 3 comparables do not bracket
subject’s OPINION OF MARKET VALUE
FNC-R-SCA-069-04 Sales Price: 1st 3 comparables have sales prices greater than subject’s
OPINION OF MARKET VALUE (772500)
FNC-R-SCA-069-06 Sales Comparison Approach: Sales Price: All Comparables and/or Listings and
Pending Sales have prices greater than the Subject’s OPINION OF MARKET
VALUE (772500).
FNC-R-SCA-111-04 Location: 2 of the 1st 3 comparables contain positive or negative adjustments
for Location
FNC-R-SCA-159-01 Site: Comparables: Size of 2 of the 1st 3 comparables are not within 30 percent
of the SUBJECT’S site size
FNC-R-SCA-165-03 Site: Comparables: Comparables 1-3 contain NEGATIVE (-) adjustments across
the board
FNC-R-SCA-195-27 Actual Age: SUBJECT: Age noted as 115 and age of comparable 6 is 38
FNC-R-SCA-219-04 Bedrooms: SUBJECT: For 2 bedroom, 2 of the first 3 comparables have less
than or more than 2 bedrooms
FNC-R-SCA-237-03 Gross Living Area: Subject: Greater than or equal to 1000 sq ft and less than
1250 sq ft, variance for 2 of the 1st 3 comparables is greater than 250 sq ft
FNC-R-SCA-237-14 Gross Living Area of Comparables: Subject Property’s gross living area is not
bracketed by the 1st 3 comparables’ gross living area
FNC-R-SCA-237-15 Gross Living Area: Comparables: GLA of the first 3 COMPARABLES is larger
than the subject’s GLA
FNC-R-SCA-243-04 Gross Living Area: Comparables: Comparables 1-3 contain NEGATIVE (-)
adjustments across the board
FNC-R-SCA-252-04 GENERAL DESCRIPTION: Units: ONE WITH ACCESSORY UNIT box is checked
and more than 1 of the first 3 comparables contains upward adjustment for
BASEMENTS AND FINISHED ROOMS BELOW GRADE
FNC-R-SCA-318-02 Unlabeled Line 1: Comparables: Comparables 1-3 contain POSITIVE (+)
adjustments across the board
FNC-R-SCAHIS-027-02 Price of Prior Sale/Transfer: SUBJECT: Prior Sales Price (775,000) is higher than
the OPINION OF MARKET VALUE (772500)
GAAR ® External
FNC-EXT-MKT-000-24 County Level Market Trend: Median Price Trend indicates Stable market. The
Appraisal Report Neighborhood Housing Trends notes: Property Values
INCREASING
FNC-EXT-MKT-000-31 County Level: The One Month Percentage of Distressed Sales in relation to the
Total Sales is increasing. A Distressed Sale is typically a Lender Sale or another
type of Court Ordered Sale
FNC-EXT-MKT-000-49 County Level: The One Month Median Sales Price trend is stable. The twelve
month Median Sale Price trend has been increasing
FNC-EXT-PROP-000-03 The Subject Property sold within the last 18 months from effective date of
appraisal
FNC-EXT-PROP-000-05 The Subject Property sold more than 1 time in the last 18 months from effective
date of appraisal with significant price change
FNC-EXT-PROP-000-06 Appraiser Comparable 2 is a potential Flip Sale with significant price change
FNC-EXT-PROP-000-07 Lot size of Comp as reported in the NCD varies significantly from the subject’s
lot size as reported in the NCD for at least 2 of the 1st 3 comps
FNC-EXT-PROP-000-09 Bedrooms of Comp as reported in the NCD varies significantly from the
subject’s Bedrooms as reported in the NCD for at least 2 of the 1st 3 comps
FNC-EXT-PROP-000-10 Gross Living Area of Comp as reported in the NCD varies significantly from the
subject’s Gross Living Area as reported in the NCD for at least 2 of the 1st 3
comps
FNC-EXT-VAL-000-04 Lot size of comparable 3 reported by Appraiser (1629 sf) differs significantly
from the NCD (1742)
FNC-EXT-VAL-000-06 Age (year built) of Comparable 2 reported by Appraiser (115) differs significantly
from the NCD (1923)
FNC-EXT-VAL-000-09 Gross Living Area of subject property reported by Appraiser (1,090) differs
significantly from the NCD (1158)
FNC-EXT-VAL-000-11 Opinion of Market Value: The appraisal report’s opinion of market value (772500)
varies from Valuesight’s median value by greater than 10 percent
FNC-EXT-VAL-000-12 Comparable Properties 1, 2 and 3: The average proximity of comparables 1, 2
and 3 to the subject property as calculated by the system differs from the
average distance of the comparables in Valuesight by greater than 50 percent
FNC-EXT-VAL-000-21 Sales Comparison Approach: Condition: Subject: The Description field (C2)
differs from the most recent UAD Condition Rating recorded in the NCD (C3)
FNC-EXT-VAL-000-23 Sales Comparison Approach: Quality: Subject: The Description field (Q3) differs
from the most recent UAD Quality Rating recorded in the NCD (Q4)
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