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Appraisalport polls on comp photos from June 2015

By Steve Costello,

This month I want to discuss three recent polls dealing with comp photos. In the first poll, we asked “With the availability of MLS photos, do you still feel it is necessary to drive by and photograph every comp?” We had a total of 3819 responses and the top two answers were very close. The winner, with 40 percent of the vote, was “Sometimes, it depends on the complexity of the specific assignment.” Coming in a close second was “Yes, I always want to see any property I use in a report” with 38 percent of the vote. The final answer of “No, I would rather just use MLS photos” only scored about half the votes as the first two answers, finishing with 22 percent. This makes sense because I think most appraisers want to look at a comp before they include it in a report, especially if they aren’t already familiar with the property. I can also see where some appraisers are very familiar with the properties in their area, use many of the same comps over and over again, and don’t feel a need to drive by and photograph them every time they use them.

In the next poll, we asked “In your opinion, with MLS, Google, and other photo sources available to clients, the main reason original comp photos are required from the appraiser is:” This poll had 3986 responses and had a pretty clear winner. A full 63 percent of the appraisers chose the answer “To make sure the appraiser actually drives by the comps.” So it looks like most appraisers don’t think their clients care as much about the actual photo compared to just making sure the appraiser actually visited the comp. The answer we expected to be very popular, “To provide the client with up-to-date photos of the comps – ensuring they exist in the stated condition,” only received 22 percent of the vote. A third response of “So the clients won’t have to take the time to look up the photos from one of the sources noted above” didn’t do well, only pulling in 3 percent of the vote. Not a surprise — we didn’t really expect many appraisers to choose that answer. Finally, 13 percent of appraisers went with “Other reason” as the best choice for this question. We really don’t know if there were one or many “other reasons” or what they are.

Finally, we asked “Would you be in favor of eliminating the requirement to include an original photo of every comp as long as a recent MLS photo of the property could be included with your report?” This question was very popular with 4770 total votes. It also produced a landslide vote with 79 percent of the appraisers selecting the answer “Yes.” Only 15 percent answered “No” and would not want to use an MLS photo instead of an original if it were available. A final 6 percent were “Not sure” how they felt about this issue. So, from this poll it is clear that appraisers feel that an original photo is not a necessity to produce a quality appraisal as long as a good representative photo is available from another source like an MLS.

My comment: As we all know, a photo taken at the time of listing from the MLS is often better than one taken later and USPAP does not require comp photos. Fannie Mae certifications require that the appraiser inspect the exterior of the comp, not take a photo. What about re-using a comp photo? Why the requirement of an “original” photo? To be sure appraisers drive by the comps.

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  1. As a mortgage QC analyst/auditor/whatever, I review appraisals all day long. Appraisals with out original comp photos (and explanations) tend to have more problems, and many times I can’t tell if the appraiser bothered to drive the comps at all. The photo itself isn’t really what we’re after. It’s proof that you at least tried to do your job correctly and ethically. Since location is one of the larger factors in home values, if the comp location isn’t comparable, and the appraiser didn’t at least make a note of it, and a listing photo was used, more often then not, I can make a really strong case that the appraiser pretty much did a desk review rather than an actual appraisal. I quite literally have thousands of instances where locational differences warranted at least a comment on whether or not there should be an adjustment. And I’d like to point out that if you use a comp has been recently razed (in one of the earlier comments), and now there’s a new home or it’s an empty lot, then it’s not really a sale of a comparable home. It’s more a land sale, and unless it’s land value report, it shouldn’t be used as a comp. And before someone says you’ve never been in the field so you don’t know, well, I have been out in the field, and I can tell when you’re just phoning it in. When I review an appraisal that isn’t worth the paper it’s printed on, I’m faced with a dilemma or whether or not to recommend the lender drop the appraiser (or worse, report to the appropriate licensing board). The good appraisers tend to not only take an original photo of the comp, they will also photograph any external issues. The write up on those appraisals tend have much more detail and shows more understanding of the property, the comps, its market, and how the appraiser arrived at the value.

    • But when completing the new Fannie Mae 1004 Desktop appraisal, somehow it is no longer important to view the comparable sales and listings. Does that make any sense whatsoever to anyone??

      • They wouldn’t be able to find an idiot that would do an appraisal and drive the comps for $75 total. How far this industry has fallen…

  2. It’s not surprising with so many appraisers reluctant to drive comps, discount the need for the 1004MC, etc., that the end users are starting to consider us irrelevant!

  3. Does every appraiser complete the appraisal report before doing the inspection? Stupid question, right. How can one be sure that they get all of the comparables that are needed for the report at the time of inspection, unless it’s a track home, built at the same time, similar square footage, condition, utility, etc. Can’t remember when the last 1 of those I did. I try to pull the best comparables that I can find prior to inspection and 90% of the time, whether or not, the homeowner or realtor lies, I typically find one or more comps necessary to complete the report, necessitating going back out to take the additional pictures, adding another hour or more to the time it took to complete the appraisal. The guidelines need to be changed. As far as going out to hostile areas, if there are people on the street and anywhere near the property I don’t take a picture, use the MLS photo and state it in the report. Oh, where did the time go when I actually got out of the car, told the person or persons who I was and what I was doing and they moved out of the way (the good old days).

  4. There is a Washington State instructor who states in his classes that FNMA, FHA and VA regulations require that the appraiser take new photos of comparable sales each and every time they are used in an appraisal. That means that the appraiser must take new comp photos of every comparable sale for each new appraisal, regardless of how many times the comp is used.

    I’ve been an appraiser since the mid 80’s and this is a new on me? I do indeed drive by and photograph every comparable sale I use, but not every time I use it! What do you think?

    • The instructor is an idiot, and needs to take a course in instruction.

    • I think I know the instructor that Cheri is referring to. I was in a class taught by him last week. I specifically asked, “If I inspect and photo a comp today and submit it in a report, then I find out tomorrow that it is a good comp for another report, do I have to inspect and photo it again?” His answer was that anything less would be fraud! His reasoning it that we certify that we inspected the comparables for each assignment separately. He went on to state that Fannie Mae notes the reuse of photos in your file and can use it as evidence of fraud whenever they decide to!

      I would normally take this type of statement with a grain of salt, but this guy seems have the credentials to be taken seriously. My rule has been that I reuse photos and don’t reinspect comps in most cases, if they have not resold since I last used the photo.

      We need to have this answered directly by Fannie Mae. I’m going to attempt to get an answer from the horses mouth and will post my findings. If any of you can cite sources for this specific issue, I’d sure appreciate it.


  5. According to Fannie Mae 1004-B it states that the appraiser must “inspect each of the comparable sales from at least the street.” So what does that actually mean? Well lets think about that for a second. Being that we do not live and operate in the pre-internet era one could conclude that it can be left open to interpretation. Can a person competently inspect a property from the street via the usage of the internet? Possibly… It all depends on how one interprets that statement.

    • I recently spoke with the Chief Appraiser of a large AMC. Referring to clients, he stated that “they make us lie all the time”.

      He was specifically referring to the cost approach, but it applies across-the-board.

      In relation to comp photos- although we sign off, certifying that we observed the comparables from the street, aren’t we lying in regard to rural properties?

      We’re told to take photos of “no trespassing” signs. Did we really observe the property from the street?

      It’s often a case of a taking a picture of a sign at the bottom of a gravel road, with wooded land obscuring the home, which has a distant set-back. Did I really observe it? And why did we drive an additional 43 mile round-trip to do this?

      BTW- there are usually 49 on-site MLS photos taken by a qualified, certified professional.

      So this proves what?

  6. Ann, remember back in the day, around the mid 80’s when Fannie, Freddie and HUD first required comp photos? Some of the reaction was as spirited as above. Good reasons all.

  7. MLS photos shows the condition of the property of when it was listed and would best match what the condition is at the sale date. Taking a photo of a comp 1 month, 6 months or longer is not a representation of the comparable. We have had comp photos of empty lots, homes that have been burnt down, as well as properties that have major renovations. All of those things do not have an influence on the comparable because the appraisal is using the comparable as a snap shot of it’s condition at the time of the sale. Taking a photograph of the comparable is used to hold the hand of the appraiser to make sure they are doing their job and (I believe more likely the reason) today is a data driven era and those photos can be gathered and sold to companies who use them.

    Bottom line is that appraisers are choosing to let every area of the mortgage profession have their way with you, the appraiser. Until and unless the appraisers as a whole decide to work as a whole like the realtors, Banks and AMCs, you will continue to be pushed, pulled and shoved where the rest of the industry wants you to go. I am starting to see how strangling the appraisal profession until the members average age is the mid 50s works great for everyone else. At this age, most of you will only be motivated for short term solutions,thinking of yourself and what you can get now. If appraisers were younger, I believe that a stronger, united push would be possible since they would be worried about a career.

  8. Pardon my interruption of this debate. First, isn’t that partially why we make the BIG BUCKS? Is driving by a comp over and over not worth the money we make? I think so! Some have stated they took comps that were not comparable and had to drive back out. “Get with the program and go MOBILE” its called a tablet. For those who say I’ve been doing this for 100 years. Then you’ve known for 100 years the rule has ALWAYS BEEN DRIVE BY THE COMPS! Should’ve thought about getting out 50 years or more ago, instead of complaining. “If you can’t take the heat, GET OUT THE KITCHEN!” Why I do nursing PRN, NEVER put all your APPLES in 1 basket!

  9. PUREEEEEEE-D Laziness!

  10. I always take my comp photos but over the years this seems to becoming more and more dangerous. Within the past year and a half I’ve had neighbors run out into the street to stop me and ask why I’m taking pics of homes on their street, I’ve had a homeowner get into his car and chase me down to ask why am I taking a pic of his home, and I’ve been stopped by the police because they got a call from people seeing me taking pics and wondering what I was doing. On occasions the homeowner maybe outside and I will pull over, get out of my car with my business card, and ask if I can take a pic of their home. Most of the time they don’t care but I’ve had a few instances when the homeowner has become angry that I asked me to leave. I would prefer to use MLS pics to avoid all this drama.

    • Thank you! With the advent of technology, shooting comps is the most idiotic thing that we do in our practice. I can list at least 10 reasons why it makes no sense anymore. I take pride in what I do. The appraisal community is small. Contact me if you want to talk about it. Cheers.

  11. Honestly I am surprised by the number of appraisers who think an original photo is warranted. One question- back in the day when the loans when south, how many of them went bad purely because an appraisal had MLS photos? As a professional, it is my duty and obligation to know the market, about the subject and about the comparables. By signing the report, I am attesting to that with my license on the line. Making me provide you with another photo just to prove it is denigrating.For all those appraisers who need to drive by the comp every time you use it- that is your business and what you need to do to do your best job. Others do not need this. It certainly consumes a large amount of time in the overall completing of the appraisals when you have to drive the comps every time and take a new photo. And time is money.


    • Amen. Original comp photos is the BIGGEST drag on my profitability and it contributes ZERO to my value opinion. I know my market VERY well and the market is NOT PHOTOS of sales (which I already have from assessors, google, the MLS and/or my assistant), its sales data. In the certification #2 states “inspect the neighborhood”. Wtf does that even mean? What neighborhood out in bfe where I have comps going out 10 to 15 miles?? How come I’m not required to take a picture of every house in the “neighborhood” or turn in a video showing me driving up and down every damn road to prove that I did it? (Comp photos DO NOT PROVE that I drove by the comp, only that SOMEONE did). Why don’t we have to provide a picture of the bathtub’s fiberglass wainscot hiding behind the shower curtain or turn in a substance analysis of the window screens to prove its aluminum or fiberglass? How many field photos do they get of comps when they are using desktop reports or AVMs? ZERO!! Its all just raw stupidity, even more so than the utter uselessness of the 1004mc! (DONT GET ME STARTED!)

  12. If you are not taking comp pictures you are lazy. It is part of the scope of work to inspect the comps. USPAP requires an inspection of the comps. USPAP does not care if MLS photos are used though. When you sign the certification of a URAR you are stating you saw the comps so if you are not driving by and signing the certification, you are committing fraud. I have been a reviewer and investigator for years and we all know that you only want to use MLS photos because it makes your time in the field shorter and less cumbersome. MLS photos shows the condition of the proper only when it was listed, not the condition at the sale or appraisal date. People really need to do their jobs and inspect the comps.

    • With all due respect- nonsense. You state-

      “MLS photos shows the condition of the proper only when it was listed, not the condition at the sale or appraisal date.”

      The condition of a comparable at the time of the appraisal is absolutely irrelevant.

      I’ve driven by comps that had burned down since the date-of-sale. I’ve also driven comps that had new siding, landscaping, etc. since the time of sale. I’d be a fool to adjust for these conditions. A good appraiser would never adjust for the conditions observed in a drive-by inspection at the time of inspection- so what’s the point?

      The condition of the listing does not change from the time that the home was listed to the time of closing, or if the conditions did change, this would be reflected in the terms of the sale. The listing photo is the most accurate representation of the home at the time of sale.

      The argument used to be “power lines”, etc. With current technology- Google Earth, Google Street, etc., this is a moot point. Granted, there are situations in which the appraiser needs to exercise judgment and drive the comp if need be. But that’s a rare thing these days.

      Many times I’ve driven 23 miles in rural areas (double for the return trip in some cases) only to take a photo of a “No Trespassing” sign.

      Inefficiency is always paid for in some way. No free lunch. Every unnecessary comp photo, every stupid “observation” of a kitchen drawer or attic or dishwasher, has consequence and cost.

      Currently, the price of the choking regulation of our industry is paid by the consumer, and also by the dearth of new appraisers, due to the cost and liability of being an appraiser, as well as the limited compensation due to the effects of said over-regulation, which renders our profession unprofitable in relation to the cost and energy invested vs. income.

      Actually, the vast majority of my comp photos are real-time. I resent your accusation that appraisers are “lazy” when they utilize technology in order to be more efficient.

      Also- as many have stated- we rely on Agents for information regarding all interior aspects of the comparables- but we can’t rely on them to take a street photo of the Subject?

      We need to reject the outdated and dogmatic concept of the necessity for “real time” comparable photographs.

      • Don, I could not agree more. I have been doing this for 30 years now and desperately want to get out of this industry because it has only gotten more and more cumbersome to complete these reports wit more and more verbiage required for some of the dumbest requests by lenders. I hope to be out and only do this part time in the next year or so.

    • CRAIG,


    • Appraisers need to see the comps they are using, that is correct. MLS photos shows the condition of the property of when it was listed and would best match what the condition it was in at the sale date. Taking photo of a comp 1 month, 6 months or longer is not a representation of the comparable. We have had comp photos of empty lots, homes that have been burnt down, as well as properties that have major renovations. All of those things do not have an influence on the comparable because the appraisal is being used at the time of the sale. People really need to do their jobs and know what they are reviewing or investigating.

    • Craig–
      Please quote the page, line number, and standard from USPAP that you claim requires an “inspection” of comps.

      Now please explain:
      1) How an appraiser would inspect INTANGIBLE RIGHTS which can be appraised under USPAP standard 1-4(g)? and what type of camera I can use to take photographs of the intangible comps?
      2) How an appraiser would “inspect” the comparables for a life estate under USPAP Standard 1-4(d)…knock on a door and take a pic of the old lady who answers and assume she holds the life estate?
      3) How mineral rights appraisers “inspect” thousands of cubic feet of underground gas deposits, or their comps.
      4) How the US Army Corps of Engineers conducts USPAP-compliant appraisals on “temporary flowage easements.” (I guess you’d have to take your comp pictures at the exact time of a flood? Thankfully those can be predicted with 100% future accuracy, unlike property values themselves.)
      5) Why USPAP Advisory Opinion 34 allows appraisals to be retrospective or prospective. (Surely properties or their comps that don’t exist yet or no longer exist are tough to “inspect” and photograph.)
      6) How certified appraisers issue USPAP-compliant reports for air rights, water rights, etc. Any Google search will demonstrate these are done all the time…are all those appraisers negligent?

      Your post indicates a grave misunderstanding of USPAP.

      • USPAP does not require any photos, inspecting the subject inside or from the street, or driving by the comps. Unfortunately, some appraisers who have only done lender work confuse USPAP with Fannie, etc. requirements. This is a lender requirement. Otherwise, how could a desktop reviewer change a value? Why this lender requirement? Otherwise not all appraisers would inspect the exterior of the comps, as required by Fannie. In the past, in Canada, lenders did not require viewing the exterior of the comps. Canadian residential appraisers I spoke with said “I know all the houses there.” Or, “I saw it a couple of years ago.

    • Your thinking is flawed. Comparables are selected within a reasonable time frame of one year or less.

      If the Comparable was discovered to have burned down one month ago, does that mean that it wasn’t comparable when it sold four months ago?

      I hate the “lazy” accusation. But I’m glad that you’ve lived to be 109 years-old.

  13. I don’t know why extra trips for photos are necessary, unless the weather, rain, sun spots, spoil a photo. In that case, then use the MLS photo and explain. I research first, take many comps with me, drive by most and get the photos. Later choose the best comps. When the requirements are, you must inspect the comps from the exterior, get the photo then. You can also make notes about the comp or neighbors homes, park, playground, etc.. I suspect that most who use MLS photos are not really inspecting the comps, and shortening their report time.

  14. I agree with Klara. Today I have to drive back to get more comp photos because the ones I took with me on the original assignment were too small (the actual sq ft of the property is 500 feet larger than tax rolls). Therefore its a two hour trip out of my way today just to get comp pics. Really- how often do you get the comps right before you have ever seen or measured the house? I try to use the online MLS on my phone but it doesnt work well enough. I think going back a second time to get comp photos is single handedly the biggest time drain in my business.

    • I am very surprised at how many appraisers make a second trip for comp photos. I very rarely have done this in my 30 years of doing residential lender appraisals. When I have to go back in the field, it is always did not pre-screen the property well or the property had something very strange and unexpected. I always printout a long list of 1 line MLS listings and sales and printout at least 20 full mls printouts. I never use price as the only criteria. I never rely on pubic records to have correct data. I ask the borrower if the public records is correct, particularly bedrooms and GLA. If I did not do this before going out, I would bring my laptop computer with me to do it in the field and would purchase a wifi hotspot for it. I also google the address to see what it looks like from a street view. Of course, if I have to go back out in the field, even for one comp, I always do. I am an “old timer”. I have to drive by every sale. Otherwise I can’t sleep at night ;> I have never been able to do desktop appraisals or reviews, of course…

      • I very much respect you Ann, but we clearly disagree; or perhaps it comes down to the fact that we just live in very different areas.

        I’d welcome your feedback on my comments.


        • I think you misunderstood my comment. The best photo of a comp is when it was first a pending sale. A photo when first listed is also good.
          If you choose to work for lenders, you have to put up with their requirements, however idiotic or stupid, per USPAP. Lenders do not trust appraisers. Fortunately I have not worked for any lenders since 2005. USPAP does not require an inspection of the subject or the comps.

      • I know in Virginia half of the appraisers don’t drive by the comps on fha orders. When I do reviews I am shocked. Several of these appraisers even work for board members. I spend about 30 to 40 hours a week driving by comps.

      • Totally AGREE. If I DON’T do MY JOB, to the FULLEST I can’t sleep at night. There’s no rock left un-turned. It’s called integrity. A rear gift to possess these days. And I work PRN jobs, go to school and I’m old too.

      • Totally AGREE. If I DON’T do MY JOB, to the FULLEST I can’t sleep at night. There’s no rock left un-turned. It’s called integrity. A rear gift to possess these days. I also work PRN jobs, go to school and I’m old too.

        • So- if, upon drive-by street inspection, you note a difference in the condition of the Comparable as compared to the MLS photo, do you make an adjustment?

          Like- an “it burned down” adjustment?


    • Pardon my interruption of this debate. First, isn’t that partially why we make the BIG bucks. Is driving by a comp over and over not worth the money we make? I think so! Some have stated they took comps that were not comparable and had to drive back out. “Get with the program and go MOBILE” its called a tablet. For those who say I’ve been doing this for 100 years. Then you’ve known for 100 years the rule has ALWAYS BEEN DRIVE BY THE COMPS! Should’ve thought about getting out 50 years or more ago, instead of complaining. “If you can’t take the heat, GET OUT THE KITCHEN!” Why I do nursing PRN, NEVER put all your APPLES in 1 basket!

  15. In the Fannie Mae/Freddie Mac forms, in the preprinted Scope of Work, #3 states “inspect each of the comparable sales from at least the street.” When the appraiser signs his/her signature to the preprinted form, he/she is acknowledging that the comparables were viewed by them. How does the reader of the appraisal report (client) know that the appraiser did view the comparables? The thought would be if the appraiser drove by and viewed the comparable from the street, he/she would have taken a photo of the comparable, thus proving that the appraiser did view the comparable from the street. This would also be the best practice as the photo could be reviewed as the appraiser is writing the report and rely on it for comparison viewing and it would provide proof that the appraiser did view each of the comparables used in the appraisal report.
    USPAP does not specifically state that the photo of the comparables used in the appraisal report must be taken by the appraiser. It was stated in the 2008-2009 edition of USPAP that when the Appraisal Foundation removed the definition of Supplemental Standards, “the deletion removed specific recognition of Government Sponsored Enterprises (GSE) as a source of assignment condition because they provided guidelines.” But it also stated “the edits do not change 1) the necessity for an appraiser acting in compliance with USPAP to follow GSE guidelines where applicable; and, 2) the enforcement of USPAP, including items necessary for competent performance and meaningful reporting.” The duty for the appraiser to comply with applicable assignment conditions is embedded in the obligation to provide ethical and competent services. The Scope of Work Rule requires appraisers to identify the problem to be solved, which includes identification of assignment conditions. In communicating assignment results, the requirement that reports be meaningful and not misleading creates an obligation to comply with applicable laws, regulations, and guidelines. Therefore, USPAP requires appraisers to know and understand GSE guidelines as they are part of the appraisal problem to be solved and are an assignment condition.
    Fannie Mae guidelines change over time and the current Selling Guide (2014) indicates that the photos of the subject property must be original and that the comparables may be of original, from the Multiple Listing Service (MLS) or copies from the appraiser’s files. However, Freddie Mac guidelines state the following: 44.12: Required exhibits and addenda (Effective: 03/19/12) each appraisal or inspection report must include at least the exhibits required for the assessment type. The exhibits must meet the requirements provided in this section. (a) Exhibit requirements: For any comparable sales, if an original photograph cannot be obtained, a clear copy of the photograph of the comparable sale from a multiple listing service (MLS) is acceptable. The appraiser must have provided a reasonable justification for using the MLS source. HUD guidelines show the following for comparable photos: Photo depicting the front view of each comparable sale utilized must be those taken by the appraiser. The photos taken by the appraiser are considered evidence of compliance with the Scope of Work of having inspected each comparable sale from the street. Use of MLS photos to exhibit comparable condition at the time of sale is acceptable; however, the appraiser must include their photos as well to document compliance. Two of the three appraisal guidelines require the appraiser to take a photo of the comparables. Most of the time a lender/client will order the appraisal as a Fannie Mae, or Freddie Mac or FHA. But it is not uncommon for a lender/client to shop the loan around and the loan that was going to Fannie Mae ends up going FHA. The lender/client may also have specific guidelines that are included in the appraisal order that specifically state the comparable photos must be originals. These guidelines would be part of the assignment conditions that are found in USPAP under Scope of Work – Problem Identification, which state: In an appraisal assignment, for example, identification of the problem to be solved requires the appraiser to identify the following assignment elements: client and any other intended users; intended use of the appraiser’s opinions and conclusions; type and definition of value; effective date of the appraiser’s opinions and conclusions; subject of the assignment and its relevant characteristics; and assignment conditions. Therefore USPAP creates an obligation for appraisers to recognize and adhere to applicable assignment conditions which would be the relevant appraisal regulations and guidelines that indicate whether comparable photos are to be originals taken by the appraiser or not.
    The best practice would be, if the photo of the comparable cannot be taken from the street, take a photo of the mail box, driveway, or address sign and then include both the original photo and the MLS photo of the comparable as an addendum photo and clearly identify it as a photo taken from the MLS. Always use the original photo of the comparable that is taken by the appraiser to show that the comparable was viewed and if the photo is an original taken from an office file, state so in the report.

  16. I totally agree with your opinion. I think MLS photos are a much better representation of the comps than a current photo and I also think lenders have an unrealistic expectation of the turn time. I no longer quote or promise 2 days after inspection because it can take me two days to actually get to writing the report with my work load, and then I have to return to take comps photos ( I don’t take comps photos when I first go to the property) on the 3rd or 4th day. My clients are used to me taking longer to complete most reports for them and this has not impacted my business volume. In fact, because I am certified, I am seeing more business now than anytime in the past and new AMC’s and even banks are asking me to join their panels. I focus on quality, not speed. I sleep better at night knowing the report quality is there even if the ETA has been sacrificed.

  17. It should be about getting the information correct, not about a picture.

  18. I have a big problem with this. Our state board(NC) has now started to discipline fellow appraisers for providing MLS photos when original appraisal appraisal requests state “original photos only”. This is extremely disappointing that our board has taken this position as this is a large ongoing contention between working class residential appraisers and lenders. I am a firm believer that if a lender wants an original photo, then they better be paying a large appraisal fee, especially if the home is more than 30 minutes from my office. Why the large fee you ask, well my opinion differs extremely from the lenders and if the lenders took my thought process, I seriously doubt this would even be an issue. There are only two ways to complete an appraisal with original comp photos and neither fit into the neat little package of a report that AMC’s and most lenders are striving for.

    The first option is for the appraiser, if they don’t have portable MLS access on the subject’s inspection(most of us dont), is to take several comps on the appointment with them printed out, take all the photos and when back at the office dig through the ones that fit the best and use them in the appraisal. You will have to take several because most of us don’t have sketching software that we obtain the correct subject square footage at the end of the appointment. So your left driving around taking photos of many properties you may never use. This is what lenders expect that we are doing to obtain comp photos while we are on our subject inspection. Another large contention with this being the expectation of the lender, is that if you have made decisions about what comparables to use prior to examining the subject. So in some form or fashion, you as the appraiser on some level have now pre-determined the value of the subject. A direct violation of USPAP. While most of the lenders are not aware that this is the precedent they are setting, I don’t think many realize that this policy is the cause of many misleading reports and just flat out using the wrong comps when better ones exist. This is what the lender is supporting. For you to somehow use in some cases terrible or vague tax records to predetermine what comps you will use for the subject prior to examining the home closely on an appraisal inspection. This is wrong and the state appraisal boards should not be supporting this method either.

    The second option is the one I like, however we as appraisers are a long way off getting paid what we are worth working under these terms and methods. I personally would like to know that I have gathered all the subject info to the best of my abilities before I even look for comps. After I have arrived back at my office, put in my pictures, done my sketch and analyzed any repairs and upgrades the subject has or needs, by then and only then after I have all this info on the subject home, do I then start to look for comps. That I know I have done to the best of my ability to get to know all I know about my subject property which in turn allows me to select the best comparables that will yield the lowest gross/net adjustments. This is the correct way, in no form or fashion does the first scenario even come close to the accuracy of this method. Here is where the huge problem comes in though, that I know many appraisers are not talking about. That after you have completed this process, they are not letting us use MLS photos. If this method is the lenders expectations, that we are now jumping in our cars and driving to and back from the subject property and sometimes circling the subject in miles and miles taking comp photos to include with our most accurate appraisal report. If the lenders and AMC’s that are paying these mid grade to low ball appraisal fees with this expectation, then this method doesn’t benefit the appraiser either. If this was the case for all reports and mandatory for the appraiser, I don’t think you would be see an appraisal fee under $500 for the added work.

    I believe this to be a major concern for our business of working class residential appraisers right now, as our board has even jumped on the lender bandwagon in writing discipline cases based on appraisers not following through with taking actual photos. There are many pro causes for using the MLS photo. Obviously lenders are not now and likely will never in the near future be paying me what it is worth for option #2 above, to carefully pull the perfect and right comps to then jump back in the car to go back to the subject’s area to take more photos. Using the MLS photo shows what the home looked liked when sold, the condition from the exterior is more accurate. Think if a comp sold and was then completely renovated after sale but yet in our appraisal condition and quality ratings are set low because the house was in shambles when it sold months prior. This just leads to more commentary having to be written on our parts. How about if the new owners add a garage…more commentary for us again to say it wasn’t there at sale. So by not using the MLS photo, behind every corner it creates more work for us and were not getting paid for it. Furthermore our licenses are now in jeopardy because of it. Just wait until you explain this on the next fee quote for a lender that wants original comp photos…..$500-$600 sir/madam…I know, I know, you can hear the stun in their voice, then comes the laugh and then comes nothing…because that lender is now to busy taking you off the future preferred appraiser call list and likely never orders from you again.

    I work in a growing market with lots of sales, I have a lot of direct competition in my market and will almost get beaten by lower fees by just quoting a nominal appraisal fee, yet one that pays me to visit the subject’s area twice on every report. Often I see terrible appraisals come across my desk and think to myself, what in the world was this appraiser thinking when they pulled these comps, even sometimes missing better comps even on the subject’s street. These types of reports are almost always due to appraisers that stick to my the first option. On top of most likely predetermining the subject’s value, pulling comps when blind to the subject’s features and square footage, eventually will certainly lead all appraisers down a dark path. Option 2 is irrefutable when compared to option 1, 99% of the time the second option will create a more credible report. So when will the lenders either make this realization and pay us to return to the subject’s area twice for all appraisals or simply drop this nonsense about not allowing mls photos. In the meantime, those appraisers that are trying to be the best appraiser by following option two but simply dont have the time for that second trip, use the MLS photos wisely because until we can all come to an agreement on how this properly should be done, your state board might be on a witch hunt. Good luck out there fellow valueers.

    • Are you psychic and reading my mind? I think EXACTLY the same thing. I can only say AMEN Brother. From a Texas Appraiser who only works for private clients & banks who keep their loans.

      The Pics issue would be a step in the right direction, but I don’t hold out much hope for wanting to do federal work until scope creep & liability dumps to appraisers reverse course in a big way. I might not be getting wealthy but I have a life, enjoy the appraisal work I do, & can sleep at night. I encourage all competent appraisers to at least part time consider, real estate sales, & or real estate investing & earn some money from your expertise. It has made a big difference in my life. My fellow Appraisers, Stop scurrying for crumbs & take a bite like the clients we have been working for.

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