There Go My Brackets
From the Illinois Appraiser June 2016
Is it a USPAP violation to fail to bracket or end up with a tight bracket?
USPAP is silent on bracketing. For that matter, so is Illinois law. Here’s what Fannie Mae says;
“When there are no truly comparable sales for a particular property because of the uniqueness of the property or other conditions, the appraiser must select sales that represent the best indicators of value for the subject property and make adjustments to reflect the actions of typical purchasers in that market.”
Not a word about bracketing.
While comforting for an underwriter to see the collateral fall snugly into place, bracketing is still a guideline. This hasn’t stopped AMCs and lenders from complaining to the Board about missed brackets or huge ranges. There just isn’t a law against having a sloppy bracket, nor should there be.
Something else from Fannie Mae;
“It should be noted that the indicated value in the Sales Comparison Approach must be within the range of the adjusted sales price of the comparables that are reported in the appraisal report form.”
Read here for the full article:
Check out the other very interesting articles such as AMC fair housing Myths and Evaluations. Link to original newsletter.
My comment: I have never “bracketed” anything except the value, when I used to do appraisals for Fannie Mae loans. I have no idea why lenders are requiring bracketing for everything with an adjustment. Just another Stupid Scope Creep I guess. Works ok in conforming tracts with lots of sales and minimal adjustments, but goes downhill quickly after that. Of course, the entire appraisal review-by-computer assumes that all houses are in conforming tracts. As do the Fannie forms, of course.