Why Comp Photos in Appraisals?

Why Comp Photos?

by Richard Hagar, SRA

Excerpt: First, don’t even think about not doing it! To begin with, it’s required. Inspecting the exterior of every comparable isn’t a USPAP requirement, by the way, it is a Fannie Mae, Freddie Mac, Federal Housing Authority (FHA), and Department of Veteran Affairs (VA) requirement.

However, FNMA’s requirement goes directly to the heart of USPAP’s “scope of work” rule. USPAP defines scope of work, in part, as: the type and extent of research and analyses. The scope of work section of the 1004 appraisal states “The appraiser must, at a minimum: (3) inspect each of the comparables sales from at least the street.” So, when an appraiser agrees to an assignment and its required scope of work, they have agreed to personally inspect the exterior of each sales comparable used in the appraisal. There is no way around this; an appraiser can’t contradict the certification requirement by inserting a qualification within the appraisal. In other words, it’s your job; you are being paid to personally inspect each sales comparable—so do it!

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My comments: Last week’s newsletter had a very popular negative post on comp photos: Original Comp Photos: Dangerous, Unnecessary. This week is the other side!! I know what it is like to drive many miles to take an original comp photo that I somehow forgot to take. But, I am more comfortable if I take another comp photo again as I forget about the details sometimes. I have used MLS photos when I cannot see the comp from the street.

Hagar discusses the many aspects of original comp photos, including the limiting conditions on the Fannie forms. In my opinion, the statement is somewhat uncertain. “…inspect each of the comparables sales from at least the street”. Does this mean original photos and always driving by? I do not have this statement in my non-lender appraisals, plus many other Fannie statements. However, many lenders and AMCs have this in their requirements.

On the other side, I used to travel to Canada to speak at appraisal conferences. At that time, taking original comp photos was not required for lending purposes. Few appraisers did them. They said they had “seen it in the past”.

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Appraisal Original Comp Photos

Original Comp Photos: Dangerous, Unnecessary

by Damian Downie

Excerpts: As I do many times a day, I was taking comparable (comp) photos for an appraisal. This one in particular is a condominium, so I was taking photos of two condos in a competing complex. There was a gate into the property, so I stopped across the street and snapped a photo of the gate.

Three minutes later, about a mile from the site, I looked over to my right out the passenger window, and I saw a man holding his phone up and pointing it at me. I asked him what he was doing and he angrily asked me why I was taking pictures of his car.

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My comments: Always a hot, hot topic!! We’ve all got appraiser stories about comp photos (dogs, police, crazy people chasing you down the street, locked gates, etc., etc.)!! After 45 years of appraising I am never bored. There is always something new or weird that I see ;> My scariest experience (for the subject) was when two large Dobermans broke through the screen door of a mobile home and came after me. I got back into my car and told my client to get another appraiser!!

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AMC Fined for Appraisal Order Blast Violation

AMC Fined for Appraisal Order Blast Violation

Excerpt: Consolidated Analytics, an AMC based in Anaheim California, was fined $3,000 for violating the Utah AMC Administrative Rules R162-2e-306 “Offering An Appraisal Assignment and Communicating with Two or More Appraisers About a Potential Assignment.

The specific part of this rule that pertains to broadcasting has been relatively effective in reducing the broadcasting of assignments. Clear Capital recently was fined $5,000 for failing to comply and there are additional complaints working their way through the system.

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My comment: Broadcast orders are bad for many reasons for both the AMC and the appraiser: goes to everyone on their list, no considerations about appraiser qualifications for the assignment including geographic. Hundreds of appraisers competing on fees when business is slow make it hard for appraisers to stay in business. There is always someone with a lower fee, in appraising, and any type of business.

When business is strong, such as today, AMCs have to take whatever warm body they can get. Many appraisers are way too booked up and not taking any more work.

Maybe you can get your state appraisal regulator to get a similar regulation!!

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What does it cost to take appraisal comp photos?

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What does it cost to take appraisal comp photos?

In general, how much do you think the requirements of taking comp photos increases the cost of completing an appraisal? www.appraisalport.com poll
My comments: Comp photos are very controversial, especially with the availability of google (including historic photos), mls, Zillow, etc. Interesting results. Don’t know if this includes blurring out personal items, people, dogs, etc. Maybe includes driving time (non-rural of course) and downloading and filing photos. At least we don’t have to spend lots of money on photo processing plus time going to and from the store any more!!

I am not sure why, but lots of appraisers don’t like to take comp photos. USPAP certainly does not require it. I always do, even if I have taken a photo before, because I can’t remember what was near the comp, condition, etc. I always remember it when I used hear about it when speaking at Canadian appraisal conferences. At that time, appraisers were not required to put comp photos in their lender appraisals. They told me “I know that area very well.” Or, “I drove by it XX years ago.”

Previous Appraisalport polls on comp photos
6/2/15 – analysis of 3 comp photo polls – Comp Photos and MLS, Fannie, USPAP, etc.
Plus read the comments.