It’s Not a Comp, It’s a Sale; Stop Fannie Mae Lies!
It is merely a SALE…
Something’s been gnawing at my craw ever since January when FNMA’s wonderful Collateral Underwriter (CU) was unleashed to the world. And before that, when FNMA’s Appraiser Quality Monitoring (AQM) process was introduced to judge the work of appraisers.
No one else has written about this. No one has even mentioned it. So I will: It has to do with the word “Comp” which is used liberally by Fannie Mae (FNMA).
What exactly is a “Comp?”
In FNMA’s world, it’s any property that they obtain, either by their vast AVM process which examines millions of property transactions, or properties that have been extracted from appraisal reports submitted by appraisers… yes, your work. In their fuzzy logic, it’s a “Comp” considered for your report if they say it is. It is not!
A true “Comp” is a property viewed and/or analyzed by a real living, breathing, mirror fogging appraiser. An appraiser who compares sold property against the subject property in terms of multiple features, characteristics and amenities. It is not determined by an AVM. It is not determined by an algorithm within the vast bowels of FNMA. Until the property has such analysis done by an appraiser, it is merely a SALE…it is not a “Comp”.
This FNMA lie really became evident to me yesterday (4/20/15) when FNMA released a news release. The news release was about how CU has been integrated into their on-line Desktop Underwriter software mortgage lenders use. You can read it here
Within that news release is this quotation from a VP at a mortgage lender:
“The collateral information that CU provides is invaluable and simply staggering,”
said Breck Tyler, Executive Vice President, Trustmark Mortgage Services.
“CU has aided in providing important comparable data that was previously unavailable or very difficult to get. CU messages in DU will help streamline appraisal review and make the underwriting of an appraisal a much more informed process.”
Then today, FNMA released info directed to Correspondent Lenders who intend to use the CU process in UCDP, but don’t intend to sell the loan to FNMA: https://www.fanniemae.com/content/fact_sheet/collateral-underwriter-non-seller-implementation-guide.pdf
which has this statement:
“Fannie Mae does not instruct or suggest to lenders that they ask appraisers to address all or any of the up to 20 comparables that are provided by CU for most appraisals.”
I want to repeat what I said above in case you missed the point: A PROPERTY IS NOT A “COMP” UNLESS YOU DETERMINE IT IS AND INCLUDE IT IN AN APPRAISAL REPORT. Otherwise it’s just a “sale”.
If you’re an appraiser who liberally uses the word “Comp” in place of a “property sale”, I would ask that you be more careful. If you receive info from a lender, AMC or anyone else who asks you to look at the “Comp” they have provided, correct them. Use the words “sale property” until you have determined that it truly is a “Comp.”
I’m also asking members of appraisal organizations and associations to communicate your concern about this lie perpetrated by FNMA directly with them. Ask FNMA to change the word “Comp” used in their CU Reports, news releases, instructional materials, etc. to “Property Sales” so that there is no misunderstanding about the significance of this issue.
If organizations and associations won’t do that on behalf of appraisers, then we might as well kiss the profession of residential real property appraising goodbye. Because if a list of ‘sales’ are considered “Comps” then an actual human appraiser won’t be needed to provide supportable property analysis and market value reports.
So, you may distribute this message to anyone.