Client Supplying Comps

Accepting CLIENT Provided List of Comparables - Client Supplying Comps

CLIENT provides the appraiser with a list of comps…

I’ve heard about this practice, but this is the first time I’ve actually seen it ‘in print’:

Do you supply a list of available comps for each order?

Yes, in most cases. Click the “Comparables” button while completing the form to view and select available comps. This will save you significant data entry time.

Please note: Option only available for BPO and hybrid valuations.

client provides comps

I was doing some on-line research for a potential new client which provides a wide range of services to the mortgage industry, including appraisal, and found this statement among their Q&A document. Caused me to step back and ponder this situation, and evaluate whether to accept them as a potential client for my business.

Keep in mind, clients can do anything they darn well please, and ask for the moon if it suits their needs, because USPAP does not apply to them.

But when it comes to appraisers, ‘we’ had better be very careful and properly evaluate the presented Scope of Work, assignment conditions, and other info a client provides…such as a list of ‘comparable’ properties to potentially use in an appraisal… and a hybrid valuation report is one that appraisers can do.

Per USPAP, appraisers are expected to provide their valuation opinion without bias or coercion in a way that favors the client or parties to the report. Our independent opinion is supposed to be provided based on OUR own research and analysis, irrespective of what others desire.

When an assignment client provides the appraiser with a list of comparables, that borders on coercion and may be considered intimidation from the client toward the appraiser. There can be an unwritten expectation that the client-provided comps be either the ‘only’ properties to include, or else must use one or two in the report to make it seem like the appraiser has done their own research.

This is NOT the same when a sales agent provides the appraiser with MLS print-outs of properties. The agent is not the appraiser’s client, even though the agent may represent a party to the transaction. Most appraisers will respectfully accept the MLS print-outs, and then analyze them for potential use. I, for one, don’t have any qualms about asking agents for properties they consider to compete with the appraised property when I find issues with supporting a contract sale price.

But when a CLIENT presents the appraiser a list of properties as comps, and basically says ‘use these’, it’s an entirely new ball game.

I would encourage appraisers to be very cautious about accepting CLIENT PROVIDED comps for any assignment. Per Dodd-Frank, mortgage lending assignment clients are supposed to have an Appraiser Independence Compliance contact person you can call. If low level clerks push you to accept ‘their’ comps, then you should talk with the compliance person before accepting the assignment.

“Let’s be careful out there.”

Dave Towne
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Dave Towne

Dave Towne

AGA, MNAA, Accredited Green Appraiser - Licensed in WA State since 2003. Dave Towne on

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17 Responses

  1. Avatar Bill Johnson says:

    We’ve all seen it right (reconsideration of value/tidewater), you know where the appraiser is copied in the e-mail chain and the loan officer (Representing the client), agents, borrower, home owner, pool guy, etc. team up to supply us with better comps? In a way I applaud the above board effort of this client Dave (still wrong), but rest assured, our lender clients have no problem providing assistance to push the deal through.

    Seek the truth.

  2. I won’t do an assignment for which I do not use my local MLS. How do you know all the relevant comps are being given to you if you work in an AMC’s portal and select from a list of “comps”?

    I feel this is also a backdoor way to get appraisers licensed in a state to cover pretty much the entire state (or multiple states) without having local MLS access. You may get appraisers who know little to nothing about the market making value decisions.

    Lots of companies are pushing Hybrids and the other associated “alternative” products. I am just waiting for the shoe to drop next housing downturn. How much you wanna bet when losses start happening due to reliance on these products the appraiser will be in the cross hairs? A good lawyer holding a copy of USPAP in their hands would be able to ask an appraiser some very pointed questions about why they even completed the assignment in the first place…

  3. Avatar David Laufman says:

    They can only supply sales, the appraiser decides what is comparable. Did they REQUIRE you use only the sales provided? If they did, that would be an unacceptable assignment condition in my book. Just giving a list of sales is not coercion, just data. It is up to us to decide what is comparable. I would ask how they qualified their list of sales to see if i should bother reviewing the data. A list of sales is not coercion. If the requirement is that you use only those sales, well that is just unacceptable.
    I should also state that I do not do hybrid appraisals or BPOs

    • Avatar Koma says:

      Well said David.

    • Avatar Bill Johnson says:

      Technically you are right David, but in my experience 99 out of 100 times the lender provided sales clearly show what our clients intentions are (THEY WANT HIGHER VALUES). When VA form 1805 most often shows (line 34) a Refinancing Amount of Proposed Loan, what percentage of the time do you think an appraiser would receive a reconsideration of value request if the appraisers market value is equal to or exceeds that number (near 0%)? Are you going to get more or less reconsideration requests if market value is below the proposed refinance amount? Required or not, history shows us (blacklisted, withholding of payment, reduced future work, etc.), that although the appraiser can win the battle, we will most certainly lose the war. One more thought, when the assignment is for a refinance (no agents), and the lender is 48 states away, but locally the borrowers meets with their LO, who do you think is pulling data (sales/comps) to try and attempting to influence the appraiser?
      Please VA, stop providing a proposed refinance amount.
      Seek the truth.

      • Avatar David Laufman says:

        Bill, your point is what? That everybody else’s definition of Market Value is the” highest” sales price, where our definition is the “most probable” sales price. Everybody’s interest is different, so what. That is the real world of real estate. Data is not bad or good, it is data. Where good data comes from doesn’t matter. Now, agreed, lenders, borrowers, real estate brokers, and owners data is slanted is typically slanted to a specific result. With that understood, it is still up to us to determine what data should be used. If its good data, use it. If its garbage like most submissions, don’t use it. The original posters assertion was that the sales submitted were required to be used. In 35 years, I have never used a sale as a comp because I was forced to.

        • Avatar Bill Johnson says:

          Call it a supply of comps, sales, or in the case of the VA (proposed refinance amount), my point is that appraisers are still pressured before (fee & turn time / lowest number wins the bid / a provided refinance number to hit (VA)), during (authors example comps/sales provided by the client), and after, reconsideration of value (99% of the time higher value wanted), sales/comps provided. Does anybody here remember Chase Bank, and their letters claiming appraiser guilt (removal from panel), unless appraisers can prove their innocence?

          The big conversation David, is that undo influence is still alive today.

          Seek the truth.

          • Avatar David Laufman says:

            Yes it is Bil, no argument there, but market participants have always been the same. We were always pressured and a lot of it was blatant. When I had a lot of clients and one got pushy, I got rid of them and tried to add a good client. and so on and so on. What has changed is that the amc world has been a lot more discreet about the influence, even though it is still there. And also we do not have the ability to walk into a thousand offices to solicit our services anymore.

            Just because someone gives you data, does not mean it is undue influence. Forcing you to use it is when it becomes coercion. amcs do it very discreetly, but I know it is still there. RE brokers, well they are advocating for their client which they are allowed to do.

            • Baggins Baggins says:

              Amc’s are advocates of the lender and like you state, are getting better at concealing that advocacy.

              What good is separation from loan production if we still get our paychecks from people whom advocate on behalf of the lenders commission based interests? Amc’s, the long arm of the lender.



  4. Ross Grannan on Facebook Ross Grannan on Facebook says:

    Add it to the work file, accepting sales from anyone isn’t coercion. 99% of the time I already pulled the same comps as the realtor or borrower. If there is something that is off that was provided make sure you consider what is offered and make sure your narrative backs you up, especially if it is a limited market.

  5. Retired Appraiser Retired Appraiser says:

    They should be fined $1000 for every comp they attempt to “supply”.  That would put an end to this BS.

  6. Avatar chris says:

    I hear this….they are looking for the idiot appraiser that says to himself….”hey…great !!!, Now I don’t even have to do research anymore !!!”

    Maybe it’s for those “far away” low balling appraisers who might not know he/she needs to look at the neighborhood MLS board cross over for additional sales data,

    The games are still being played….money, money, money… guys realize they really don’t like us, never have, never will. We make money doing our jobs, and because we do our jobs they don’t make any money.

    Just another day in the office…. Last week I was ordered an appraisal for a house I appraise the year and a half ago, somebody told the homeowner that is house went up $70,000 in 18 months.

    The owner told them he would not pay for the appraisal, smart man. Now I have data supporting only a half a percent increase in Market values over a year-and-a-half.

    And I got paid for a no brainier appraisal by these morons!!!!

    We all make half of our money on their stupidity !!!

    Keep them coming !!!!

    • Baggins Baggins says:

      You’re downplaying the gravity of your position and the magnitude of their mistakes.

      Largest investment of people’s lives, everything on the line, longest financial commitment they’ll likely ever engage in.

      The appraiser functions as an essential separation of power and check to the balance.

      You earned your money that day. Many ethical realty and lenders argue, we don’t need the appraiser. They’re overlooking why the human appraiser is so essential, not everyone is as ethical as the next guy.

      Not directed at you, but for appraisers whom don’t take their job very seriously, casually outsourcing and buying these constant tech solicitations regarding improving earnings and increasing volume, there is always a price to pay. Rolling the dice is just not my thing.

      My signature. My conclusions. My research. My unique hand written statements. My photos. My sketch. Personally inspected. There are so many easier targets. There is a world of understanding about an individual’s personal ethic, based on the very basics of how they structure their business and how they posture their solicitations. Mind you now, the below is just the tip of the iceberg, the worst offenders whom were picked. Millions more go under the radar in terms of private settlements, denial of service, loan rejection, etc. Those interested in big dollars should do themselves a favor before it’s too late and scoot over to sales. Despite what they may have told appraisers, appraisal is neither glamorous nor exciting, and there is no easy avenue to simply double up and increase income.

      FBI Financial Institution/Mortgage Fraud News

  7. Baggins Baggins says:

    I’m chain smoking right now at the desk. Yes, I know that’s poor form and I rarely do that. Too cold in the garage right now.

    It’s a tough consideration and judgemental call, to harbor ill will to those whom take advantage of others, and seek to suppress us personally. Don’t wear yourself out crashing against that wall, it will always be there in one form or another. This is the difference between holding a license as an individual or not, personal accountability. They’re just disposable process clerks, nothing more.

    Just market down the top 100 lender nationally and top 10 statewide lender lists, discover who assigns directly without the use of amc’s, give them top priority. It only takes one or two reliable client connections to form a stable appraisal business. Or work from the bottom up, that’s also interesting, fill in orders have their time of day and value as well. Also boutique lenders often do hold to direct assignment protocols, they don’t play with volume and every request is precious to them.

    What you do not do is work with companies whom seek to supply comps, do not have a solid understanding of what the appraisal fee should be (requesting bids rather than providing up front fees), etc. And if you have to make a tough decision regarding lender prioritization, always choose the one whom hires a qualified actually licensed appraiser as the appraisal distribution manager. It’s not rocket science, don’t let them keep you down. If the solicitation does not move, simply leave them your flyer or card and let them know you’ll be available as soon as they move away from amc’s. Stay organized with a manilla folder and paper printouts for every solicitation attempt, you will refer to them later and may be surprised to find opportunity had been formed and all you needed to do was play the field and wait for the inevitable staff turnover. If I pick up the phone, having honed in on a winner, I usually make that sale. Simple. Easy.


  8. Seemingly innocuous-client, agent, owner supplying comparables they think may be relevant. A time-honored tradition and legitimate appraiser consideration.

    EXCEPT when they go so far as to include them in the report template in a way that encourages their use over independently searched and analyzed comparables on the bass of “Saving so much time”!

    WTH! How about just filling in the value as well? I’ll say it one more time “There is no USPAP compliant bifurcated hybrid / BPO combo out there. It does NOT exist.” For TAF to foster the myth that it does is disingenuous and a disservice to appraisers that want to do a good job.

    • Avatar Koma says:

      Mike I agree. I’m good but not that good and will accept client, agent, owner supplied sales. 99.9% of the time I’ve already seen them anyway. Also, when they provide them and say comparables I remind them no they are sales, they are not comparables until I determine them to be.

      I just hate now they run automated searches without looking at them and then send over a dozen instead of two or three. And Oh Boy some of the junk being sent is ridiculous. Like subject SFR year 1920 and they’ll send SFR years 1980-1990 or one with a year 1920 but that contains 2 apartments…etc..etc.

      I’m thinking we’re in for a heck of a lot work coming into the next crash.


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Client Supplying Comps

by Dave Towne time to read: 2 min