All your comments are correct from an appraisal point of view. The problem is that truth and reliability is an appraisal goal and the goal of PAVE is social engineering. I guess the powers to be think if you artificially increase the value of homes and the resulting loan amounts in a given neighborhood then the average income in that neighborhood will also rise to meet the higher payments. Seems to me that is what happened between 2000 and 2012 and how did that turn out.

Of course location matters (well we all thought it did before Maxine got involved). We have situations here that involve an older improvement on a canal that leads to a river that gives access to the Gulf of Mexico. FANNIE’s algo will send sales 20 years newer in a gated community within 1 mile with no access to the waterways. Not at all the same thing! I was always taught I should utilize the rule of substitution when selecting comparables. Just being proximal does not mean comparable. I can show you areas where the values range from 200k – 2,000k – within a mile of each other. I do every Appraisal as though I was going to buy the real estate. Which others would I consider and why. What is driving the buyer? What are the major marketing points? Just going to the same shopping center does not make a comparable. Good luck out there!

I always was taught comps should be within 1 mile or less of the subject, if you had to look elseware it should be in a comparable neighborhood, with similar properties. Location, location, location.

All the more reason why I will probably retire after this year and after 49 years.

This is a little like the government saying “the way to combat cancer is to stop allowing doctors to render a cancer diagnosis”. As appraisers we report the results of governmental policy and as the saying goes, “don’t blame the messenger”.

Location/proximity is the #1 important part of value; hence land value/location.

Location, location, location!

“steps federal agencies can “take using their existing authorities to enhance oversight and accountability of the appraisal industry and empower homeowners and homebuyers to take action when they receive a valuation that is lower than expected.”

This is akin to giving a drunk 16 year old the keys to Ferrari. I’d just rather they’d be honest and say “if you dont appraise ant contract price, you’ll be turned into your state board, sued, fined, or all the above.
One more nail in the coffin….

https://www.aei.org/research-products/report/comments-on-the-pave-report/

The government refuses to recognize the real cause of the wealth gap which is the income gap. Instead they help people with less income and less money take on more debt which they can’t easily afford. This can cause these people to lose their homes and be worse off financially in the event of any family emergency or a change in the economy.

The PAVE report and Federal government worked directly with private parties who have an agenda. They worked with Jillian White of Better.com Mortgage and Lisa Rice of the private non-profit Fair Housing Alliance. These people have promoted the false narrative of the “racist white appraiser” for their own agendas of respectively procuring business and grants.

The PAVE report and Federal government are also working directly with businesses who would benefit from the lower cost of AVMs. The cost benefits aren’t passed onto the borrower but pocketed as profits for business. We all know AVMs only are somewhat accurate with the absolute average home. AVMs don’t see condition, upgrades, actual current size, actual current bed/bath count, view, specific location in a neighborhood… because they don’t have that information. It’s GIGO, Garbage In Garbage Out. Homes with full views that are fully remodeled will be under appraised with AVMs while homes in fair C4-C6 condition with negative location factors and no view will be over appraised.

The government needs to look at real data from unbiased sources in order to help people. They need to stop blaming appraisers for differences caused by other factors. It makes them look totally incompetent.