Inspections and Comp Photos During a Crisis

You should know, I have opened up a special folder for all of your hate mail that will surely come after you read this post.  It is round and has a plastic liner for easy take out. Though I fully expect to be vilified, I would ask that you have an open mind to what I am about to say. 

Let’s start first with a few anecdotes.  Last summer, after a long and hard search to find a reputable dentist, I finally found one and went for a checkup.  X-rays were done on my teeth (a very important piece of information for the dentist to have, I would suppose), but they were not taken by the doctor.  Three weeks ago, I turned in all my receipts, financial statements, and W-2s to my CPA. I did that. Emailed them myself. Finally last year, I had lunch with a truck-driver friend of mine.  As part of the casual conversation, he said he never loads his own truck, but he is 100% in charge of making sure it is done correctly. For someone driving an 18,000 lbs missile down a public road, I think he ought to make sure it is done right.  I assume I could make similar statements of relying on others for important tasks, data, and information on just about every profession out there; attorneys, electricians, teachers, retailers, pilots, politicians, journalists, software engineers, real estate agents, and even scientists.  

I realize the target I am paining on my back by daring to question the ‘normal way of doing things,’ but I believe the daggers being thrown are by scared and insecure appraisers who do not value themselves or understand what value they personally bring to the table.

Let me establish a few facts;  first, USPAP does not require an inspection be done by the appraiser of the subject property.  In fact, USPAP does not require an inspection at all. Second, USPAP says nothing of comp photos.  Finally, contrary to popular belief, not even Fannie Mae requires comp photos. It’s true (Reread Scope of Work number 3 on the URAR – but read it carefully – if you don’t believe me).  

As I write this, we are in the midst of a global pandemic.  Many states have “stay-at-home” orders and, for a large number of assignments, the scope of work is being modified to change how we gather subject and/or comp data.  This change to the way we normally do things is causing some heartburn among a minority (though very vocal) number of my peers. I have heard the argument 1,000 times; “Dustin, if we change the SOW now, it puts us on a slippery slope to the ‘new normal.’ When this is all over, we will not be relevant because our clients will realize they can get data from other sources.”  To this argument, I say “Good!”  

Stick with me. 

For good reason, USPAP does require we have good data to analyze and make the conclusions we make. Credible data is the key to a reliable appraisal and subsequent appraisal report. Remember where all this ‘normal’ came from in the first place.  It is the clients who, over the years, have increased scope creep and put us in a little box where it is accepted practice to personally inspect each subject property and take real-time photos of the comps we use. And, if I dare say so, it is about trust.  By and large, our clients (at least in the lending world) do not trust us. Fannie Mae asks us to drive the neighborhood and comps, but the client says, “take a picture so we know you actually did it.” Frankly, it is insulting.  

Are there good arguments for the appraiser personally seeing the inside of a property? Of course there are; REO and luxury properties come to mind, for examples.  Are there insights to be gained from driving comps? Naturally; a subdivision just outside of Jackson, WY might be a good example, where values are impacted by placement on the hill and the types of views (incidentally, the neighborhood is gated and cannot be accessed legally anyway).  The point is not to say an appraiser should never need to inspect a home or drive a neighborhood. Perhaps in the majority of instances, those might be wise, but shouldn’t that be the valuation expert’s call?  

Due to health and safety concerns during the Covid-19 pandemic, many provisions are being made to change scope of work protocol.  Some are ignorantly defending inspections and comp photos – not as being important to the appraisal process – but as a defense for why appraisers are important to the valuation process overall.  In other words, I hear many crying, “If the lenders allow appraisers to get information from another party, perhaps they will not see the value of having appraisers at all!” To that I say, if the integrity of the appraisal process is not harmed by outsourcing some of these aspects (or eliminating them all together), I’ll raise a glass.  I am reminded of The Broken Window Fallacy by Frédéric Bastiat (look it up if you have not recently read it).  

Again, I am not saying we should never inspect homes or drive comps. I am making the argument that the appraiser – the professional – should be allowed to make that call.  Afterall, they are in the best position to know whether or not it is warranted for each assignment. Think about how it is with private appraisals. Sometimes I do a desktop. Sometimes I do a drive by. Sometimes I send an assistant to do a walkthrough or take comp photos. Sometimes I do it myself.  The point is, each assignment is unique and the professional makes the call. For more information on this topic, see The Appraiser Coach Podcast #338 with Ernie Durbin.  

Last night, I took my beautiful bride of 24 years on a “date.”  With the shutdown, the night on the town consisted of calling ahead, picking up our food, and eating it in an abandoned mall parking lot, but at least we were able to spend a few hours away from the kids.  As we were leaving our neighborhood, I noticed a man taking photos of one of our neighbor’s houses. “Looks like an appraiser,” I said to my wife. When we returned from our spectacular dinner-date, I noticed a for sale sign in that neighbor’s yard.  So, it wasn’t an appraiser afterall, it was a Realtor; or was it? The name on the sign was that of a female neighbor who is an agent and lives across the street from the home going up for sale! Even though she lived 12 steps from the house she was listing, she outsourced the photos to another individual.  Her time was better spent marketing the property, not taking photos. She gets it.  

Appraisers, we are professional analysts not data gathering interns.  If you are worried about your job being outsourced to technology or other individuals, stop looking at it as your ‘job.’ You are a professional and this is a profession.  Professionals focus on where they are most needed and can contribute the most value to the process and delegate the other important roles to well trained employees/contractors or modern technology.  

In conclusion, let me share with you two stories.  On Thursday, I received an email from a borrower detailing the specifications of her home.  She also included 3 pictures showing all sides, the shed, and every room inside (from different angles).  Using her words, photographs, an expired MLS listing, county data and some carefully worded assumptions, I was able to complete a 1004 desktop for a client. 

On Wednesday, I spent just shy of two hours driving around Salmon, Idaho getting comp photos for an assignment.  I ended up with six pictures of mailboxes, driveways, and No Trespassing signs and ended up supplying the client with MLS photos so they could see the homes I used as comps.  The worst part was, I knew that is what I would get before I even started my journey.    

So, what is your point, Dustin?  Glad you asked. If we want to be viable now and into the future, let’s spend our energy promoting our true worth.  We are professionals. If we want to be seen as such, let’s focus on the part of the process that sets us apart from AVMs, BPOs, and Zillow.  By and large, what we offer to the valuation community is not data gathering. Before you get too defensive of your inspections and comp photos, consider what your real value is to the process. 

Though your weight and blood pressure is important data for a doctor to know, the doctor doesn’t weigh you or put the cuff on your arm.   

For more information on this subject, please download and listen to The Appraiser Coach Podcast Episode: 528 During a Pandemic, Are Comp Photos And Inspections Necessary


31 thoughts on “Inspections and Comp Photos During a Crisis”

  1. Gary Phillips

    You sir, are correct, “rural comp” photos are the biggest waste of time, energy, money and gasoline. Cant tell you how many times I have pictures of mailboxes, long driveway and no trespassing signs. Then an underwriter 900 miles away says “use the MLS photos”.

    Thanks for your time

  2. I agree with you 100%!

    Specifically, my biggest argument has always been with comp photos. Now, I make a habit of taking my own comp photos as close to the sale date as possible as soon as the sale data becomes available. I’m a one-man operation and my system works very well for me. Note: With FSBOs, that could be a couple of months after the sale date.

    75% of the time, I’m able to use these photos. However, with an FHA assignment, to meet their scope of work, I have to drive around and take a new photo of a comp every time I use it. That makes absolutely no sense!!!

    If the house sold in July and I took a picture of it the first week of August, and then use it as a comp the following November, December, February and March, which pictures best represent that sale from the previous July?!!!!!! When I took an August photo or the following four or five photos I took every month through the winter time?!!!!

  3. As Appraisers, we are slaves to the lenders. We don’t have a large enough coalition to make a difference. Our “independence” is working against us when we try to work “together” for a common cause. We all know driving comps are ridiculous sometimes, but if the lender wants them, we provide them. We aren’t taken seriously. We don’t even take ourselves seriously if we can’t find the strength and numbers to work together as a group…rather than independents.

  4. Chris Williamson

    I agree comp photos are not essential, but the subject inspection is th emost critical part of an appraisal IMO. I assume the person at the doctor that takes your blood and vitals is an employee of the doctor and been trained by their staff? Or does your doctor take your word for what you BP and heart rate is?

  5. The worst part is that the lenders don’t realize that these rules about comp photos came about years before digital photos and email came into existence and none of the rules or certifications have been rewritten since. Even the language on the 1004 hasn’t been updated for over 20 years, here in lies the true problems with technology and the crooners that still run the industry.

  6. Victor F. Andrews

    Right on, Dustin! Remember back when we even ‘typed’ our reports too? We finally let go and delegated that portion of our profession and we became more productive! We can be even more productive and we may be forced to, if we focus on our expertise in solving the actual valuation question or problem, allowing others we train or trust to provide ‘services’ including the inspection, measuring, photos, etc.

  7. Your point: It is the appraiser’s decision (or it should be) as to what is provided in the report, within USPAP regulations.
    A comment that we are “slaves” to lenders is correct. But suck it up of you want to do work for AMCs or lenders.

  8. I agree with photos of rural properties, but Dear Dustin since you know me you know that I do complete rural appraisals. I don’t care about the property photo from the street but driving those communities and the sales are key to understanding if I am on 3 miles of knock your fillings out dirt road or on a road that may not be all weather but is navigable, plus it allows me to understand topography, vegetation, overall site utility, type of fencing and god for bid the neighbor being able to access their property across the subject site without an easement or a barn that is not exactly in the right place. For me driving rural properties is necessary, so sorry for not being on your side on this one. Can things be outsourced, absolutely, but I find it mildly amusing that the appraiser is in control. Not sure that I agree with that item. Yes we can control what we are willing to do, but my recollection is that most lenders don’t really care about our thoughts, just get the appraisal but whatever means, most time it is cheap and fast terms. The key to all of this is what data is the AVM going to use, will it be before March 15 and the Feds dropping the funds rate to essentially 0 or will it be after. That is the true question in all this, Now that gets to us being professionals and what does the general market really need us for. Hmmmm film at 11 as they say. By the way if I in the circular won’t be the first time that has happened. Have had several lenders tell me they couldn’t use my report because it didn’t support what they needed. Thank goodness 75% of my business is non-lender based, don’t have to deal with all this craziness of AMC’s. But I do have to deal with attorneys and judges who might not be so savvy on RE but do have their own thoughts on how things should be done, they just don’t get into values until the gnashing of teeth in the deposition. Take good care and if you hear an echo it will be me at the bottom of the circular. Stay safe out there appraisers who are still doing interiors.

  9. In the 80’s appraisers were blamed for the real estate market crash, saying we were unregulated and unqualified and we got state regulations/licensing and ‘continuing ed’. In 2008 we were once again blamed for the housing bubble saying we were less than honest and influenced by loan officers and we got the Dodd-Frank act. This using 3rd party data for inspections will eventually be used to blame us for the next crash. Mark my words! By the way, my base fee is $500 and I’ve been asked to do appraisals using 3rd party inspections FOR ONE HUNDRED DOLLARS! Explain to me what “professional” is going to do them for that price!

  10. I agree with Brad Bassi. I can’t tell you how many times I drive to a comparable and THEN I figure out why it sold for more or less. There is a lot that can’t be seen from photos and aerials. I did a waterfront yesterday and didn’t think it was worth the pending amount until I got there. Once I saw the place, it gave me a better feel for why it was so much higher than the comparables which I also drove by. Had I not driven to the subject and comparables, I really don’t think that I would’ve analyzed the data correctly. I do agree though that in rural areas where you already know the comparable cannot he accessed, is a waste of time.

  11. diana r kanitz

    Bravo Dustin, i am in total agreement
    Comp pix are the biggest waste of time
    For years they have not allowed our interns to do inspections, these people are hand picked and TRAINED by us, now all of a sudden with the bifurcated products any Bozo with a pulse can do the inspection, now with the bifurcated products MLS pix are OK
    WHAT HAS CHANGED, i’ll tell you what has changed, they want faster and quicker, they think bifurcation will accomplish this, so now all of a sudden MLS pix will do, idiots can do inspections, the need for a valid valuation has not changed
    As appraisers we already had a bifurcated process, i had interns doing inspections and typists typing the report and i did THE APPRAISAL
    They wonder why we don’t take interns and where is the next generation of appraisers going to come from, the answer is, interns aren’t of much use because they can’t do inspectons
    As for MLS pix, they MORE accurately reflect the condition of the property at time of list/sale, not 4-6 months later when we use it as a comp and it has been repainted, etc. Especially in retro appraisals, the MLS pic should be used, i have been by a retro comp and not even recognized the property due to renovations after the purchase which could have been years ago



  13. Here we go again. *sigh* The issue is NOT with “others” supplying “data” (be honest, we all mean photos for this discussion) – the issue is that this data (photos) is being provided to the appraiser to utilize in the Appraiser’s report, mainly by unknown / undisclosed parties. This data (photos) becomes something that is utilized in our analysis and ultimately affects our opinion of value. It’s NOT just someone else taking the photos like your example of the broker friend…and we all know how brokers take photos anyway, so I won’t get into that.

    -These photos are supposed to show us details of the property that we are unable to determine via other sources.
    -These photos will shape our opinions of the construction quality and condition.
    -These photos will result in being utilized ultimately to make ADJUSTMENTS in our reports.

    Question; Why is the lender not just ordering a standard Desktop or Drive-by appraisal and having the photos taken by a third party (homeowner, broker, lender hired person from the internet) sent to the lender directly to include in their loan file?

    Think about it…will every homeowner trying to get a refi include photos of the holes in the wall behind the door?…the water stained ceiling?…the worn carpet?…the leaking faucet causing wood rot inside the cabinet?…missing shingles on the back side of the roof? Will every refi homeowner say honestly that the HVAC system is not working? Will every homeowner trying to sell his house? Will every broker? Will an untrained, unlicensed party really understand the nuances of quality and condition well enough to provide accurate photos of any issues affecting those factors? It’s up to us as the Appraiser to decide.

    The Appraiser is responsible for the decision to rely on third party info. The signing Appraiser is REQUIRED to have a reasonable basis for believing those PERFORMING the 3rd party work are competent. The signing Appraiser must have no reason to doubt that the work of those individuals IS CREDIBLE. (notice I said the signing Appraiser….see USPAP 2020-2021 – Pg 24 – lines 729-733)

    While you are correct that ANY inspection of the subject property is NOT REQUIRED under USPAP, including an inspection is part of the agreed upon STATED scope of work for the assignment AND part of the scope of work decision by the Appraiser in order to produce a report that is not misleading and is credible. It remains the Appraiser’s decision as to whether an interior inspection by the Appraiser themselves is required. If you decide it is, and the lender will not agree to modify the engagement, then decline the assignment. The same goes if an Appraiser decides that an interior inspection is NOT required to produce a credible report. Example : Let the lender / client know that you are no longer performing interior inspections due to the Covid-19 issue, but you are able to produce a credible report for the subject without it; possibly by a desktop or drive-by report.

    The PRIMARY reason for inspecting the subject property is to gather information about the characteristics of the property that are RELEVANT TO ITS VALUE. (see USPAP 2020-2021 AO 2 – pg 68, lines 30-32) So lets not deceive ourselves that 3rd party photos will not be considered in our value opinion.

    Whether the inspection is performed by the signing Appraiser, another Appraiser, or a 3rd party, an Appraiser MUST ensure that the degree of inspection is sufficient for the Appraiser to understand the subject property’s relevant characteristics, so the Appraiser can develop a credible appraisal. (see USPAP 2020-2021 pg 69 – lines 73-86)
    ***Always remember to state what you did and didn’t do in your report in regards to a personal inspection.

    Now someone will usually bring up the “extraordinary assumption” (EA) argument about now. Please understand that as an Appraiser, you can NOT “extraordinarily assume” your way out of your RESPONSIBILITY to produce a credible report that is NOT misleading OR your LIABILITY for the contents of your report. Some appraisers seem to believe that as long as they fill up their report with paragraphs of “extraordinary assumptions” it relieves them of the liability…it does not. (see USPAP 2020-2021 pg 290-291 – FAQ #243 – “Employing an Extraordinary Assumption when a Client Provides Inspection Data” – NEW to USPAP)

    While too lengthy to quote here, this FAQ is very applicable to this discussion. It does state…

    If an Appraiser determines that the information contained in an inspection report (provided by a 3rd party) is reliable and allows the Appraiser to identify the relevant property characteristics and develop credible assignment results, then an extraordinary assumption would not be necessary.

    However, AO 2 includes additional language relating to EA’s related to the Appraiser’s decision to determine the degree of inspection needed to be sufficient. FAQ #244, pg 291, “Can an Extraordinary Assumption Be Used Without a Reasonable Basis?” relates to USPAP Standards Rule 1-2(f)(ii) and is also NEW to USPAP.

    OK…now I’ll wrap it up…apologies for the long post. 🙂

    I include all the previous USPAP references for ONE REASON GUYS…
    To be sure we are all aware of our responsibility and liability. I agree that right now, we are all wading through new territory for several reasons; new inspection issues as a result of “bifurcated” appraisals, and as a result of Covid-19 just to name a couple. We all need to weigh multiple factors and decide for ourselves just how to approach these inspection issues. Just do it with an informed approach and don’t let yourself be talked into doing something you may regret later. Just as it’s always been, WE AS APPRAISERS WILL BE THE ONES HOLDING THE BAG WHEN IT ALL GOES TO CRAP LATER ON.

    Since Covid-19, in my area at least, lenders are NOT ordering desktops & drive-bys as much as FULL INTERIOR inspections. They realize that as many people remain out of work because of the “stay-at-home” executive order, there may be a possible increase later of defaults. They have decided to cover their butt now…we need to do the same.

    Stay well, stay safe all.

    P.S. re; the “suck it up” comment…Nah. If I’m gonna do something requiring “sucking it up”, it won’t be something I can go to Federal Prison for. ¯\_(ツ)_/¯

    1. Dustin does all of this LayDeeTee and still kicks out 4 to 9 appraisals a day. If you don’t believe me, he’ll sell you a VHS tape describing how the Philippines is the answer.

      I’ve never trusted my clients, and just because they say you can do a desktop 1004 today and all is good (just explain everything away), good luck in front of that review board in a couple of years when your work file is as thin as a supermodel.

      Seek the truth.

  14. Charles Urquhart

    Driving by the comps is required by the FNMA form. If we don’t like it we should try to get that changed. Appraisers that don’t drive-by comps save time and may be able to complete assignments faster than appraisers that drive-by the comps. This potentially puts the appraisers trying to do the “right thing” at a competitive disadvantage. Isn’t it as simple as that?! The playing field needs to be level.

  15. Fannie Mae does require comp photos as an exhibit, please read the selling guide-Exhibits for Appraisals states: Clear, descriptive photographs showing the front, back, and a street scene of the subject property and the front of each comparable.

  16. Well said! No darts here. I just had a client email me 3 times advising an appraisal was ‘due before 5’ today. I responded that ‘the appraisal is ready and has been ready for 2 days! I simply need to find the time to drive 2 hours to take photos of my comparable properties, ALL of which are better represented by MLS photos anyway because they actually represent the what the properties looked like at the time of their transaction. After 3 hours in traffic I returned to my office and sent the report out 30 minutes before the deadline. STAY SAFE OUT THERE.

    1. John, how can you be 100% done with your analysis and thus form a final opinion of value without verifying the data? Even if you see a driveway and take a picture, the drive to and viewing of the market area (day of / week of), is knowledge you should consider before forming an opinion. Appraisers are lazy, and often don’t want to see issues that make assignments difficult and or take extra time to complete. Don’t believe me, try being a big city appraiser where with A la mode and their peer sharing comp platform you get to see how other appraisers avoid complex issues. Its not unusual to have a comp be used by 20 other appraisers, where you get to see the real appraisers from the form fillers 4 to 9 appraisals a day guys. Backs to a freeway, no time for that, its neutral. That fake MLS picture from the roof, no problem I need it to be beneficial. The specific floor location for that condo, no big deal they are all on the 1st. Inputting the MLS GLA for that comp instead of exploring why public records are different, no problem follow the heard. That garage conversion, forget applying a cost to cure.

      Seek the truth, and stop ignoring it people.

  17. Randall R. Davis, SRPA, SRA

    This Covid-19 situation has given me time to consider how to get interior photos and know that they are actual and show EVERYTHING accurately to my requirements to make reasonable commentary and adjustments. Lightning struck a couple of weeks ago when my four-year-old granddaughter FaceTimed me to show me how she learned how to roll her tongue. What? It wasn’t the tongue rolling but the FaceTime. I touched the screen when she was showing off and a white button appeared on the right of the screen. I touched it and it took a picture. I got my daughter on the FaceTime and asked where did the photo go after I took it? She said look at your iPhone or IPad photos you Old Fossil. Bam! I did and there she was, tongue rolled and all. Enter the lightning! Why not try that with a driveby/exterior due to Covid-19? I was working on one and called the homeowner and asked if she had the ability to FaceTime and she said “of course, you old fossil”….(I added Old Fossil”). I was life-altering for me and my exteriors. I had drawn the house footprint and asked the homeowner to go to the front door and to reverse the view so she could point the IPad to where I directed her. As we walked thru the home, I had her turn on the lights in each room and to then show me the flooring, walls and ceiling. When I wanted a photo I just said “hold that view for a moment”, let the IPad focus and touched the button. I took 25 pictures from the basement, 2nd floor, and garage. I got multiple views of the kitchen, bathrooms, basement mechanicals and her cat. The photos were clear and no worse than if I took them with my camera. My only wish is that it’s too bad that the photos when I add them to my reports aren’t scratch and sniff……you know, to get the real feel of having been there to verify if the cat used the litter box or just sprayed wherever.

    1. Randall – it is possible to record a FaceTime video, so you can go back later and take screen shots from the video at any point. Just make sure the person on the other end knows they are being recorded.

  18. Randall R. Davis, SRPA, SRA

    This was a VA. We have completed many refinance and sale assignments this way. I have completed several with FaceTime pictures for several credit unions.

  19. Randall R. Davis

    I disclosed exactly what I did, how I did it and who was carrying the IPad around. I find this to be more factual than having the homeowner/occupant taking THEIR pictures. I feel far more confident in this process. Not as confident as an actual inspection but far more than owner supplied or MLS listing pictures. Practice on your house and test it out. You will be pleasantly surprised on what you get this way.

    1. Disclose all you want Randall, but the homeowner, your client, nor the VA will be by your side when your in front of the review board to explain your actions or non-actions.

      Seek the truth.

      1. Initially Guaranteed Rate created a no contact appraisal, ordered for any transaction not eligible for a 2055 or desktop, for FNMA or Freddie. Fnma just updated FAQ to say virtual inspection is not a full in person inspection. Killed Guaranteed Rates idea. I had one of the no contact orders and updated them, they switched to 2055. Doesn’t look like virtual inspection on something requiring interior inspection will fly. Seems FNMA has determined the scope of work for us again.

        1. Joseph, why would you even say yes to their hybrid of a hybrid of a product when their specific instructions indicated the following?

          Do Not indicate Desktop nor Exterior in map reference, follow traditional appraisal guidance.
          Do Not use the new Fannie 2020-04 LL modified set of instructions/scope of work statements.
          Describe at a high level any deviations from normal process with extraordinary assumptions and still complete “as-as” unless there are noted repair items or required inspections.

          In other words, they were asking appraisers to NOT modify the traditional 1004/1073 reports to say “Desktop”, nor did they allow appraisers to include the revised change in scope of work instructions. Good luck “describing any and all deviations”, and good luck in front of the review board defending your actions without such new protections.

          Seek the truth, read the small print, understand clients don’t care about you (it will be okay), and with the knowledge don'[t be afraid to say NO.

          Thank you Guaranteed Rate for paying appraisers the full fee regardless of desktop, or exterior, and thanks for offering hazard pay and or a temporary increase in appraisal fees.

  20. If you can form an opinion of value using a shared comp or from another source without actually inspecting the area and taking the picture (whether driveway or dwelling) you are not competent (and probably don’t even know better) but don’t worry 2 out of 3 appraiser’s aren’t anyway especially the ones with the weightless Institute designations who become reviewers and get the free ride for the rest of there careers.

  21. Wow; Brad Bassi, SRA, Very well said. I agree with you. Oh, you forgot about the pot farm, 10 foot fencing, no trespassing signs, video cameras, and the smell that is noticeable for miles.. Now here is the question, If I was an investor, I am buying loan packages as a whole, I want documentation. I want assurance that there is Collateral for the millions of dollars that are invested. As an investor, I have to think twice, about buying a loan package, that my auditor states there are no comparable photos. People are visual. Why not offer a good product!

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