Driving Comps Can Be Risky Business

Recently, I had a scary experience while taking comp photos. I live in a very rural area where there are a lot of people who are very protective about their private property.  The location I was headed to was a house about three miles down a private road.

The place was a bit off the beaten path, GPS wasn’t very accurate about where I was going. There was still snow on the ground and there weren’t really any visible markers to let me know where I was.  At one point, I thought I was where I needed to be and stopped at a large cattle gate.

The gate I stopped at was marked with a number of “no trespassing” signs and there was a camera pointed at me. Having a better view of the house from the gate, I realized this was not where I needed to be.  I was only out of my car for a few seconds and I didn’t take any pictures or anything like that.

I continued down the road and found the house I needed. I spent about 45 minutes taking the pictures I needed of a very large, luxury, custom home. On my way back out to the county road I passed the same gate I’d stopped at before.  However, this time there was a black SUV sitting there pointed towards the road.

The SUV pulled onto the road and started following me. It was kind of creepy.  I thought back to the podcast we did with Blaine Fine about safety and decided that the safest thing I could do would be to head towards a police station. 

The nearest police station, that I was aware of, was about 40 miles away and in the opposite direction of where I needed to travel.  My safety is worth more to me than being late for my next appointment so I decided to go ahead and head to that police station. I got to the county road and turned towards the station.  The SUV didn’t follow me from there so I continued for a few miles before turning around to head for my next appointment.

In the end, nothing happened to me other than being followed.  Whoever was in the SUV was very intimidating but they weren’t violent.  It was a scary situation though.  I was out in the middle of nowhere being pursued by persons unknown.

Yes, in this case, I was on a private road.  Since I had an appointment on that road and was expected, by default I had permission to be there.  I hadn’t taken pictures of that house I mistakenly stopped at.  I had done absolutely nothing wrong.

This particular situation is just an example. There have been other times when I’ve been chased down while I was out taking comp pictures, and not just when I was on a private road. I’m not the only one this has happened to either, I have heard from plenty of other appraisers that have similar stories.  I know some appraisers  that work in some neighborhoods where they won’t even pause to roll down the window and take a quick picture with their cell phone.

I’m not a fan of comp photos.  Yes, I’ve heard all the arguments about why they’re a good idea but that all just sounds like tradition to me. I know, we can’t be certain about external factors unless we drive the property. Those pretty little pictures on the MLS might not show that high power electric line or county water tower lurking at the back of the property.

The liability is on the appraiser and not taking the time to understand the area and the situation is an issue.  It is on you if you don’t do your due diligence and miss the fact that the subject backs up to a Walmart.  You have a professional responsibility but are comp photos worth your personal safety.

There is no requirement in USPAP to drive comps or to take pictures of comparable sales either.  You have probably been doing so from your first day on the job, but it is not required. It is really more about what is in the agreement that you have with your client.  If the agreement says you’ll drive comps, you need to drive comps. If the agreement says you’ll take up-to-date pictures of that subject, then you need to head out and take them.

As a professional you should be able to make the decision about whether those comp photos are needed.  You can make that choice to accept the agreement or not.  You don’t need to put yourself in jeopardy just to get that $450 fee.

Unfortunately, I don’t think that clients will start to back off of the demand for comp pictures until something terrible happens. Banks won’t start to realize that it’s very dangerous to be out there doing what we’re doing until an act of violence results in serious injury or death.  What can we do, as professionals, to protect ourselves while still giving the client what they need? There are many law firms that are helping injured victims located in Ormond Beach area to get over their injuries, even due to accidents. You can get their help.

For more information on this subject, please download and listen to The Appraiser Coach Podcast Episode 438: Are Appraisers at Risk when Driving Comps?

37 thoughts on “Driving Comps Can Be Risky Business”

  1. I would like to know the statistics of accidents caused by appraisers (us) stopping and causing traffic issues just for that comp photo. I hate it. Our photos do not represent the property at the time of the transaction or sale. Our photos make no sense at all, but I guess that’s why the banks want them. They are the masters of making no sense…

  2. FNMA and Freddie will have to change the pre-printed scope of work (3). I know this doesn’t specify photos are required; however, it does state that you inspected each of the comparable sales from at least the street. I agree with the sentiment.

  3. It will all come to a screeching halt when an AMC thinks they are doing extraordinary due diligence gets sued by the appraiser putting them in harm’s way.

  4. glenn pennington GA-82

    comp pictures had shot in my area, do not know if shooting at me. sound not the other way.

  5. Gary Phillips

    I agree 100%, I work a lot of rural areas in Missouri and people who live on acreage in the middle of no where do it for a specific reason and that is to avoid people like me. One of these days some one will get killed doing this stupid task and if I was the significant other of that person I would sue the lender, the AMC if there is one, FNMA or Freddie or FHA or VA all the way up to the dude sitting at 1600 Pennsylvania Avenue. After all he was the guy early in his campaign who stated he was going to do something about these low values in inter city neighborhoods.

    1. “Yes, in this case, I was on a private road. Since I had an appointment on that road and was expected, by default I had permission to be there.”

  6. Yes, I’m sure every veteran appraiser has their chased-down story, and when you’re in the boonies especially, it’s very troubling. I understand the rationale about, for example, noxious odors in the neighborhood that don’t show up on google earth, but as you said, our safety has to be considered in this equation too. March on Washington, anyone?

  7. Karen Koopman

    APPRAISAL REQUIREMENTS CHANGES BY FREDDIE MAC in 2017: Previously, copies of MLS photographs could be used for comparable sales only if the original photographs could not be obtained. Additionally, an explanation was required by the appraiser as to why MLS photographs were being used. .To provide flexibility and create efficiency in the appraisal and underwriting processes, we are removing these requirements and now allow clear electronic images, including copies of MLS photographs, to be used for comparable sales without an explanation from the appraiser.

    I put this statement in the appraisals that I don’t take the comp pics for. I have had no trouble.

  8. I state on all my fee request, my fee is for mls photos of the comps. Add $100 for real time comp photos. Don’t get that many with additional fee. I do the same for FHA & USDA. as they require real time photos.

  9. I agree. If we appraisers depend on the accuracy of the MLS listing of comps to provide correct data and information, why is is that we can’t depend on the photos provided? An advocate for taking photos stated in a recent issue of Working RE that one of the main reasons to take comp photos is in case the sale was sold for lot value only and the improvements demolished. In twenty plus years of appraising I have seen that one time. Not to mention that any MLS service I have ever used has the option “sold for lot value only”.

    Having said all this, I have purchased removable magnetic placards that go on each side of my vehicle while in the field that have my company name, logo, website and phone number on it to let residences of the neighborhood get an idea of my intention and purpose there. The harassment by the ignorant has been reduced 100%. Plus it is inexpensive advertising.

  10. Dustin, you cant be out there cow tipping in broad daylight! I do agree that it is not worth it to jeopardize your safety for the fee. If it is not safe to take a photo, just skip it and explain in the report. If the client insists on a photo, it is at that point you can decide to proceed or recuse yourself from the assignment. In dangerous areas, I can see this as being reasonable. I work in suburbia and usually am able to get a photo without endangering myself. When I see reports with all MLS photos, I can only think that the appraiser might just be cutting corners and using the “Im not safe” excuse to save time. Stay safe out there, and leave Farmer Browns livestock alone!

  11. If comparable pictures are so important to the lender, then why are MLS pictures acceptable if they are in a gated community??

  12. I’ve been saying for years that taking comp photos are dumb and antiquated. I am a person of color and I can’t even begin to tell you how many times I’ve been chased down, stopped, cursed out, or had the police called on me for trying to do this incredibly stupid part of my job. Something needs to change before someone get seriously hurt and I’m dead serious.

  13. For your safety, the answer is to have highly visible signage on your vehicle. I used to be stopped, followed, etc. Since our company installed signage on our cars the most I’ve had to do was roll down the window and point at the large sign on the side and smile. They smiled back.

    I do agree that comp photos present many dangers, especially for us rural appraisers. Stopping on the blind twist in a road (because there are no shoulders) can be rather hairy. As Dustin said rural folks can also be extra protective of their property. I am not a fan of driving 25 miles to take a photo of a comparables mailbox, but I still see the value in driving comps. I learn things that I would have missed on Google Maps. So should we have to photo comps? You can put me down as a hard maybe.


  14. I too have been chased down the road by vehicles, quads, etc. I always stop to explain to people who I am and what I’m doing and why. It’s never been a problem. However even in town people have come out of their houses yelling at me and demanding that I delete the photo. Again I try to explain and if they remain irate, I simply drive away. Once I took a photo of a cops house and that evening had a knock on the door by law enforcement. I carry multiple forms of defense and have been trained in self defense, so not a big deal to me. But I never go past “Do Not Trespass” signs and try to include that sign in the photo. I’m one of those rural people and have cameras on my driveway with alarms when ever someone pulls in.

  15. Hi Fred. I am White and I’ve been chased down as well. Sorry I don’t see the point in bringing race into this topic. I know its a popular trend these days but I hope that you don’t feel that because your a “person of color” that it doesn’t happen to “White” people.

    1. I am a white male who has also been chased down and had the cops show up at my door. That being said, your comment about him bringing race into it is ignorant as is your use of quotations to emphasize your whiteness. The OP was saying that because he’s a person of color, he already has people eyeing him suspiciously because he’s not a “white boy” driving around the neighborhood. You’ve never been discriminated against or made to feel unsafe because of your “white boy” skin. Keep your redneck racist comments to yourself.

  16. Is this whining still happening like it is 2017? If some of you don’t want to follow the scope of work, then take desktop and review assignments. What is next, no exteriors on the subject because a neighbors dog might get loose, or a snake might bite you from under a deck (both things have happened to me). Being a true professional who wants the full fee means taking the good with the bad. I recommend that none of you who don’t want to do this do much litigation, insurance, wealth management or other non form-filler type of work… you will get crushed. Do you all not see that the end result of this is more bifurcated work and lower fees so that the client can send somebody else out to the field to do what you don’t want to do? Are any of you ready for 25-30% less fee on every assignment? Be smart. Put yourself in a lenders shoes… would you loan your own actual money on what somebody says based on the internet, or would it be worth a few hundy more to have a real pro check it out?

    Nobody asks for you to put yourself in harms way… if the road is private or unable to traverse, just take a photo of where you got to and move on…I have never had an issue with one photo of a private road sign (or a road with 24 inches of snow on it) and two originals…never. Just do the best that you can in the field and document it. I go to extremely rural and mountainous areas and get paid more… not an AMC $50 but hundreds if not double the fee. Be smart and respect your time and charge more.

    Driving by can be a hugely reliable verification source. If some of you are the kind that do not call agents to verify things and just use the MLS and county records, then also be prepared to get crushed by a state board, court, etc. Most MLS data is copied from the assessor, so this is not two sources. Curbside viewing, even without a photo, is huge.

    Lastly, does anybody think that other jobs have no hazards? At least this one is right in front of you and can be avoided or mitigated in most cases and not a silent killer in decades that nobody knew about like leaking halogen in a data center, asbestos, etc. I am not saying that the problems are not real, but we are not the only profession with problems. I understand the privilege that I have as a white male and do not take lightly that what happens to me can happen in further increments to other people, but again, what is the profession where this is not the case? I have not solutions other than to be smart. It is probably a better argument that random traffic accident injuries and deaths pose more of a problem than the irate homeowner, but most probably realize that this is a ridiculous argument to make.

    If any of you were offended that I used the term whining, then wake up and know that if clients ever succeed in replacing us, this is exactly how they saw us as a whole… whiners. It has already started to happen.

  17. In Georgia, we have a hands-free law, which states, A driver cannot have a phone in their hand or use any part of their body to support their phone. Drivers can only use their phones to make or receive phone calls by using speakerphone, earpiece, wireless headphone, phone is connected to vehicle or an electronic watch. . This disclaimer is added to each report. Lenders seldom ask us for originals as it is illegal to even be stopped and using the phone while in a car.

  18. I’ve been chased by homeowners in their car taking comp photos and pulled over and questioned by police. If there is a no trespassing sign, I take a photo of that. Not worth risking safety for a photo.

  19. Never worth the safety risk. Always respect the no trespassing signs. The Hills have Eyes. lol All kidding aside know your value and please stop ignoring your profession and the key role it plays in our nations economy. Appraiser’s stop accepting 20 year old fees.

    Actually this would be a great topic to follow up on. How and Why, Appraiser’s don’t know their own value.

    anyway thanks for the entertaining read this AM.

  20. I’m sure everyone has heard this from an authority figure early in their lives. ” Everyone has to work, but you can work smart”.

    Save your photos !!. I re-use comp photos all the time for subsequent assignments and do not drive back by the comp. If I get blow back from the underwriter because the photo I use shows brown grass and it is now spring/summer, my standard response is I took that photo shortly after the sale closing and it is the best representation of the property at that time. If you would prefer a more recent photo, the additional charge will be $—. I have had several rural appraisers tell me they have few sales in their area within a year and they always take photos periodically of the sales even if they have no need for them at the time, and re-use, re-use.

    Has been a long time since anyone took me up on that.

  21. Wow I’ve been saying most of what you said in this article for 25 years. I’ve been chased down, run off the road, yelled at, threatened and scared for my life. And for those that say I’m just whining then have a gun pulled on you and tell me how you feel then. lol I’ve often thought of putting the police reports of these incidents in my appraisals to use as an explanation of why comp photos were not taken. Unfortunately, it’s going to take one of us getting killed to change this ridiculous rule and if it was really that important USPAP would require it. Oh and please don’t take pictures of “No Trespassing” signs. These are the type of people that have a camera on you and will hop in their car to come after you. Learned that the hard way.

  22. Scott Williams

    I have had a similar experience except I was taking comp. pics. A property owner started following me, but after following me down private driveways for the next 3 pics. he decided to turn around and go home. This was 30 years ago. It would be much scarier today with a lot more firearms, cameras and suspicious people.

    The real question is how good is good enough as far as data collection goes (and analysis for that matter). With clients, and especially AMCs, continually requiring more and more work with no increase in fees, it often seems like the sky is the limit. In residential work, the appraiser has almost no control over any of it, except the option to turn down the work. In almost all other professions, the professionals more control the extent of the work rather than the clients.

    We currently have a bifurcated situation in appraisal. On the one hand, the clients want appraisers to supply more and more research and analysis (for no increase in fees) under the theory that “you will want to do a good job, won’t you?” My stock answer to that is: “Not especially. I want to do enough to produce a credible appraisal, but not any more than that unless you want to pay extra.” We never claim to have all relevant information, only to collect a “reasonable” amount. Almost no everyday appraisals would fit the definition of demonstration appraisals.

    On the other hand, appraisers are told they are too expensive and too slow, and lots of very smart people are working hard every day to figure out how to cut appraisers out of the transaction. They are perfectly willing to give up on anyone with true expertise even looking at the subject property much less taking current comp. pics. As for analysis, they are willing to live with real estate broker opinions when the broker may have no analytical training or expertise. They are also willing to live with often huge value ranges with wide confidence intervals when using big data analytics, all the while nit picking appraiser efforts.

    This bifurcated situation conveys mixed messages to appraisers. They really want highly competent people making appraisals, except when they don’t seem to care about this at all. They really want ethical appraisers, except when they don’t. They really want accurate values, except when they just don’t care. The actual message being too often received by the profession is: “If we (the clients and regulators) don’t care, why should you?” Not a good message to be sending.

    The solution: beats me. Appraisers could step in and solve a lot of these problems, but other extremely powerful stakeholders seem to have no interest in this approach. Until these stakeholders figure out how to eliminate the appraisers’ role in the transactions, we will probably just muddle through.

  23. USPAP and Fannie/Freddie do NOT require photos. It is the lenders. Not only is it a COMPLETE waste of time it is DANGEROUS. We all know the powers that be could care less about our safety, however, they do care about quicker and not having to take comp pix would streamline the process making it quicker. Additionally, we have turned into a society of guilty until proven innocent. We should not have to take a picture to PROVE we drove by the comp.

  24. That doesn’t just happen in a rural setting. A while back (b4 digital photos), I took a picture of a comp and there was someone outside in the neighbor’s yard. Well after completing all my comp photos and heading home, I noticed someone following me..every turn I made he made, so i figured it must be that person who was looking at me taking the picture, so I made sure I made every turn signal clear, I even pointed out my window which direction I was going to make. When I finally reach my office (I was a staff appraiser at a mortgage company then) I got out and told the person who pulled in near me: they are going to feel real stupid since I was only an appraiser taking pictures of comps so he left. Another time someone must have reported me taking picture of houses on their street so they called a constable who met me when I was coming out of the house I was appraising (2 cars mind you) so I asked:Can I help you officers? They said an Can We help you?..connecting the dots and figuring why they were there I almost said Sure I need to take some more comp photo’s would you help? But instead the homeowner intervened and told they why I was there. They still said I needed permission to take photos and I just said uhhh… okay. (public street)

  25. Two things. I have been harassed more in urban areas and had police called on me than rural areas. And most of the people I come across in rural areas are friendly and understanding. I always stop when I see someone on the property in question and let them know what I am doing and ask for permission to take a photo. 99% of the time they say yes. The other 1% I say thank you and leave. The most trouble I have ever had is from nosy neighbors.

  26. Jerry Parsons

    As mentioned above, the scope of work on a 1004 states that you have personally viewed the exterior of the comparable sales. If you are really viewing the exterior of the comparable sale, why not just shoot a photo? Takes 5 seconds. Credibility. Your there anyway!!! Or do you want to complete a desktop and call it a full 1004. I agree with “Doug” and others. Stop the whining. Take a photo of the street sign, neighbors gate, no trespassing sign, don’t put yourself in harms way. just explain what you did.. Always put mls photos in the addendums. Not original photos. We have all been chased down and harassed. These are just war stories from the trenches… Dustin was on the private road doing
    an inspection, nothing would change the outcome, except, read the maps better, or maybe pull over and see what’s up. Most people are nice and understanding, it does not matter where you are.. Oh, I use to Work in Silicon Valley, where older homes were sold and razed the next day, with a 30 year mortgage (vacant land sale+cost). Contractor would build a new luxury home 3x the size. Yes this is still happening! Go create some value…

  27. The same appraiser who doesn’t drive the comps “to personally view the exterior of the comparable sale”, is the same appraiser who ignores the appraiser’s certification on 1004D’s, “I certify that I have performed a visual inspection of the subject property to determine if the conditions or requirements stated in the original appraisal have been satisfied”. Forget about following policy right, its all about taking that extra front and street photo during the initial inspection, and using that agent supplied photo of the repair to save a trip.

    For those who outsource 90% of the appraisal, stop complaining about driving and taking pictures (10%).

    Seek the truth

  28. Donald Jean Peyton

    Relax rural appraisers, be smart, be respectful, be discrete, be careful, stay off those posted private roads. A mail box, or access road entrance is enough especially when you can back it up with listing photographs. We can look a bit suspicious when taking comparable photographs. I too have looked at the barrel of a shot gun, received many threats, told what I can and cant do many times, chased & followed at some level by homeowners, gangsters and idiots. Take a second and think how you look to them. If they are kind I always explain what Iam doing and most calm down. The small percentage that immediately approach me in agner, or block my vehicle are assured that that isn’t a great idea on their part. I let them know if I’am on a public road I can sit there and take photographs all day(if I want to work them up). Private roads are another story. Be careful do you best to cover up what you are actually doing dont ever get out of your car to take a photograph of a comparable. Rural properties require more time, much more time, make sure your price them accordingly.

  29. SCOTT Francis NORTON

    If you don’t think its important to drive by a comp and photo it for locational comparison alone to the subject then you are not competent

  30. Fannie form says we “inspected” the comp from the street- it does NOT state we have to take a picture, the picture is to PROVE you did so, we are turning into a nation of guilty until proven innocent. As for this nonsense stopping, it won’t stop until there are a NUMBER of lawsuits suing the client for the appraiser being harmed and/or killed, one lawsuit won’t wake them up

  31. Hello,

    This message for the appraiser who identified himself as “White Boy”. I am also an appraiser of color. I get stared down and sometimes followed as soon as I drive into some neighborhoods; never mind stopping and taking pictures. I am always uncomfortable taking comp photos. Just yesterday, I pulled over on a side street after having taken some photos to look at some paperwork. A young man in the house across the street from where I was parked came out and asked me why I was parked in front of his house. When I told him I was an appraiser, he said “do that shit in front of someone else’s house.” Although I was very tempted to react differently, I decided to drive off. As I was driving off I said out the window “this is a public street”. The response back was “Fuck You Nigger”. Don’t tell me race doesn’t play an additional role here. It is unfortunate that you don’t want to hear it.

  32. Taking comp pics is a ridiculous waste of time. Particularly these days when many of us are on 2-3 week turn times and clients are frustrated. Also it is an unnecessary risk for the appraiser. There is plenty of online data to determine external obsolescences.

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