NAR Taking Action

The article was published over the weekend from the Washington Post Online about the new legislation proposed for the 18 month moratorium on HVCC. Enjoy.

Washington (DC) Post via World Wide Web 07/03/2009
Lowball Appraisals Spark Uproar By Kenneth R. Harney
Saturday, July 4, 2009
It’s by far the hottest controversy in real estate this summer, and it could directly affect the value of your house — probably negatively — by tens of thousands of dollars.
The issue involves lowballed appraisals and the new rules guiding appraisers in both price-depressed and rebounding markets. Consider these snapshots:
*In San Diego, Steve Doyle, division president for Brookfield Homes, is trying to close out the final 20 houses of a 120-unit single-family subdivision. Prices range from $340,000 to $350,000. But recently there’s been a major hitch: Appraisers assigned by banks are coming in with valuations of $60,000 or more under Doyle’s selling prices. The appraisers, who Doyle says are inexperienced, unfamiliar with local market trends or both, are using distressed sales — foreclosures and short sales of existing houses — as their “comparables.” Some of the distressed properties are in poor condition, and all of them offer fewer amenities, Doyle says.
*In Wilmington, N.C., a loan applicant with a house in excellent condition and an unblemished payment record sought to refinance into a 4.75 percent mortgage. She bought the property four years ago for $160,000 and made about $20,000 worth of improvements. Her loan application, according to Paul Skeens, president of Colonial Mortgage Group of Waldorf, was “a slam dunk — nothing to it.” The house was worth $180,000 to $200,000, according to a local realty estimate.
But when the bank sent in an appraiser with little local knowledge, he chose as comparables two short-sale properties that had both closed in the mid-$140,000 range and one inheritance sale around $155,000. The last property was “in horrible condition,” Skeens said. “I’d call it dog meat.” The deal-paralyzing appraised value that came in for the slam-dunk refi: $149,000.
*In the suburbs near Cleveland, Enzo Perfetto, manager of Enzoco Homes, builds custom houses on clients’ lots. Recently, he said, banks have begun assigning appraisers from far outside the area to value lots as part of mortgage packages on new homes. Some of the comparables they use are in foreclosure situations, and that depresses land valuations. A young couple who paid $75,000 for their lot recently had it valued at just $30,000 by an out-of-area appraiser who looked only at online data, according to Perfetto — discouraging the couple from proceeding.
“I think the pendulum is swinging way too far in the wrong direction on appraisals,” Perfetto said. Bank-assigned appraisers often “don’t know the local market and they’re going for low numbers to be ‘safe.’ ”
* * *
Complaints about lowballed appraisals — from builders, real estate agents, consumers and mortgage companies — have erupted since May 1, when government-backed Fannie Mae and Freddie Mac put their new appraisal rules into effect nationwide. Critics charge that the new system fosters the use of appraisers willing to work for low fees — sometimes 50 percent below previous standards — and who are willing to conduct home appraisals far outside their typical areas of activity.
The Fannie-Freddie system — known as the Home Valuation Code of Conduct — is complicated by the fact that it is a byproduct of a legal settlement in 2008 between New York Attorney General Andrew M. Cuomo and the two big mortgage investors.
Under the code, appraisers are now routinely assigned by appraisal management companies rather than local mortgage companies or loan officers. The management companies pocket as much as 40 percent to 50 percent of the appraisal fee paid by the consumer.
Frustration with the new system boiled over and made its way to Capitol Hill late last month. The National Association of Home Builders called for an immediate change in the rules governing the use of foreclosures, short sales and other distress transactions as comparables for appraisals on non-distressed homes, whether new or resale.
Two congressmen — Travis W. Childers (D-Miss.) and Gary G. Miller (R-Calif.) — have introduced legislation calling for an 18-month moratorium on the appraisal code. In identical letters to Cuomo and to James B. Lockhart III, the top regulator of Fannie Mae and Freddie Mac, the National Association of Realtors also requested a moratorium and complained that the code is raising consumer costs, distorting property values and killing sales.
Asked for comment, Lockhart said through a spokesperson that his agency is “monitoring” the situation, and considers “the views of market participants important.”
Bottom line: Be aware of the issue. It affects your equity, even if you’re not currently buying or selling. And watch whether Congress fixes the problem.
Kenneth R. Harney’s e-mail address is (c) 2009 The Washington Post Company

  1. Chuck Mackley

    Markets have been in decline for years now. Why the problem now? I suspect it is more because appraisers are selected by the lender and not by the people trying to close the deal. Lap puppy appraisers have been used to support transactions for too long. Now the lender with real skin in the game are choosing the appraiser.
    Appraisers are coming from no further away today than before May 1. The only real difference is that appraisers must be selected by the lender and not by the Realtors and developers.
    If short sales and REOs dominate a market, then that is the market. Appraisers report market conditions, they do not create them.
    Developers have been gaming the system for years, offering rebates, concessions and free upgrades, lowering the values of their homes without disclosing them to anyone. That is how people end up with $500,000 mortgages on homes only worth $350,000.
    These people are just whining about not being able to use their “team player”, number hitting appraisers anymore.

  2. Hall

    If that homeowner bought in 2005 in Wilmington, NC it is highly likely their home decreased in value in 4 years. If the deal by the mortgage company was a “slam dunk”, why didn’t they get it reviewed or get another appraisal? Those comments appear to be no more than sour grapes. The out of town mortgage brokers helped create a bubble market here, especially in the beach markets.

  3. Doug

    Appraisers were never ground 0 for the housing bubble (or their possible cozy relationship with local mortgage brokers). Loose lending guidelines that included neg-am loans and no doc qualifying were the main culprit. Dishonest players in the biz took advantage of this situation and we’re now feeling the hangover after the party.
    HVCC solved no problems, however created new ones. On the surface, HVCC looks great, but in practice it is a major mess. Appraisals are opinions and these opinions are supported by lenghtly reports. It is dream-land to believe that all appraisals are created equal, but that is what your friendly AMC would like you to believe. As an appraiser for over 10 years, you’re not likely to receive an “aggressive” or “high-ball” appraisal that would requrie 2x or 3x the work of a “low-ball” report.
    Anyone who supports the HVCC can be found in 1 of two camps. A. They are ignorant of the realities of the cost/speed/quality issues in the appraisal process. Or B. They are very happy with skimming 1/2 the fee from the very people who do the actual analysis.
    Remember, you get what you pay for. And that includes lending money to people who really don’t have the ability to repay their loans.
    OK. How to solve the problem? Return lending guidelines back to prudent lending guidelines by requiring down payments and verification of assets. But, guess what, the lenders with skin in the game starting doing that a few years ago after trouble was bubbling (pun intended).
    If the HVCC doesn’t get fixed (and it should go away) it now becomes a crap-shoot as to whether a quality appraiser can be found to take the necessary time to write a decent report for YOUR home sale/purchase or refi.
    Good luck!

  4. Steve Owen

    The first two commenters are right on the money. The article says that the appraiser used properties that were in poorer condition, but does not say whether better comparables were available and does not say whether the appraiser made adjustments for the condition. When short sales are part of the market, you have to consider them. The question is not “what does the builder want to sell for?” The question is “what would a typical buyer pay?”

  5. jack deuce

    This is all about commissioned salespeople regaining control of the appraisal process. It is pathetic, whiney, corrupt, and disgusting. There were no complaints before HVCC when the mortgage broker’s lackey appraiser showed up with his hands around his ankles ready to do the realtor’s and the broker’s bidding or risk not getting any more work. Most of those reports were utter crap, hiding defects, using superior sales, ignoring real competitive properties, and even worse. If you crooks can’t get your commission without having an appraiser in your back pocket then go try and sell something that does not require a loan backed by the Feds. – pathetic, whiney, Turds.

  6. Adele Schnabel

    There is truth to both sides. You get what you pay for is truly applicable here. The management companies are rushing these reports, paying disgracefully low appraisal fees and their reviewers are using computerized valuation statistics to knock down the appraised value given by the appraiser who actually performed an inspection. HVCC DOES NOT WORK. There has to be some regulation and supervision of the management companies. No appraiser can do a competent job on an appraisal within 24 hours for $150!!!

  7. I spoke with Ken long before May 1st. He was well educated on what the HVCC and the results of AMCs. He just failed to report on the issues with AMCs and how they are bank owned. We have given him many issues on the problems with bank owned AMCs. MBs should not be able to influence value over the appraiser, AMCs should not be allowed to skim fees and banks should not be allowed to own AMCs at all. Not even 1% ownership.
    It should be fully disclosed to the borrower what the cost of the AMC is and what the fee that is paid to the appraiser. MBs should not be able to state I need this much to make it work and AMCs should not be shopping for the “cheapest appraiser.” Grow up everyone! The days of asking for comp checks are over with and AMCs that are shopping on cheapest priced appriaser, like Wells Fargo does every day should be regulated and put out of business. The cost of refinancing is paying for a qualified appraiser. Period the end. This should be regulated on a federal level or allow the local banking commission to have control over the banks doing business in their state. There have been so many complaints against Wells and Chase and their AMCs but the State Banking Commission cannot act. That is the article Ken should be working on.

  8. Christian Serio

    If all the appraisals were coming in at the values needed to make the deals work, would the realtors and brokers be complaining about where the appraiser is coming from to do the appraisal??? No, absolutely not.
    Just because an appraiser comes from a different area does not mean that he/she does not know the market. I’m an appraiser from Miami-Dade county in Florida, however I also have an extensive knowledge of the real estate markets in Broward and Monroe counties. I guarantee that I can provide ethical, honest, credible appraisals in all three counties eventhough my office is in Miami.
    Most realtors and brokers don’t even read the appraisal reports, they just look at the estimated value and if it meets or exceeds the value needed to make their deals work then there is no problem with the appraisal.
    I’m sick and tired of realtors and brokers blaming appraisers for killing their deals. Unfortunately most realtors and brokers were spoiled by their “team player” appraisers that always provided appraisals with the values needed to make their deals work.
    I will agree that the HVCC needs to be revised in order to regulate the appraisal management companies which are stealing money from the consumers and the appraisers. The appraisal management companies actually instruct the appraisers not to include a copy of the invoice with the appraisal because they want to avoid confusion for their borrowers (Confusion?, they just don’t want the borrowers to know how much they’re stealing from them).
    However, I believe the HVCC must be working to some degree because realtors and brokers are voicing their opinions that they are not happy. The fact is that they can no longer do business as usual with their “team player” appraisers.
    An appraiser’s job is to provide an honest, ethical appraisal report to protect the integrity of the real estate market and the public. A REALTOR’S JOB IS TO MAKE AS MUCH COMMISSION AS POSSIBLE. A BROKER’S JOB IS TO MAKE AS MUCH COMMISSION AS POSSIBLE. Who do you trust? A realtor or broker that wants to make commission or an appraiser that is providing an honest, ethical service?
    Buyers and home owners that are trying to refinance need to wake up and open their eyes. Did you ever think that the so called “low appraisals” might actually be a very good appraisals that will help you avoid being ripped off by the commission hungry realtors and brokers???

  9. bill abalos

    Not all appraisers were lapdogs owned by the realtors and mtg brokers. To be sure, that segment of the business was out there. I for one had plenty of business prior to the HVCC and I always stood up for myself against mtg brokers looking for me to hit a certain number. There are also good mtg brokers out there who repected an appraiser’s opinion of value. Does any body remember the concept of honesty and integrity? I know first hand that most of the appraisers currently out there accepting assignments can’t spell honesty or integrity nor do they know what the words mean. The good appraisers and mtg brokers who really cared about the business are the one’s who are being hit the hardest since honesty and integrity have gone the way of the 8 track player. They are interesting to look at but nobody wants them anymore.

  10. “Appraisers come from no further than before May 1st” – Chuck Mackley
    When I started to read your post, I stopped when I got to that line because it became blatantly obvious that on the subject of HVCC, you have no clue what you are talking about. The furthest I’ve had an appraiser come from for one of my purchase loans was 248 miles away, and I’m not in a “rural” area. While HVCC may appear to be good, and while it’s intention is well placed, putting unregulated AMC’s in the drivers seat is not the answer. The AMC’s are often owned in part (up to 49%) by the banks themselves. Furthermore, although HVCC has designed appraisals to be portable, lenders do not seem to have the understanding (because of all the misinformation from the AMC’s) and so appraisals are not ever portable. This is a nightmare situation, I’m in the business of lending money, not gambling with my clients. When it comes to HVCC, I never know what I’m going to get, what a fun conversation with the borrower “we could lock at this great rate, but your appraisal is due back anytime between tomorrow and next month, so you’re going to have to pay more for a longer lock or risk losing it all together” or how about “Give us $500 and then we can figure out if this deal is possible, you want a receipt…oh, sorry the AMC’s haven’t set up a system for receipts”. What a joke. The AMC’s put the word out that realtors cannot contact appraisers under any circumstance, and the appraisers and the realtors believe it. IT’S NOT TRUE!! READ HVCC!!! It simply is not feasible to do a loan without having the ability to communicate with the appraiser who is one of the most integral people to the transaction. Really folks: Non portability, out of area appraisers, Low ball (low work) appraisals, longer lock in fees, inability to communicate, duplicate appraisal fees, and our local hardworking appraisers are getting chopped off at the knees. Oh, and do you know why??? Because WAMU got together with an AMC and colluded value. So now we all have to work with AMC’s??? Lastly, part of the settlement was to fund an oversight commitee to HVCC. Guess what, it was never formed.
    Looking for examples, imagine this (these are things that have happened within the industry)
    Appraisal is ordered through lender approved AMC, appraisal comes back BUT appraiser is on lenders blacklist. Whoops, guess we have to order another one…
    Appraiser comes in from out of town, sends the appraisal about 4 weeks after order date; problem, THEY MEASURED THE WRONG HOUSE!!!
    Appraisal comes in and is declined by lender; why? Because it is the appraisers first appraisal ever, and no senior appraisers signature! (AMC’s don’t require that you see, plus there’s not enough money to go around)
    So to all of you who clearly don’t understand the situation, I say: “Get educated on HVCC or stay out of the debate”
    Good Riddance.

  11. David

    I am an appraiser with 17 years experience. Prior to May 1st we took a great deal of pride in or research. We have never had a complaint filed against our office; nor a claim against our E & O policy. If undertaking an appraisal on a difficult property we would spend up to 3 days on the job. That same job now goes out in 24 hours or less.
    On May 1st Everything Changed: Appraisers were asked to:
    *Give up their existing lender clients, regardless of the age of their business.
    *Provide 24 hour turnaround (or less) regardless of the assignment.
    *Do at least 50% more work (1004MC, add 2-4 additional comps, etc).
    *Surrender at least 50% of their income to appraisal management companies.
    They are traveling 100+ to accept appraisal assignments because they were forced to give up their entire client base [appraisers also have families to fee].
    They are throwing out trash reports because they are being forced to by AMCs. 24 hours is not enough time to do a decent report. 50% of the fee is not enough to support their businesses.
    I openly admit that on May 1st I instructed my staff to cut every available corner when completing appraisals. I don’t run a nonprofit business so something had to go (primarily time spent on analysis).
    *If you’re going to place time restraints on appraisers except junk appraisals.
    *If you’re going to force appraisers to do twice the work and reduce their fee by 1/2 EXPECT SUPER JUNK APPRAISALS.
    *If you’re going to force appraisers to give up their client base that some spent 40 years building…expect the appraiser to take assignments outside their region so they can feed their family.
    As for the argument that states that appraisers are lowballing values to be on the safe side: Consider this fact: Lenders are asking appraisers to put the most emphasis on comps that occurred within the past 3-6 months. Duh…it doesn’t take a rocket scientist to figure out that this creates an automatic bias towards the low side considering what happened to housing over the past 3-6 months.
    Realtors need to cosider these things before they bash appraisers. It’s not the appraiser causing the problem. It’s the insane guidelines that appraisers are forced to follow (namely the 1004MC form and HVCC).

  12. In the Uniform Standards of Professional Appraisal Practice (2009-2009) the Preamble states “USPAP is to promote and maintain a high level of public trust in appraisal practice….” This is what appraisers are supposed to do. Prior to HVCC appraisers were “cherry picked” to “make the deal work” this is NOT the appraisers job, nor has it ever been. Some of the posts are dead on…”not all appraisers are lapdogs owned by Realtors and mtg. brokers”,….”Most Realtors don’t even read the appraisal report, they just look at the estimated value”. Realtors should take the latter and former as Gospel. While appraising in CA, I easily made the case that residential property in our area Fresno, Modesto, Tracy, etc… was depreciating at 2% per month. In short, it is the appraisers job to analyze the market and report his/her results. While I am no fan of AMC’s, at least they provide some “buffer” and allow the appraiser to be impartial. Face it, the business models for Realtors, builders and appraisers are changing and no amount of whining will change it.

  13. Tim

    Problems are easily identifiable;
    1.) Untrained staff at the lenders. Of the Big Three banks all of them have processing, underwriting and loan functions being outsourced to India. No formal training in real estate at any level only bank policy and procedures.
    2.) MCS, lots of blame to go around here. Incomplete MLS listings by the Realtors lead to inaccurate MCS reporting. However, if the appraiser argues againsn’t the veracity of the MCS and does no show EXACTLY that data in the report it will be considered unacceptable. SP/LP % will be incorrect, amount of 12 month decline may be incorrect, all kinds of things. So if you “have fast” your MLS listing data don’t blame the appraiser for what the statistics show. In addition the folks from India that don’t know how to read an appraisal report are also charged with review of the MCS.
    3.) Lenders guidelines for appraisal reports are set in stone. An appraisal order used to be one page. Now 5 or 6 and includes “instructions to appraiser”. Two comps in the last 90 days, One Pending, Two active. All market adjusted for date of sale. (Thats the decline % shown in the faulty MCS due to the faulty MLS data or SP/LP ratio from same).
    4.) This notion of the HVCC screwing up values and costs and mandating use of AMC’s. Mostly false. AMC’s are an additional profitable line of business (including title insurance)that the big banks came up with. Most of the false info out there is from the AMC’s themselves trying like hell to compete with each other. Latley appraisers have either quit, taken on other types of assignments that pay full fee or have been contracted by a lender directly at a reasonable compensation structure. The 48 hour turn around time comes from the AMC’s having to look hard for a couple days to find an appraiser who will work for the low fee. Then send out the “rush” assignment. Some have even increased their fee split (about $30 !). Again, that assignment is attached with a set of “instructions to appraiser” with now the AMC as the enforcer. Since now the AMC’s are having a little problem with finding appraisers, rushing them and enforcing the lenders “guidelines” some appraisal reporting is statistically accurate but may not reflect the true current market function. That takes some time to complete and support.
    If anyone wants this all fixed its pretty easy.
    Big banking needs to hire and train Underwriters, processors and support staff to accurately review appraisal reports. Not outsourced on the cheap.
    They also need to get out of the valuation and title business and break apart that monopoly. There is no good reason for AMC’s to exist ! Period. There are numerous portal upload programs that are secure, scrub the report for errors and cost $10 or less per report. ($200 to the AMC seems a little much doesn’t it ?) Realtors need to input all data in the MLS fields and this should be required. The FNMA Market Conditions Summary should be reworked and shelved until the MLS Boards around the country can supply accurate data to analyze.
    Mortgage brokers could not have pushed “Risky Sub Prime Loans’ if they were not made available by the banks in the first place. If big banking had not got rid of the seasoned, experienced Underwriters who knew how to read an appraisal report the mortgage brokers who engaged in selective appraiser selection would have never been able to put one past them. Even with that getting rid of staff review appraisers paid on salary rather than production “per unit” was also a costly practice.
    Big banking needs to bear the cost of regulation since they spent so many years and so much money avoiding them.
    Appraisal fees will go up. They have to cover the same amount of overhead that any other business has. Appraisal fees, until just lately, have remained at 2003 levels.
    State appraisal boards need to free up their time from investigating homeowner complaints about value opinion that lead to sanctioning for mispelling errors and other such nonsense. Go find the fraud, its up again this year !
    Those are the solutions. I doubt big banking will give up their additional sources of profit and will fight any additional overhead for regulation to the bitter end. I doubt local MLS boards will fine Realtors for incomplete or incorrect listing data. I very seriously doubt the HVCC will be repealed or changed in any way.

  14. Lenders are turning out to be their own worst enemies. We also know that appraisers have always been there own worse enemies.
    The simple fix, for lenders/AMC’s, that would quell the masses is under their noses and they can’t see it for their greed. Everyone knows they still own or control the AMC”s. If they would pay the appraisers a larger part of the fee and increase the turn time, they would have better, happier, less stressed appraisers who would not mind working for them (so instead of being a 6 billion dollar a year industry it would become a 4 billion dollar industry). There would be less complaints and better quality reports.
    Demanding a 24 hr turn time is self defeating for them. When I was trying to work with AMC I had reports coming back 60-90 days after completion with requests for meaningless changes. Why is turn time so important when it’s taking so long for reviews. At one time “turn time” meant 5 days instead of 10; and we made the exception of our good clients.
    If the AMC would use a rotation system that was not biased they would have happier appraisers. They should assign orders and not broadcast them so that work would be spread among all appraisers and not just to the appraisers with most sophisticated technology who capture first.
    The solution for appraisers is one I have preached for the past 20 years.
    Appraisers need to organize away from and in addition to the few existing groups (AI, Naifa, etc). They need to be more friendly with one another and share, not boast, and quit being “loaners.” I know it’s nice not to have to talk to anybody, but sometimes it’s necessary for your own well being. Appraisers need to join together and strike back. Without appraisers, there can be no real Estate or loan transactions. A one week strike would bring the real estate and banking industry to it’s collective knees. But it has to be done by ALL appraisers, even to country bumpkins who are travelling 200/mi for $200. Perhaps we appraisers need to practice saying words like team and join together, and cooperate more often.
    I have mtg broker clients who can’t use some of the smaller AMC’s because their lenders won’t take their paper unless it is with the LSI’s of the business.
    I am a virtually unemployed 20/yr, honest, good, knowledgeable appraiser. I tried working with AMC’s. To the best of my knowledge I am in good standing with all of them. However, I have not been used by them in months, if not years. Oh and they all have rotating systems so they can’t discriminate.
    Thank you, Mr. Harney. I am a fan of your writing.

  15. Tim

    I agree. You have been doing this long enough to remember when appraisers were not competitors. Local appraisers knew each other and frequently got together for lunch or something. We had our own way of managment which was ; I’m too busy, not in my area do you want it ? and If you get one out of your area , too busy, shoot it to me. Things worked fine. AMC’s promoted an increase in appraisers by allowing trainees to do volume and gave them a path to certification. Then used them to fill the rotation list of the big AMC panels. Increased their territories and sent them a ton of work while lining their own greedy pockets. This will probably not change. When I saw Freddie Mac’s response to all the complaining and lobbying I knew this thing was over. Then to add insult FHA nominates a new chief who came from where;
    World Savings Bank, and Wells Fargo with time spent at Freddie Mac !
    Intergrated Assest Managment….look them up, that’s were residential appraising is headed. $50 inspections and floorplans, automated value. REALTORS beware..if values are already set by the bank who needs marketing or sales assistance? Just call your bank tell them you are ready to sell and find out what the collateral value is. Sell the house to the first person who has a letter of loan commitment for that amount. Stop by the bank and have them fill out the sales contract and arrange for (bank owned) title search and set the closing date. Done.
    Commerical, Tax Appeal and maybe some probate, divorce stuff will be available. Thats all. I have cut everything to the bone starting from late 2005 and now am almost a part timer. I laugh at some orders I get that are three counties away with a 3-day turn for $200. Hell I can get RELS to give me an REO assignment for more in my county. That is, by the way, all they ever give me since I refused to Limited FHA Desk Tops for $45. Jeez even the bank “staff” jobs are on a 45% fee split with the same expectations of any AMC and if you get low review rating on an assignment that will cost you 10% in fee split that month. 35% fee split….wow, last time I saw that was 1989.
    No entity is going to do anything about this. We let the monopolies run crazy and now we can real them in. bailed them out thinking they would modify and refinance troubled loans. What a joke ! They have been pitifull and all of them declared stellar profits the last quarter.
    I don’t see this appraisal profession ever returning to a viable independent business model again.
    “To promote and protect…

  16. David

    Perhaps in the near future FNMA should consider offering typing lessons to those in homeless shelters. They are only willing to pay for the service of “form fillers”. By having the homeless fill in their appraisal forms they will providing a great service to society. At the same time they will then be able to make $50 appraisal orders a reality (and without complaints from appraisers). I seriously suggest that FNMA, Freddie Mac, & President Cuomo consider this option to make their lives easier.

  17. joe scovel

    HVCC I,B,6 states that a Realtor may not tell or inform or suggest to the appraiser what he, the Realtor , would like to see the appraised price come in at. OH , but he can give them a copy of the REPC. Get real ! Want a truly arms length appraisal that does not interfere with the Contract and Closing process? Do you want a sure and fair appraisal process in your real estate affairs. Order an appraisal when you do the listing. PERIOD, No not a CMA. They should be outlawed. An appraisal at the listing stage should be mandated by the states and the NAR should be supporting this. But I can hear them now yelling at me and waving the flag etc etc. A mandated appraisal at the listing stage would solve so many problems associated with the sale of a real property. Although I am a commercial realtor I have required my sellers of single family homes to geta full blown appraisal when I took the listing. If they refused I didn’t take the listing. They were repaid at closing and everybody was pleased with a firm appraised price on the table from the onset.Especially the buyer’s agent. This took a lot of questions out of play. Thanks Joe Scovel Sandy Utah