Driving Comps: The Great Debate


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Driving Comps: The Great Debate
by Isaac Peck, Editor

Rarely has there been a debate as passionate or spirited in the appraisal industry as the one raging now: should appraisers continue to be required to drive comparable sales (comps) and/or take comp photos? Here are both sides and a survey to see where the majority of appraisers come down on the issue.

Appraisers in favor say comp photos are a value-add that provides the appraiser with critical information about the neighborhood and comparable sales. Appraisers against it say that it is unnecessary, a waste of time, and puts them in dangerous situations.

Working RE recently published two opposing articles on the subject, Original Comp Photos: Dangerous, Unnecessary and Why Comp Photos? (find it at WorkingRE.com). The stories produced dozens of emotional comments, with appraisers heatedly debating each side.

Do appraisers take original comp photos just because that is what Fannie Mae, Freddie Mac, and lenders require, or is there a real value? Some appraisers argue that it is not even a Fannie Mae requirement, citing their website which reads: “Copies of multiple listing service (MLS) photographs are acceptable.”

To help gain some insight for the industry, Working RE recently published 2021 Comp Photo Survey, which asks appraisers their opinion on the subject. The survey takes less than two minutes. The results will be shared with the entire industry. (Visit WorkingRE.com/photosurvey to take the two minute survey.)

For now, the debate rages. And what better way to air out the arguments than the words of boots-on-the-ground appraisers? Here are the two sides of the debate, in appraisers’ own words.

Danger to My Family
I was taking comp pics in a typical tract subdivision which was not located in a “sketchy” part of town. As I was leaving the neighborhood, I noticed a guy getting out of the truck behind me and walking toward me. Just then the light turned green, so I took off. He ran back to his truck. A few seconds later, the truck is following me. A different car pulls up beside me with two people yelling at me, asking why I was taking pictures of their friend’s truck. I yelled back what I was actually doing and they seemed to have accepted my explanation. Mind you, this was explained driving alongside each other at 40 mph. I saw them all pull into a gas station as I continued on my day. About two hours later I get a call from my wife, who is at home, asking if I took a picture of someone’s truck! Apparently, the guy with the truck found out where I lived and showed up at my house and confronted my wife about why I was taking pictures of his truck. She explained to him what I do. He accepted her explanation and left without incident. But what if he hadn’t and decided to harm my family? Comp picture taking is absurd and dangerous. Next time any one of you who disagrees and accuses us of “whining” about taking comp pics, ask yourself how comfortable you would feel if an angry stranger showed up at your home. —Eric Fenlon

Necessary, Sometimes
I think inspecting comps is a necessary part of our practice. Many times I see something that I would have missed in photos (power lines, sewage plants, etc.). With that said, I won’t take a comp photo if I see anything hinky and never if anyone is in the front yard. I just photograph the nearest intersection sign. When I had an unmarked car, I had several scary situations, but now that I drive a car with the company name on it, I rarely get asked what I’m doing. If I’m asked, I just point to the sticker on the side of the car and that solves it. However, when I do rural appraisals, I often risk my neck trying to get a picture of a mailbox. Many times the roads are curvy, or you have to stop after the crest of a hill, and most of the roads do not have shoulders. All this for a picture of the mailbox? —Jim Anderson

Waste of Time
The reason MLS pics are OK in the new bifurcated products is because that process would not be possible if comp pictures needed to be taken, so guess what? It’s magically OK to use MLS pictures. The appraisal can be done perhaps days sooner if you don’t have to drive the comps. I have been doing this for almost 20 years and can count on one hand the number of times it made a difference. I have, however, been confronted many times by angry people concerning the picture taking. —Diana Kan

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Just Put a Sign on Your Car
I was pulled over by a police officer while out taking comp photos. Someone had reported a “suspicious” vehicle driving slowly. Once I told him who I was he suggested I check into getting a Realtor® tag on my vehicle. In my area, to use our MLS, we need to be full members of the local Realtor® association. Being a full member, I am able to have a Realtor® tag on my vehicle. This has greatly reduced the aggravation and confrontations. Might be worth checking into. —Janet Jansen

Not Dangerous
Dangerous? No. In more than 35 years of doing appraisals, I’ve had exactly two instances of people being upset that I was taking photos. In one case, it was a woman who was in the middle of a divorce and thought I might be a private investigator. In the other, the lady of the house wanted to make sure I hadn’t taken a photo of her young son (I never take pics of people). Unnecessary? Maybe. But we have ourselves to blame. If appraisers were better at knowing the certifications they sign… and about not taking it upon themselves to decide that one or more comp pictures don’t matter… then the GSEs may not have insisted that we actually take original photos of the comparables. Let’s not pretend. We all know appraisers who routinely use MLS photos and never bother to drive by the comparables. —Stephen

Absolutely Necessary
I totally disagree with the author of the article about not taking comp photos. Particularly if you are in rural areas, you may not see everything but you have an opportunity to get a feel for the neighborhood. I have been an appraiser for over 50 years and completed many original and review assignments. Doing many field reviews shows me that some unscrupulous appraisers have manipulated photographs and maps to make comparables more or less desirable. To do away with the requirement of an appraiser inspecting comparable sales is an abhorrent idea. —John Underwood MAI, SRA

Thank you for writing this. In my 18 years in this business, I’ve had people sneak up on my car and bang on my window as I sat and took notes. I was stalked and hunted through a neighborhood a few months ago after taking a comp photo. He was relentless and I finally stopped and gave him a quick explanation. He apologized for scaring me and drove off, but as a woman in this business, I was traumatized. It’s making my heart race just typing this out. You are correct, we have all the tools we need to assess the location of a comp available to us on the Internet. There are times a photo of a comp is nearly impossible such as one on a busy street. We create unsafe driving conditions for ourselves and the cars around us—with all this beginning and ending with having to take comp photos. —Amanda G.

Get Higher Fees, Do It Right
I love you folks, especially when I’m in court watching you getting your butts handed to you in a sling. A lot of the time MLS/Google/etc. are five-eight years old and out of date but you go ahead and use them and when you’re called to defend your appraisal by a mad property owner or such, and you go look at your “comps” to prepare yourself (weeks or months later) and find, whoops, you blew it on one or some of the comps. I have been at this over 45 years, and have had the experiences you folks have and have gotten smarter about how to go about it. There are some tricks of the trade that time teaches. An easy one is drive a truck, not some go-cart. Good luck, stop whining, get higher fees and do it right. Or go do something else. —Jack Kennedy

Concealed Defects, Changing Neighborhoods
I agree, taking photos can be challenging at times, so much so I have become careful of my environment, time of day, etc., and especially of those observing me taking photos. It comes with the business. Maybe your company is purchasing loans originated in SoCal, up in the area off the Antelope Valley Freeway. There are a lot of oil derricks up there. You get sent out as the reviewer to take a look at the properties and much to your surprise, you find oil derricks in the open areas behind the homes, that somehow don’t make the MLS or appraisal photos. Nor are they mentioned in the reports or listings.

I cannot tell you how many times I went to a home that is fine in the MLS photos, but the adjacent properties are not, and this may have impacted the price of that property. There are many things you cannot tell from photos in the MLS. It’s been my experience that agents don’t place anything negative in those MLS pictures. Driving by the comps is not just about seeing the home, but about seeing its environment and perhaps motivating factors impacting the price paid. Like you, I don’t like having to drive all the comps. However, I recognize the importance of doing so, even if on occasion, I have to deal with someone who’s upset about me taking a few pics.

I’ve been appraising in my area for more than 40 years. I’ve been in some of these neighborhoods hundreds of times, yet I’m amazed at the changes I see happening in the area in the short time since I was last there. Having appraisers take a current photo is a check and balance system, designed to keep honest people honest, and it helps appraisers keep up with various principles of value at work in the neighborhood. —Patrick

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Not Feasible
Here’s another problem with comp photos that is not typically mentioned; it requires the appraiser to choose their comps before seeing the subject property. Can any professional appraiser make a credible argument as to why selecting comps before seeing the subject property is better than selecting them after? Of course you can’t; we all know it’s better to select the comps after seeing the subject property, preferably after the sketch has been completed and the appraiser has had a chance to confirm all the subject’s features and influences. You can select comps after seeing the subject property then drive the comps, but that isn’t feasible with the fees we’re paid and the time constraints to make an extra trip into the field to shoot comps. —David

Why Cut Your Own Pay?
As a vocation, I don’t get the argument that people make to take away a value-add. Is the end game that somebody else goes to the subject and everything else is online and all that an appraiser does is some market analysis, adjustments and offer an opinion? What will this take? An hour? So you get $100-$150 for an “appraisal”? You should be getting paid for the WHOLE PROCESS, so why cut out any of it? Spare me the “efficiency” concerns—if you think that a lender or AMC will not want to cut back your pay for this, then you are fooling yourself. They already want to cut pay for a 2055 even though they take no less time to do effectively; I can go inside and look and measure in less time than it takes to scour listings, assessor sites, etc. If you want to do less, somebody will want to pay you less, period. In the end, you will do the same amount of work in a different way… for less money. —Doug

Shotguns and Accuracy
You have eloquently expressed my thoughts and arguments concerning photographing comparable properties. I actually did have a shotgun pointed right at my face. I have been chased with people brandishing baseball bats, tire irons, and once, a sword-like weapon. I’ve been doing this almost 14 years and it never gets easier. It affects my mood, creates enormous anxiety and stress, and makes me feel like a pervert when kids are out playing in their driveways. I do not blame homeowners for attempting to protect their homes and neighborhoods. Furthermore, the comps are selected based on their time of sale so that corresponding photos are more accurate than “today’s” photos. Photographing comparables can be dangerous and does not contribute to the derivation of an accurate valuation of the subject. Thanks for writing a long-overdue article of such importance. —David Edward Cohen

About the Author
Isaac Peck is the Editor of Working RE magazine and the Vice President of Marketing and Operations at OREP.org, a leading provider of E&O insurance for appraisers, inspectors and other real estate professionals in 50 states. He received his master’s degree in accounting at San Diego State University. Reach Isaac at isaac@orep.org or (888) 347-5273. CA License #4116465.

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Comments (11)

  1. There are, as many have said, pros and cons to the comp photo debate. There are several premise’s for each – something there that the Broker ‘selectively” cropped out of their MLS photo, etc. that you see in real-time. But with the advent of high-quality aerial imagery, probably 99% of those types of things are going to be caught when you do your due-diligence research. So, we shoot them for FHA and others no matter what. Well, (and especially on rural and mountain properties) I like to save time as much as the next guy. So if I don’t suspect anything out of the ordinary or I am familiar with the location and am already aware that there is nothing there to be a problem, why spend hours (yes sometimes its hours) driving to shoot a single picture of a single mailbox. Let it be the Appraiser’s call.

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  2. I believe it is necessary to drive by comparable sales to get a better feel for the neighborhood and differences in the properties, however, I do not believe it is necessary to take our own pictures. That is the part of the process that puts us at risk, whether it is a busy road that is dangerous to slow down on or people at the house that are alarmed by a strange person taking pictures. With more children at home and more people working out of the house as a result of the pandemic, it is more common to be questioned. It is typically easy to diffuse the situation just by explaining what we are doing, but people do get unnecessarily annoyed and there have been a few times in my 25 years of appraising where I have encountered very angry people. We are on the honor system for many aspects of the appraisal process, so driving by the comparable sales can just be another one to add to the list. Pictures from the time of sale are more relevant anyway.

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  3. Put a license plate frame on your car.
    Mine has the words: “Real Estate Appraiser” at the top of the frame and there is one on the front end as well as on the rear end of my car. This one small addition to my appraiser toolkit has precluded ALL of the incidents that I have occasionally (rarely) encountered with local residents when driving comps in my 30 year appraisal career.
    I would be willing to bet that 95-98+% of appraisers have NOT taken this simple step.

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  4. With all of the technology today and also adding to the mix, the paranoia people have these days, comp photos are a waste of time and a total pain. Especially when you have the homeowner or the renter or nosey neighbor flag you down because they think you are with the CIA and they are SO important the CIA must be taking pictures of their homes in broad daylight with every other house having surveillance for…. what reason? Who knows? I was chased by a woman who thought I was having an affair with her boyfriend and was casing the house to see if she was gone. That was pretty scary. But, I have been confronted too many times to count while in front the comparable.

    All we are doing is taking an exterior photo of a house. We are not going inside. If it’s a neighborhood you haven’t appraised in before then maybe it’s worthwhile to make the drive around the neighborhood. But, most of us know the areas we appraise if we’ve been doing it long enough. The MLS photo should suffice, providing the agent took good photos. If not, then it’s a good idea to take your own. I prefer to put my focus on the subject property and provide the most detail I can about the property. I want the powers that be to know there is nothing that can substitue the physical inspection of a subject property, becasue you just know they are trying to figure that one out.

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  5. by William A. McCann

    Having completed hundreds of appraisal in “urban renewal” zones of Chicago, I had many experiences, not just in inspecting the subject but in also inspecting possible comparables. In one such instance, I parked my car on an arterial street immediately behind a bus stop to take a couple of quick photos of a comp and knowing full well this neighborhood was considered dangerous. I looked up and down the street–got out of my car and began focusing the photograph. At that moment, a Chicago Police car stopped behind my car and a very large african-american policeman got out of his car and walked up to me. He said in very authoritative language, “What the hell do you think you’re doing”? I replied that I was a real estate appraiser and was taking photos for an appraisal I was doing for the Chicago Dept. of Urban Renewal. He replied, “Since you’re a city appraiser, I’m going to stand here until you get your “white ass” back in your car and get the hell out of here”! I replied very politely, “Yes officer” as I got back into my car.

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  6. It would appear this topic has become one of the great debates. Having read the comments left by fellow appraisers, it would appear I must live under the right star. We are people first and appraisers second. That said, how do you carry yourself, like prey or a predator. Crazy as that sounds, what you throw off for vibes is what aggressive people pick up on. From the type of vehicle you drive to your dress and overall mannerisms. Having been appraising for over a 43 year term now, I like everyone else, has entered into sketchy neighborhoods with the lounging street lizards eyeing your every move. I will admit, my background includes some tough sledding, having been shot, stabbed numerous times, etc., etc., I have always and still do carry a weapon, everywhere I go. I have never, ever had any type of an issue with anyone while working as an appraiser. The only incident I can recall was when a thug looking guy came by asking (politely) what I was doing. No fuss, no muss. I have and continue to be sure to know my comparables and yes, I do take file photos. I do not typically employ them, but rather, I use MLS file photos for my reports. In my practice I do a considerable amount of litigation work. During litigation, I have been called upon to produce evidence of having familiarity with my chosen and employed comparable sales. That is one of those instances when a picture is worth a thousand words. All good using MLS photos, until you get called out.
    Stay well and always keep your head on a swivel. Bob

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  7. We lose focus of the real issue when we speak about “driving comps”, this discussion needs to stay focused on the requirement of taking pictures of the comparable sales. Yes, I believe it’s very important to drive the market area and become competent when using comparable sales and making adjustments. This discussion/debate becomes very muddy when there’s a crossover between driving comps and taking pictures. Homeowners are generally fine with individuals driving past their residence looking at their home, but when the vehicle slows down, window goes down and a camera comes out, the situation changes. Hiring an Appraiser to perform an appraisal is just that, to trust that the Appraiser is competent in the market area, drives the comparable sales and provides a clear and concise report that abides by appraisal standards.

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  8. There will never be a photograph of a comparable taken by an Appraiser that is current as of the day the comp closed. Anything after that is subjective for condition at best. IF it is for proof that the comp was viewed by the Appraiser, then our word means nothing and the whole report should be done by non-PROFESSIONALS. IMO

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  9. I agree that photographing comps doesn’t make sense and is dangerous. When I first started appraising, it was in Compton, CA. I drove by a home and noticed there were people in front, so I continued on around the block. Before trying again, I stopped 3/4 the way around and pulled over. Suddenly I saw a young guy walk around the corner and yell in my direction, “HEY 5-0″…which is slang for “cop” in Los Angeles. Clearly this guy was not afraid to call me out for possibly being a police officer. Needless to say, I opted for no comp photo that day. Also though, most of my experiences in Compton were very positive with homeowners and never had any other issues. BUT, also to be noted, my fellow appraiser in the office heard gun shots during broad daylight and saw a guy fall out of his car with a gunshot wound. As new appraisers at that time, clearly it wasn’t worth the small fee we were getting for doing inspections. Taking comp photos only creates potential problems. I say that it’s reasonable to ask an appraiser to “drive” the comps, but the photo from the time of sale is more relevant.

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  10. I charge for driving the comps. In rural areas this can add $200+ to the assignment. If my client does not want to pay me for my time, they can go elsewhere. Most of the time they don’t. It is my favorite part of this job that I have been doing for 35 years. I am getting paid to drive country roads where the scenery is amazing while listening to my favorite tunes and every now and then stop to take a picture of a gate. Yes I have been confronted a couple of times. One time was a little scary. I now carry a gun. No big deal. If you mostly do suburban or urban work, taking photos does not take much time. It might add 15 minutes to the assignment. It is these suburban assignments that are generally a waste of time taking photos, but until someone can figure out a way to say “take photos of comps if you feel its necessary” then I guess we all have to do it so CHARGE for it.

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  11. This comment below is just for my friends who are in the real estate appraisal business!
    There is a great debate over personally taking comparable photos or by using the MLS photos. The one argument in favor was that if the appraiser doesn’t drive to each comparable, he or she may miss something on the street like the location near a gas station of sewage treatment plant. My comment and thoughts follow:
    With Google and so many other ways to see everything on the street, even by satellite, the argument that driving the comps allows you to see something you would have missed is simply ridicules.
    There is no need to continue with old outdated methods that were necessary before computers and the on-line resources available today. The advantage to not having to drive out to take a comp photo is that you may discover a better sale that didn’t show up prior to the inspection.
    You may also find during the inspection that the subject has something different than reported or expected. Now, for free, you have to go out after going back to the office, just to take new pictures.
    All of this has “zero” impact on your opinion of “market value”, not to mention that the property may have changed since the purchase and it no longer represents how it was marketed.
    Dr. Dan Tosh, PhD, JD
    AQB Certified USPAP Instructor

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