Original Comp Photos: Dangerous, Unnecessary


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Original Comp Photos: Dangerous, Unnecessary
by Damian Downie, CEO of Downie Valuation Services, Inc. 

I’ve been meaning to write this for a long time and what happened today is the straw that broke the camel’s (appraiser’s) back.

As I do many times a day, I was taking comparable (comp) photos for an appraisal. This one in particular is a condominium, so I was taking photos of two condos in a competing complex. There was a gate into the property, so I stopped across the street and snapped a photo of the gate.

Three minutes later, about a mile from the site, I looked over to my right out the passenger window, and I saw a man holding his phone up and pointing it at me. I asked him what he was doing and he angrily asked me why I was taking pictures of his car. He had a scowl on his face and so much anger in his voice that I seriously expected to see a gun pulled next. In that part of Sacramento, it would not have been a shock. When I tried to politely advise him I was a real estate appraiser, and was only taking photos of comparable sales, he did not want to hear it. He seemed to get angrier saying, “I’ve got your photo (mother…F-bomb).” Fortunately, I was able to drive off without it escalating but it certainly could have.

Will it take one of us getting shot or killed to remove this archaic requirement of driving comps?

This was the third time I had been chased down by someone in the last year alone, and I’m not the only appraiser to go through this. I would bet most full-time appraisers have similar stories. This can and should be avoided. Each time something similar happens, the angry/concerned party has either willfully refused to listen to my explanation, or wasn’t able to comprehend what I was saying. Many people do not know what an appraisal is, and most do not understand what our job entails. In other words, because most people don’t know we take photos of comps they don’t understand why strangers are taking photos in their neighborhood. They are quick to assume we are up to something worse. Very few times a person will say, “Oh ok, I was just checking. Have a nice day.”

Ever since appraisals became necessary, we have been required to take photos of each and every comp that we use in our reports. The reason for this is so we can get a clear picture of just how comparable these properties are to the subject. To evaluate if they are comparable in location, condition, quality, design and appeal, among other things. When this requirement was set, so many years ago, we did not have the technology that we do today. Back then, we could not see detailed photos with the many tools we have on the Internet. We didn’t even have the Internet back then. We do now, and it’s time we all agree that photos from the Internet are not only more helpful than driving comps, they save appraisers wear and tear on their vehicles, remove worry or concern from homeowners or tenants, save us time and money and keep unnecessary traffic and often lost appraisers, from driving up and down city and rural streets where children play.

As competent appraisers, we need to be informed of all aspects of the neighborhood, in order to provide a credible report, but proof of our neighborhood inspection isn’t necessary. Many tools we have today allow us to get a very clear picture of everything a drive-by of each comp would, and more. One is Google Earth, that allows us to see everything around the subject property as well as the comps we would use or consider. We do not need to drive around each side of every comp to know they are on, or backup to a busy street, commercial property, have power lines, etc. Satellite images allow us to zoom in and see these things right at our desk, and most of the time, this is even better than a personal inspection. With regard to inspecting the exterior of each comparable property, I doubt that I am the only one who makes sure to go fast enough so as not to be noticed by a potentially angry resident. The need to move quickly reduces the value of the in-person inspection in the first place.


We cannot sit there for several minutes and take notes because we know that the longer we do, the more probable it will be that there will be a problem or confrontation. MLS photos not only show us, in detail, what that property is like, they show us what that property looked like as of the date of its sale. And that’s really more important, considering the fact that by the time we see them, it has been months or more since the sale, and improvements are likely to have been made. This, along with the other benefits listed above make online photos a much better alternative.

MLS photos, along with allowing the appraiser and the reader to see what the exterior of the property in question looked like, as of the date it was listed, allow us to see detailed photos of the interior. These photos are clear and we are able to zoom in or out so we can get a very strong idea of its overall comparability to the subject property. Driving by them and taking photos of properties owned by proud and concerned people, is completely unnecessary to provide a competent and credible value, and an overall supported appraisal report.

Many of us perform appraisals in rural areas with parcels of more than an acre in size. Typically, when we take photos of these properties, we cannot even see the improvements, and wind up with only a photo of a driveway. In these cases, we include the photo of the driveway and then supplement it with an MLS or other online photo. We sometimes spend an hour or more driving through these rural neighborhoods because the comps are so far apart and the majority of photos end up being of driveways. This is costly in multiple ways, and overall completely unnecessary because an MLS photo would have been more than enough for credible results in the first place. In the end, the MLS photo was the only real photo data provided for the reader.

Our industry is constantly changing, and it often adapts to technology. When I first started in this business 17 years ago, my supervisor told me stories of how he used to paste actual pictures to reports, and that he had to submit full appraisal reports via US mail. Why don’t we do these things today? It’s simple. We have adapted to technology. Our current technology allows us to attach digital photos to reports and submit them electronically. Why haven’t we adapted to the technology provided through Internet tools to eliminate the ridiculous needs of our clients and Uniform Standards of Professional Appraisal Practice to drive past and take photos? I hope we can get together and make this change for the better for all involved. Let’s embrace our current technology, and move forward towards safer and more efficient appraisal work.

Bottom Line
When HVCC was put into place, appraisers lost a good portion of our fees to AMCs and other middleman type companies. With the abolishment of the requirement to drive past and photograph all comps, appraisers could free up hours per day towards better and more efficient productivity. Our clients insist we are making “customary and reasonable fees” but that is simply not true. Fees have come back up over the last 14 years, but they are still not where they used to be. Reducing this burdensome requirement could allow increased productivity that raises our bottom lines back where they were before 2006.

Of my 17 years in the appraisal business, I have been in the field for 12 years and spent five working quality control for an AMC. I know many appraisers and have spoken to most of them about this problem and need for change; not one of them has disagreed with my argument. I even discussed this with a staff appraiser from the California Bureau of Real Estate Appraisers, and he agreed with me 100%. He suggested that I write to Fannie Mae if I wanted to really help make a change. I will absolutely do that, once this article is published.

We have the technology to make a change for the positive, so let’s use it. It’s cost effective for those of us who deserve our customary and reasonable fees, so let’s get those fees. And it’s safer for appraisers and residents of our communities, so let’s be safer. That man from the Sacramento condominium complex did not need to have to worry about his property or safety, and I did not have to worry about mine. Let’s come together and make the right decision. MLS photos and other online tools are sufficient, so let’s use them.


About the Author
Damian Downie has been in the residential appraisal field for 18 years. He is the Founder and CEO/Chief Appraiser of Downie Valuation Services, Inc. in Roseville, CA.

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Comments (77)


    Get magnetic signs for both sides of your car/truck, the postal service does, some county assessors do- clearly display that you are an appraiser- 99.99% solved- there will always be someone but it explains preemptively what u are doing. I routinely drive 15-25 and more comps per assignment, or, all that are available. HOW DO U KNOW WHICH 3-6 YOU ARE GOING TO USE? I do good work. No original comp pics is a skippy’s dream !

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  2. Driving comparables does allow one to get a good feel for the neighborhood, and realize how truly “comparable” one property is to another. But other than getting a feel for the neighborhood, it is not valuable and can even be misleading, as you are comparing the property today to it’s condition in the past (this seems to imply an extraordinary assumption). Many times a property is significantly renovated or improved after sale. Perhaps a new porch was added, a new roof installed, or the exterior was upgraded. Then your photos are actually misleading, as they indicate a superior property than what actually transferred at the time of sale.

    But the biggest issue with requiring new comp photos with every assignment is that appraisers are not actually using their inspection details when selecting comparable sales. For logistics reasons, when going on assignment, appraisers typically select their comparables *before* even seeing the subject property. It is simply not cost effective to inspect the subject, then research and find the most similar sales, and then drive by and look at them. So the appraiser selects these “comps” sight unseen, and then when he gets back to the office after viewing the subject property, will attempt to use these comps in the report. Often, even if a better comp is available, it will not be used, because it is simply not cost effective to make a second trip out and take additional comp photos for a < $500 fee..

    When appraising commercial properties, I am often using different comps after I see the subject, because then I understand better the layout of the property, and what competing properties it is most similar to. But with residential properties this is extremely difficult due to the original photo requirement for comps. Expecting appraisers to select comparables ahead of time based on MLS photos alone and then include their own photos after the fact is illogical. Either give us a high enough fee to make two inspections, or do away with comparable inspections entirely.

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  3. I have been an appraiser for 43 years. I don’t mind driving the comps, but I would prefer to have the option to use either an original photo or MLS photo, as appropriate. I don’t think it is “whining” to point out that I was once threatened with a gun. There are some crazy people out there & there may be some situations where it is not practical or reasonable or even safe to photograph some stranger’s house.

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  4. Driving the neighborhood and having in-depth knowledge of the subject’s market area are the key points, not taking a specific photo of a comparable. Other than a visual from the street, we really don’t “inspect” comparable properties. I don’t take one step onto a non-subject property for obvious reasons. I use the MLS to obtain 90% or more of the comparable information, including interior and exterior pics. The question of using MLS photos though is simple. Right now, we are required to take our own pics. so do it. I get that, and that is what I do. However, the argument for continuing this practice, in my opinion, doesn’t hold water. When a comp sells, that is the home is listed in the MLS as sold, a market transaction has occurred. What the home looks like at that specific moment in time is most important. What happens to that home after the sale and prior to the effective date of your subject is irrelevant, both good or bad. I’ve driven by comps that have had a complete make-over since their sale, and I have seen homes completely trashed. What the comp looked like at the time of sale is almost always the best indicator for the price that was paid for the transaction you have reported in your appraisal. I agree with most that we should be using the technology available to us and it bothers me when I hear complaints from lenders and AMC’s about how long it takes to turn an appraisal. Well, I can guarantee you that in a lot of cases a good 2-3 hours of drive time could be removed from the process, and more for rural properties. In many cases it is the difference of submitting an appraisal in the morning, rather than the end of the day or next morning. But for now, we do what we must do, take the pics people!

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  5. One time I was taking comp pics in a typical tract subdivision which was not located in a “sketchy” part of town. As I was at the stop light leaving the neighborhood, I noticed a guy getting out of the truck behind me & 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 car with 2 ladies pulls up beside me & they start yelling at me asking why I was taking pics 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 all while we’re driving along side each other about 40 mph. I see them all pull into a gas station as I continue on my day. About 2 hours later I get a call from my wife, who is at home, asking if I took a pic of someone’s truck. I was totally dumbfound & asked why she asked that. Apparently, the guy with the truck showed up at MY HOUSE & confronted my wife about why I was supposedly taking pics of his truck. She explained to him what I do & he accepted her explanation & left without incident. But what if he hadn’t & decided to harm my family? Comp pic taking is absurd & dangerous. Next time one of you other appraiser’s accuse us of whining about taking comp pics, ask yourself how comfortable you would feel if an angry homeowner showed up at your actual home.

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  6. I think inspecting comps is a necessary part of our practice. Many times I see something that I would have missed in photos (powerlines, 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 photo 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 all is cool.

    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 the picture of a mailbox?

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  7. One thing that I haven’t seen mentioned is that you aren’t the only appraiser taking pictures of someone’s house. Nearly every other appraiser is driving by with their cameras pointing into someone’s house. If it’s an area of high HUD loans, it goes on for a year after they move in since the photos have to be seasonal. I have had people yell at me “could you people stop taking pictures of my house! What is wrong with you?”, and I totally get what the poor people are saying. I do know that driving by the comps is essential, but the picture thing is dangerous and creepy.

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  8. the reason MLS pics are OK in the new bifurcated products is because that process would NOT WORK if comp pics needed to be taken, so magically it is OK to use MLS pics. 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 more times that by angry people concerning the picture taking.

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  9. Very true, thanks for writing this. I’ve had someone get in their car, and begin to chase me around the neighborhood screaming and honking their horn. Once I approached a stop sign this person tried to park next to me. I opted not to get in any drama, so I never acknowledged the person and drove away. What did I think while I was being chased? I was thinking what if she pulls out a gun or tries to attack my vehicle. In other area where there’s known criminal activities, it’s scary taking photos while there’s obvious signs of danger around. I’m not risking my life for the bank. If I feel unsafe, I’m skipping. That’s it.

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  10. 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 are 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.

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  11. GoogleEarth not 100%…it just steered me to the wrong house yesterday…I had driven by the house already but wanted to get another look and was confused…that’s not my house…and it wasn’t…actually driving by to view the neighborhood is still the best bet…photos probably not, everybody has a “ring” now and you’ll end with your pic and license plate on NextDoor and the police notified

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  12. I have had a shotgun pointed at me, near-miss vehicular accidents, people up in my face wanting to know why I am taking photos of their house and calling cops, thinking I am up to no good. In this day and age, driving around wasting time, gas, productivity to take pictures of pictures that already exist is the definition of STUPIDITY.

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  13. Dangerous? No. In more than 35 years of doing appraisals, I’ve had exactly 2 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 PI. 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). Unecessary? Maybe however, 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 of them 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 appraiser who routinely use MLS photos and never bother to drive by the comparables. Oh.. none of us, of course.

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    • I’m glad you don’t think it can be dangerous, but I have been threatened with a gun. There are some very crazy people out there. I would like to have the option to take original comp photos or use MLS, as appropriate.

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  14. 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 evverything 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 field reviews many times show 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

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    • The author did not state that we shouldn’t be driving the neighborhood. We can and should still do that, but there is absolutely no need for the appraiser to be taking a picture of a comp (unless it is not in the MLS, about half of sales in my market). And I certainly don’t need to take new pictures of the same house for every report I use it in, regardless of what season it now is. Despite using my own original comp photo in a report, I have been asked to take a new one “with snow” or “without snow”. Yet, I have taken pictures on the same day, some of which have snow on the ground and some of which do not. This is ridiculous busy-work that provides no useful information to the reader, especially if changes have been made to the comp since the sale. Also, this “requirement” does not keep the unscrupulous appraisers out of the business, they just find ways around it; it only wastes the time of the good appraisers.

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  15. -Some comparable photos are from MLS. MLS photos are considered reliable and the greatest indicator of a comparables condition at time of sale which could be up to 12 months prior to date of inspection. The market area is known to the appraiser and in most cases, the comparable has been driven by during the course of business.

    and another one

    SOME COMPARABLE PHOTOS ARE FROM MLS AS DANGEROUS CONDITIONS RELATED TO POTENTIAL CRIMINAL ACTIVITY DID NOT ALLOW SAFE ACCESS TO THE FRONT OF EVERY COMPARABLE. MLS photos are considered reliable and the greatest indicator of a comparables condition at time of sale which could be up to 12 months prior to date of inspection.

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  16. I agree with the author completely. Taking comp photos is often 40% of the time it takes me to complete a report. If I pull comps before seeing the property so I can take photos when I see the subject they are often not as relevant as I thought once I see the subject property. If I wait to do comp photos after the fact it’s usually 3 to 4 hours of driving back to the area to get photos. I live in a rural area and find myself taking driveway photos at least as often as I take photos of actual houses. I’ve been yelled at, chased multiple times, had the police called on me 3 times and even had a resident block my exit from a dead end street. There isn’t a neighborhood in my coverage area that I haven’t driven through a hundred times. I know where all of the adverse neighborhood features are, I don’t need to see them a hundred more times. All of this extra work and risk is a waste. I saw an interview of someone from Fannie Mae on this or another similar site about bifurcated appraisals. A question was asked about whether the appraiser would still be required to take comp photos. The Fannie Mae rep stated that this was an out dated practice and that with so much information available on-line there was no reason to drive past a house. I agree but it’s too bed they don’t see it that way for conventional appraisals. Doing away with in person comp photos would also cut down considerably on appraiser turn times and ease the alleged appraiser shortage, which was the stated purpose of the bifurcated appraisals in the first place.

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  17. Mwahahaha …. luv you folks, especially when I’m in court watching you getting your butts handed to you in a sling… clients luv that action

    Clients also like having a reviewer point out that your appl sucks cuz you don’t know your comps as You didn’t want to drive them

    A lot of the time MLS/google/etc are 5-8 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 prepared yourself (weeks or months later) and whoops, you blew it on one or some of the comps

    Have been at this over 45 yrs, had have the experiences you folks have and have gotten smarter about how go about it. There are some tricks of the trade that time teaches. An easy one is drive a truck, not some go cart …. there are several very good reasons for that…. you figure it out.

    At one time an appraiser could make good money and stay out of trouble … not anymore, you want good money, get ready to big hours or get yourself in trouble. Always fun hiring attys to defend you …. have had many colleagues go thru it, I managed to avoid it.

    I keep doing this cuz I don’t work for low fees and luv getting out of office, dealing with prop owners etc … and hunting season is only 4 months long and my grandkids aren’t into fishing these days.

    Course I’m learned 40 years ago that you don’t get rich doing appraisals…. and used the appr to pay bills while I also did other things accordingly.

    I saw how this biz was going 20-25 years ago and refused to let my kids get into it.

    Ok, off my soapbox ….

    Good Luck ….. quit whining …. get higher fees and do it right….. or go do something else

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  18. Thank you Damian for your courage. I am an appraiser in Pennsylvania for 29 years. I have seen our profession evolve over the years. Federal regulations imposed are never practical but once imposed are difficult to release. We as appraisers must take back our profession and demand practicality and reasonable fees. I do many rural properties and like you are frustrated and talk to myself driving past comparables that I have already viewed from the MLS records and Google that present a better representation than the driveway or trees I view from the public street. In these days of preserving the plant I would think FNMA/Freedie Mac, the FHA and VA would be more senstive of burning fossil fuels to take comps photos of nothing. Technology is a great tool/assist. Why can’t we utilize it. Michele – Pittsburgh, PA

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  19. THANK YOU for writing this article. I have actually considered making a home video of what is required in order to take comp photos as I am doing them (taking one hand off the wheel to hold a camera and your eyes off the road….its one of the MANY things that makes ZERO sense these days and I am OVER IT. So, thank you for having the courage to say what we are all thinking. I say, lets start a petition……..https://www.change.org/start-a-petition

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  20. Agreed! So what can we do? I live in Coeur d’Alene in northern Idaho. As soon as I leave town into rural areas I deal with lots of private roads, no trespassing, poorly maintained and remote access roads, snow and ice, and people that prefer their privacy. Nothing wrong with that. What’s wrong is appraisers creating uncomfortable situations trying to take a photo of a driveway leading into the woods where you can’t possibly see the improvement, and then inserting an MLS photo anyway so the reader can see what the property looks like. Bypass infringing on people’s privacy and endangering the appraiser, and step up to utilizing our modern tools.

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  21. Clear, descriptive photographs showing the front, back, and a street scene of the subject property and the front of each comparable. The subject and all comparables must be appropriately identified. Acceptable photographs include original images from photographs or electronic images, copies of photographs from a multiple listing service, or copies from the appraiser’s files.
    Photographs of comparable rentals utilized in the Small Income Residential Appraisal Report (Form 1025) are not required.


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  22. 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 those observing me taking photos. It comes with the business … not all photo takers are appraisers and not all are innocent.

    What if you were an undercover police officer like my brother was, and a guy drives by and takes pictures at an angle of the house next door. It looks like he may be taking photos of your kids playing in the yard … maybe you’ve had a few threats in your time on the police force … how would you respond?

    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 with appraisals to take a look at 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 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 pics.

    Driving by the comps is not just about seeing the home, but more 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 that’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 100’s 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 help appraisers keep up with various principles of value at work in the neighborhood.

    Thanks for the article and perspective …

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    • I always get bashed by other appraisers when I bring this up. I am called lazy and other derogatory remarks. I drive all my comps, and take photos . . .but I have been shot at twice. I have been nearly arrested more times that I can count. I have been chased by minivans numerous times (Fortunately I always drive a fast car), nearly getting into accidents. I have almost got hit by cars, because I have to get some distance across the street to take a photo of the property. FHA makes it worse because they demand an angle shot of each comp.

      I agree that we should drive most comps, but what is funny, the most expensive homes that are in gated communities do NOT require a photo.

      Here is the solution . . .do not require original comp photos, but DO require that we should drive the comps. This is not a perfect solution, but is the only one that works. I am tired of getting pulled over by cops or getting chased or getting shot at.

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      • Oh yeah, almost forgot. I have been accused of taking photos of peoples kids in the front yard, even when there were no kids in the yard. In this paranoid society, this will happen more and more

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  23. I agree with the author completely. 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 it isn’t feasible with the fees we’re paid and the time constraints to make an extra trip into the field to shoot comps.

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    • Exactly. I can’t pick comps in advance. I’m an urban appraiser in a very active market. If I draw a 3/4 mile radius around the subject in the MLS I can most times have a couple hundred comps to choose from. I go back to my office and actually pick the best comps to use and put in the MLS photos. If the lender insists on original photos, I either don’t work for them anymore, or I tell them that I will need an extra day and a trip fee of $100 to take original comp pictures.

      The difference between me taking photos with a cheapo camera vs a professional photographer is huge. People who say that the agent/photographer takes MLS pictures to present the property in the best possible light or maybe it burned down since the MLS photos were taken (So what?) Does that not make it a legitimate sale? If the exterior is staged and only presents comp in the best light with new mulch or landscaping, (Again, so what?) If that staging creates a false impression of the property, then I guess we shouldn’t rely on the interior pictures either for property condition. We should just make the extraordinary assumption all comps are in C4 condition because the interior pictures are staged to make the property as marketable as possible.

      After appraising for almost 40 years I have driven past every damn house in the city 3.7 billion times and I know that there are no oil rigs in the rear of the house or factories emitting fumes of some type. I know my market.

      If you have time to waste have fun driving around in circles for a couple hours and then have to drive back out again because you didn’t take that picture of a better comp you found when writing the report, or have fun trying to fit that square in the round hole of the grid page.

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  24. 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 do 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 and stuff. If you want to do less, somebody will want to pay you less – period.

    The VALUE ADD is having a valuation professional have eyes on the subject, the comps and the neighborhood. What easier money is there than getting paid to drive 2 hours to take photos of driveways – if you are not getting paid more for this, then you need to evaluate your business model. I will gladly drive 4 hours to look at driveways and specs in the distance, but I get paid extra for it and it is not a waste of time. Most of us do neighborhoods in town for the majority of our stuff – I do rural and mountain stuff and NOBODY has ever had a problem with photos that I took from a prior assignment driving by, so if you are driving by for every assignment, then you need to look at your business model or client list for this too.

    This would be an easier argument if people just said that they are lazy, but all of you will be whining down the road when a report is paying 25% less for you not to look at the comps and you will spend nearly the same amount of time looking at listings and Google Earth than you would have spent just driving by. In the end, you will do the same amount of work in a different way… for less money.

    Honestly, how many of you would take a 20-25% fee cut not to have to drive by comparable sales? Anybody? It is a fools argument to think that you can cut out this step and still get paid for it.

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  25. My local peers and I have been saying this for years now. I agree with everything the author said. Taking comp pics is also a safety hazard when on a busy street. Lots of screeching brakes when the drivers behind us aren’t paying attention.
    Now I hope someone can get this to FHFA for consideration since they’re relooking at hybrid/bifurcated appraisals again. Everything in this article shows how appraisers can save time in providing a finished product to the client and that’s the main driver of hybrid/bifurcated appraisals. Most appraisers I know would much rather do the inspection and measurements themselves instead of relying on an untrained individual or tax records. More time would be saved if the appraiser did not have to go back out for the comps photos, and the data in the report would be more reliable. Just my 2 cents.

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  26. There is a degree of appraiser job security in maintaining the requirement, however I think the practice of some lenders requiring photos of the rentals is counter productive and often creates the need for a second trip.

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  27. I agree, people are so paranoid now about others lookin at their home &/or taking photos…..it is a little dangerous,I think…

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  28. Good article and I agree wholeheartedly. One other more recent stumbling block we have encountered due to the pandemic is that many are working from home and we are more likely to be seen taking a photo. This may continue after the pandemic since we have had a year to perfect “satellite” working.

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  29. I have been saying this for years…a decade or so now. Driving comp photos is an outdated practice given today’s technology. The time wasted driving around for a pic of a house only to go back to the office and do what?…pull up the MLS photos to look at it when writing your report. Regardless of what the house looks like when drive by it or if its even there, the data you are using is when it sold. If you took a picture of a vacant lot where the home use to be and included in the report with a comment its no longer there (six months later) the first revision request you will get is for you to include the MLS photo showing the property. Oh, so now its ok to use…Really !! Fannie Mae has debunk the comp photo requirement already…Covid Desktop. Because of the pandemic its now ok to use ALL mls photos for the subject and comps. They are making loans with this. This is even more proof they know this is an outdated requirement. It needs to go away with the streamline.
    While everyone’s time is difference I can say it would save me 30 minutes on average per file in the field. Lets say one does 30 appraisals a month that 30×30= (900 min)/60 = 15 hours. That almost two work days per month. This does not include doing all the research on each file to going to the home(s) on a given day because you have to have the addresses for the photos. Again more time wasted when you could simply call/email, schedule, look at properties back to back and then back to the office to start writing reports. I bet one could look at two or three more properties in a day if they did not have to spend all that time researching before heading out.

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  30. No reason to take pictures of the houses themselves, I could see intersections as a compromise to “prove” you were in the area. Even this is unnecessary as we are already stating we have geographic competency, but I understand the value in order to hold off the call for replacing us entirely. I have had similar experiences, there just isn’t enough public knowledge about what we do or even laws in general (anyone can take a picture of a house from a public street).

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  31. by An Older Appraiser

    Being from the class of 1985 and back then comp photos were optional and paid $25 more. I could not provide an appraisal with credible results without visiting and taking current photos typically as of the effective date of value. If there are new improvements updates to the comparable sale this is telling the appraiser the buyer is willing exposed capital to his or her home and was it a possible tear down. Taking comparable photos assist my findings of facts and creates product knowledge of the market.

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  32. I agree with James Turner. An appraiser needs to drive the comps to perform a credible report. I am in the DFW area and many subdivisions are being rehabilitated. A comp may have sold and then was razed for a new improvement. The motivation of that sale is not the same as a market sale – AND, the comp does not now exist. Internet pictures do not always ring true about the property and/or its condition. I have had an MLS that totally had a different house in the photo!

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  34. I agree 100% and the same thing has happened to me. I’ve been chased, threatened etc.. I’ve been appraising for 33 years and I had to tape photos on a report, do my sketches on pencil, copy a map, rub on graphics and hand my pencil written report to a typist. For years, but the use of original comp photos is not Uspap , it is a Fannie Mae Rule. Uspap has no photo requirements

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  35. I could not agree more. All of your reasoning is completely valid. I know the powers to be want to streamline the mortgage lending process and this would be one step in that direction. I think the only situation you may have left out was getting “rear-ended” on a busy road while taking a comp photo. Can we start a petition?? I would like to be the first to sign.

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  36. 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 the starts and stops of gathering comp photos.

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  37. I so agree with Mr. Downie. I have been chased by homeowners, stopped by police, & risked being hit by traffic trying to snap a photo on busy roads. I’m in a rural area, & it often takes 3-4 hours to drive to all the comp locations, slowing my productivity substantially. With today’s technology, I feel taking comp photos is a dangerous & unnecessary part of our job. Someone needs to hear our voices before we get hurt or killed!

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  38. This happened to me yesterday. I was taking a picture of a 4 plex and the residents came out confronted me and became verbally abusive. They did not care that I was an appraiser. They did not want to let me leave the property. This American society is reactive and violent. Every movie and TV show depicts violence as the solution. Everyone is so ego driven that they do not have to listen. They just go with their initial gut reaction. This is happening more and more to me and it is dangerous. I would advise never linger in from of any comparable dwelling. And if confronted drive away. This is a big problem and the lenders do pnot care if we are killed.

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    Mr. Downie; 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.

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  40. I have had the very same things happen to me and have actually been detained by a homeowner using her car to intentionally block mine from leaving the area. This was unpleasant and actually illegal because I was in a public place (the street) at the time and, after a heated exchange with me (futile attempt) explaining who I was and what I was doing, she called the police. Good! Maybe they will straighten her out!! There have been other instances too and I don’t like being followed, tracked down, etc., just for doing my job–I don’t need it! To be quite frank, for me, a concealed carry license is next on my to do list. I already have a dash cam and I may invest in a body cam like the police use. The world can be an ugly place.

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  41. Great article and I completely agree that photographing comparable sales is dangerous in many ways. To photograph a home, I have to come to a stop in front of homes which is dangerous with car coming up from behind. Then I have to take my eyes off the road to point, frame and take a picture. This is obviously dangerous. If there are children playing in the neighborhood appraisers taking pictures can be misconstrued. In addition, many of my subject properties are rural properties and the time spent driving from one to another can take hours. Definitely agree, appraisers should not take pictures of comparable sale.

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  42. by The Appraisal Group George Changos

    I have been appraising in Central Texas for 22 years and I have had many run in’s with people when taking comp photos. I have had the police called on me, I have been followed, I have people come up to my vehicle and confront me and I have had people with baseball bats and other instruments in their hands confront me. Unbeknown to me, I even had someone follow me to my home and confront me. Most all incidents are resolved peacefully when I explain what I am doing, but it only takes one incident to go bad. I agree with MLS photos, if they are current and MLS photos are used in many Desktop reports now. With Covid, many Lenders are accepting Desktop products that include not only MLS comp photos, but MLS subject photos if available. How do we correct and make changes to rules we have been appraising with with 40 years or more?

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  43. by Lance Winchester

    I’m in Michigan and several times I have come across the sign in the drive ” if you can read this sign………….you are in range!

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  44. by Stephani Kobussen

    I 100% agree, I have been chased in my car taking comp photos, and just a few months ago, a man jumped in front of my moving car with his arm’s out, and proceeded to angrily approach my car window. I literally screamed which is the only thing that made him stop and realize he was scaring me. Taking comp photos can be a scary business sometimes!

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  45. Partially true points. Just like every misleading (by omission) report I have read over the 38 years (yes, some of us live that long) appraising. MLS photos can be 20 years old. Every broker I have ever known simply copies and pastes if there are photos in the database, no matter how old. The only way I can understand the neighborhood is to be in it. That gives a true perspective of it and the accessibility, visibility and competitive position of the property. For residential properties, it also reflects the “curb appeal” which is all-important. So, yes, I do use all those other alternative to increase my understanding of the comparable property, and photographing the actual improvements can be helpful only when we can get an open view of them, and from close enough to see some details. Just think about the difference in the level of confidence an appraiser has when using a property they have personally appraised in the past as a comparable rental, sale or listing for the present report they are working on.

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  46. More need to lend their voices and speak out about this. We can have “new appraiser trainees” become qualified by using 3rd party photos (those trainees who cannot find an appraiser to take them on for their apprenticeship). Hybrid appraisals where the client says it’s okay to use 3rd party photos, and we’ll supply them! So why not appraisers who are already licensed and/or certified? I’ve been chased, threatened, had the cops called on me numerous times. Cops and parents with children playing outside are the worst. Especially cops (l am lumping Sheriff’s, & State Troopers here too). 98% of the time once I identify myself as an appraiser the owner/tenant understands. Then there is that 2%. However, it only takes one time or it’s a matter of time before someone gets shot and killed for doing their job. When you’re requested to provide a “reconsideration of value” it’s suddenly just fine to use MLS photos. Why? The client doesn’t want to pay additional trip fee and for your time. I’ll ask again, if new trainees can use MLS photos, why not seasoned appraisers? I’ve been doing this for over 24 years now, it’s time.

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  47. “Ever since appraisals became necessary, we have been required to take photos of each and every comp that we use in our reports. ”

    There are certain lenders and clients that may require original photos as well as FHA, VA, USDA, etc. However, it is not an FNMA, FHLMC, or USPAP requirement to take photos of each and every comp used in a report. We are simply required by FNMA to (3) inspect each of the comparable sales from at least the street for work completed on FNMA forms.

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  48. Glad you were not hurt first of all! I was one who felt years ago that you need to drive the neighborhood to get a true and CURRENT feel for that area compared to your Subject. However as time passes and technology improves, I agree with you that with Google Earth (not always available in parts of the Country) and of course the MLS/FMLS detailed photos of WHEN the home sold are more accurate because we all know that new homeowners many times update the exterior of the homes or even add on so a current photo does no good! If you are unsure of the area of the comps, then drive by without taking photos ( If Fannie ever changes their mind on this) just to get a lay of the land so to speak. But I too have had homeowners try to flag me down asking what the hell I am doing taking photos. It can be dangerous and I think that we have enough tools in our shed so to speak to get an accurate assessment of the comparable sales. Plus we really should not be appraising in areas that we have no clue about, we need to have the requisite experience OR you really do need to drive by the comps. Some lenders go so far as wanting current seasonal photos even if you have one from the Spring and now it is Winter. That is crazy. Thanks for the article.

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  49. This is so true, I actually had a guy pull a gun on me for taking a pic of the house next to him. We really need to do

    something about this sooner better then later. Before one of us gets shoot. I am ready to support this cause just let us know what we need to do.

    As you noted the MLS pics are better any way because they show the home as it was sold.

    Edward Lafuente
    Florida Appraiser

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  50. I could not agree more. I am a 35 year residential appraiser and I have been stopped by angry residents many times even with an “APPRAISER” sign on the side of my car. This needs to be revised in USPAP.

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  51. Here is the issue that most cannot separate. Taking photos and viewing the comps from the street are two different things. I will never advocate for not viewing the comps since this is just one more reason for somebody to replace us since there is no value add over a person at a desk. I have been chased a few times, but consider this a consequence of adding value that I need to put up with – all jobs have perils. I don’t take photos if I feel unsafe and nobody has said a word if I explain this.

    Let’s don’t marginalize our impact more than we have to. There are already enough people who want to cut an appraiser out of the process already. There are unintended consequences to not providing value.

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    • In many cases, it is when driving the comps in person that I get a true sense of property value – sometimes I drive 15 comps which helps me determine value. Along with choosing the comparables, this is a very important part of the job. There are enough appraisers cutting corners already. Not driving comps takes away from our credibility. Google earth, at street level, is not a picture from today, it is sometimes years old.

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    • Thanks Doug, I simply feel more confident driving by, and do this with private appraisals as well where it isn’t in the pre-printed scope of work.

      For the 1004, we certify we have inspected from at least the street, and if we certify it, we need to do it. Take a picture while you are there. If you can’t, because someone is in the yard, or it is unsafe (usually for me because it is a busy road and people drive like they alone use the road).

      Read the certifications, and if they are too onerous (inspecting at least from the street) charge more, or turn it down.

      Just my opinion (this is to the OP, not you Doug).

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      • I have never had FHA nor anybody else complain if I take a photo down the street and state that people were in the yard or a neighbor was peering at me while in front of the home. A honest effort has always been enough. I also have a real camera with a fast lens and I can take photos without stopping and then I can park down the street if I need to look and analyze things out of view. A 16 mm wide lens with f2.8 stop will take photos crystal clear at 55 mph and you can crop them down to size if you take them at 30+ megapixel zoomed all the way out so don’t even have to look and can just shoot from the hip in the general direction. There are real tools for this job – look for fast lenses with Image Stabilization… or both.

        If you do private or wealth management work, they don’t always require that you view the comps at all from the street, but I usually do. On the rare occasion that I do not, then I don’t use the 1004 since the SOW on the form says that I did.

        I do a LOT of high value assignments where there are at least two appraisals. I can tell you unequivocally that they tend to use mine as a baseline if I have original comp photos, even if it took me an extra hour driving on a mountain road to get them, and I have something unique to offer about the subject or comp location. Not long ago, the interior photos showed a beautiful home that the other appraiser adjusted for condition since there was “no other reason” that the sale was so low and I noted that the lower price was because of a 4 mile trek up a “road” that you nearly needed a Alpaca, Sherpa or Mars Rover to get to – real 4wd with 12 inch clearance was nearly a requirement and some homeowners parked at the bottom and used ATV to get up. Got a nice letter from the lender about my analysis and photo of the road and the comp. (BTW – a simple call to the agent confirmed that their feedback about the road was all negative and that is why the home sat so long and sold for less) Another time, there was a creek that would flood a few times a year during heavy snow melt or rain… not in the MLS and unseeable on a satellite – did not seem to affect the value, but helps to build credibility.

        I don’t go down private roads, but I take photos of them.

        I have been trapped in a development by a stock trailer and followed about 8-9 times over the years, so I am not talking from a place where I just have no experience. Call 911 if you feel unsafe – I have seen the Police write tickets to the one doing the following even though I warned the guy that they would do that (and they did).

        I consider just looking online in more of the form-filling realm and viewing the neighborhood and comps in person to true valuation.

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  52. Since it’s obviously a keeping-the-appraiser-honest tactic, a less dangerous alternative would be for the GSE’s to instead simply require a photo of the street sign at the nearest intersection of the comp as well as an MLS photo of the comp. As an appraiser taking comp photos I deal with home owners (ranging from concerned to belligerent) on a regular basis. I even had one call the cops on me last year and tell them I was stealing things off of people’s porches – that was real “fun” to deal with.

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  53. I have said this for years. I personally spoke to the head of FHA Santa Anna about this problem and he understood. But said it was the only way they could make sure appraisers are driving the comps. It is unsafe, a waste of fuel and time. We have so many tools like satellite photos, street scenes etc. In the hills we cant even see the house and with all the armed dope growers shots often ring out. This is a crazy and archaic rule.

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    • Fannie Mae needs to change this requirement and remove it from the pre printed forms; once that is done, the mistrust by lenders that we are driving by the sales will be gone. And more importantly, it will allow our valuable time to be spent researching and analyzing, and driving all over the place.

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  54. And yet somehow, some way, realtors take these photos without being killed.

    Just say “I don’t want to be bothered with driving by sales” and the article can be a lot shorter, freeing up hours of reading appraisers can put toward better and more efficient productivity.

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      Hi Rob; I believe that realtors take photos of their client’s property, not comps. I doubt the client will threaten his agent.

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    • by Doug dougfein@aol.com

      By Doug
      To Rob: Realtors don’t take listing photos, professional photographers do and they are sales listings not a stranger coming to a house to take photos.

      As far as driving around taking comp photos: I am in a resort area and during the summer months houses are occupied and since Covid now these houses are occupied all year. With that said some women was standing on her roof deck that I didn’t notice. When I stopped put my window down stock my hand with camera out the window she started yelling at me. She actually ran down and ran after me yelling and took a photo of my car. About 20-30 minutes later I got a call from the police. It was a polite conversation. He know right away what I was doing and asked the next time stop and explain myself to the homeowner. I did try that once, the person came running out of the house screaming at me and insisted I delete the photo screaming at me, I drove off….. Physically taking comp photos does put the appraiser in danger. I wounder what OCSHA would think about it?

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