I'm not disputing that the value on this property was 95,000 back in october. But now 120 days later it is more around 70,000. In order to get a new appraisal the negotiator needs comps that fit these guidelines:
All comps have to be sold before our appraisal was completed on , not already used in the
appraisal and not more than 6(six) months old at the time of appraisal to be considered
valid.
This infuriates me! How can the fair market value be derived from sold comps almost a year ago! If anyone has gotten around this "rule" it will be appreciated!
Amanda
Tags:
Their guidelines on this absolutely do not make any sense in a declining market. We are disputting that it was not accurate" then" and getting an value from "then" and trying to sell it now. We also have a market that is competing with other Short Sales and REO property- why can they not be used? After all this is a Short Sale, not a traditional sale.
Anyone disputed this FHA-HUD rule successfully?
Yes, Kathleen, I have tried to dispute this with the FHA., at senior levels. I've posted on this one.
This is a flaw in the FHA/PFS program, and FHA wants to believe the problem doesn't exist.
I wrote a careful memo to the FHA, which they just ignored, because they don't think there is a problem with their appraisal process!
I talked to the Director of Asset Management for Single Family Houseing, who returned a call, and she told me that she had never heard of this problem. That no Servicer has every brought this to her attention. So, this must be just me, just an isolated case.
On a practical level, you have I think two strategies for dealing with FHA/PFS appraisals.
1. Wait until you have an offer that you believe is FMV before applying to PFS, then you can try to manage the appraisal to the offer.
2. Apply to PFS before the offer, make sure the listing price is FMV. Then, try to manage the appraisal to the list price. If you get a reasonable appraisal, you may be okay. If not, wait until the ATP period has expired, then try to sell before DIL, with a new appraisal.
Disputing the appraisal is a waste of time in my experience, because you are talking to a brick wall. For the reason Amanda is stating--the comps are wrong, and the FHA will not look beyond comps.
Keep screaming at the FHA, eventually someone there may wake up from their13th floor hideaway and actually try to understanding what is happening down on the surface of planet Earth.
Here are the address to write to at the FHA:
Himes, Ivery W [[email protected]]
(Addresses and phone numbers, including these, are publically available on the HUD website.)
Yes, Amanda, agreed totally. I also find that Wells is the most difficult of the major servicers, as far as handling short sales where the appraised value is above fair market value.
Overall, I like PFS, except for this rather large flaw.
I assume you have the FHA appraisal dispute "rules"? They are posted someone on this site. I have them, somewhere. If you don't, shoot me an email [email protected], and I'll try to find them.
Unfortunately, Wells is following the rules, but the rules make no sense in this market. Wells just "follows the FHA rules"
Cheryl has great advice here!
Wow a 27% drop since October, ouch!
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