While appraisal business is slow, I'm sure that you have had an opportunity to provide an anxious underwriter additional market information and comparable sales data, much of which will be required for inclusion on the new FNMA Market Conditions form, set for an April 2009 debut. While much of this newly required information is due to current market conditions (thus, the name), much of this data is useful and should have been incorporated into the FNMA 1004 updated in March 2005. I am not sure why FNMA dictates what should be included in this form. The current URAR asks on the top of page 2 for the number of properties currently listed and for the number of closed sales within the past 12 months. Why did they choose not to include the simple computation of an absorption rate, and a request for an analysis of this data?
I believe, as appraisers, with a thorough knowledge of valuation, that WE should design a form that best implements USPAP requirements. I think we have earned the right to self-regulate and FNMA has blown theirs!
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