An Evaluation is a short format valuation report that federal regulators have
allowed lenders to order in lending situations where the loan amount is below a
threshold - for commercial properties, initially $250,000 and at present
$500,000 - since 2010. An Evaluation may be prepared by a party without an
appraisal license. Standard appraisal requirements for the valuation methods
applied and the completeness of research do not apply. An Evaluation is
allowed only in lending situations and not in others, such as valuations for
estates, government agencies, or private parties.
Evaluations are a radical departure from the heavily regulated methods of analysis that are required under FIRREA and USPAP. With Evaluations, lenders run the risk that low-quality, unreliable valuations will provide weak support for loans. On the other hand, they open the door to analyses that "cut to the chase" and forego unnecessary analyses and boilerplate, allowing quick, low cost, and fairly reliable valuations that benefit the loan production process. Lenders, recognizing the risks, have not fully signed on to the use of Evaluations as substitutes for appraisals. If the lending process is to become more streamlined, it will be necessary for appraisers to demonstrate that we are able to provide Evaluations that are reasonably reliable.
From the point of view of appraisers, one of appraisal's main features is that it allows us to make a living. For us, the stronger the requirements for comprehensive and lengthy reports, the better. From the point of view of our customers, appraisal exists to provide good valuation advice at a cost that is proportionate to the amount of money involved in a financial decision. A level of tension exists between these interests.
Take the case of the borrower who wants a loan of $300,000 against an office or industrial building that is clearly worth $1,000,000 or more. The tax assessment is $600,000, and assessments are notoriously below-value in this community. All the comparable sales are above $100 per square foot of building, and the building contains 10,000 square feet. The bank engages a standard appraisal, at a cost of $2,400, with a turnaround time of three weeks. An Evaluation, on the other hand, might cost $1,000 and take a week. The appraiser arrives at the property only to hear the borrower's complaint that it should not cost $2,400 to borrow $300,000 when the property's value is obviously so much more than the loan amount. Every commercial appraiser has heard this complaint. The appraiser's standard answer is that the appraiser is not informed as to the amount of the loan and has only been sent to make the appraisal that was requested. The appraiser completes the appraisal, delivering a value estimate that substantially exceeds the $300,000 loan amount. And the appraiser is left with a nagging feeling that the borrower has a point.
The key to a good Evaluation that would shorten the process and still deliver a reliable value is the use of a high-quality AVM. At this office, we use Zaxia.us as our preferred AVM. The appraiser inspects the property; gathers factual information; inputs the information to Zaxia in a five-minute survey; obtains an automated Zaxia Report, which includes three comparable sales and a standard analysis through the Income Approach; and completes a Restricted Report of an Evaluation for the lender, incorporating the Zaxia Report as part of the larger report.
Some are of the opinion that the AVM output itself, the Zaxia Report, qualifies as an Evaluation. Our view is that an appraiser's attention from input to review is necessary for reliability. For a lender, the benefits are compelling: turnaround time and cost are both shortened by more than half.
The Restricted Report format is appropriate: the use of the report is restricted to the lender, who has a better understanding of the process than do others.
So long as a high level of quality is maintained, the use of Evaluations opens the door to more efficient methods of valuation.
24 Thorndike Street
Cambridge, MA 02141
Eric Reenstierna Associates LLC is a real estate appraisal firm taking on valuation and consultation assignments in Greater Boston, Massachusetts and New England. Eric Reenstierna, MAI, is the office's principal and is a commercial real estate appraiser.
24 Thorndike Street
Cambridge, Massachusetts 02141