Quick Answer: No. Asking an appraiser for a comp check, a pre-appraisal value estimate, or a "ballpark" number is treated as an attempt to influence the appraisal and is prohibited under the Appraiser Independence Requirements and the Dodd-Frank appraisal independence rules. Loan production staff can share factual property information and can request a reconsideration of value after the report is delivered, but they cannot ask for a value before the appraiser completes the work. R3 AMC, an appraiser-owned appraisal management company founded in Henderson, Nevada in 2015, handles appraiser communication for lenders so that production staff never have to. Call (702) 658-1191 to learn how.
The comp check used to be a routine phone call. A loan officer would ring a familiar appraiser, describe the property, and ask what it was likely to appraise for before anyone paid for a report. That practice ended for mortgage lending with the Home Valuation Code of Conduct in 2009 and the Appraiser Independence Requirements and Dodd-Frank rules that replaced it. Many loan officers still ask the question in softer forms, and many do not realize it is a problem. This article explains why a comp check is prohibited, what the rules actually say, what a loan officer is allowed to communicate, and how an appraisal management company gives lenders a compliant way to get comparable sales in front of the appraiser.
What Is a Comp Check?
A comp check is a request for an appraiser to analyze comparable sales and communicate a likely property value before a completed appraisal assignment. It can be phrased as “can you pull some comps,” “what do you think this will come in at,” or “will this support $450,000.” A quick verbal value opinion is still appraisal work; calling it informal does not remove the applicable independence and professional obligations.
The problem is not the comparables themselves. Comparable sales are public data and anyone can pull them. The problem is asking the appraiser for a number, because that number then becomes a target. If the appraiser later accepts the assignment, both the lender and the appraiser have a hard time proving the final value was reached independently.
Why Is a Comp Check an Appraiser Independence Violation?
The Appraiser Independence Requirements (AIR) that Fannie Mae and Freddie Mac apply to the loans they purchase prohibit anyone involved in loan production from attempting to influence the development, reporting, result, or review of an appraisal. The requirements list specific prohibited behaviors, and among them is requesting that an appraiser provide an estimated, predetermined, or desired value before completing the appraisal. A comp check is exactly that request.
The Truth in Lending Act, as amended by the Dodd-Frank Act, contains a parallel federal rule. It makes it unlawful for a lender or its agents to coerce, induce, or encourage an appraiser to reach a particular value. Regulators and investors read a pre-appraisal value request as encouragement toward a number, even when the loan officer intends nothing of the sort. For a fuller explanation of the framework, see our guide to appraiser independence requirements for lenders.
The practical consequences are serious. An appraisal tainted by an independence violation can be rejected by the investor, can trigger a repurchase demand after closing, and can expose the appraiser to state board discipline. The appraiser has every incentive to refuse the request, which is why experienced appraisers simply decline comp checks on mortgage work.
Does It Matter If the Loan Officer Does Not Mention a Number?
Yes, it still matters. The rules are about influence, not about whether a specific figure is spoken aloud. "Does this look like it will work?" communicates a target just as clearly as "we need $450,000," because the appraiser knows the contract price or the loan amount the lender needs. Any pre-appraisal value conversation between production staff and the appraiser is a risk.
The same logic applies to indirect routes. Asking a real estate agent, a processor, or a friend at another company to call the appraiser for an opinion does not solve the problem. The requirement follows the intent and the relationship, not the person dialing the phone.
What Can a Loan Officer Legitimately Communicate to an Appraiser?
Loan production staff may provide appropriate factual property information and ask for corrections or further explanation through the lender’s independent appraisal channel. Under AIR, comparable sales must not be requested from or supplied to the appraiser before the appraiser is engaged. After engagement, additional appropriate comparables may be submitted as information without requesting a target value. A completed report can also be challenged through a documented reconsideration of value process.
- Provide additional appropriate property information, including comparable sales after the appraiser has been engaged, without seeking a target value.
- Ask the appraiser to correct factual errors in a delivered report.
- Ask the appraiser to provide further detail, substantiation, or explanation for a value conclusion already reached.
- Request a reconsideration of value after delivery, supported by specific data, through the AMC's established process.
What production staff cannot do is pick the appraiser, contact the appraiser directly about value, withhold payment or future work based on a value, or request a value before the appraisal is complete. The line is clear: facts before, data-supported questions after, no number in between.
How Does an AMC Keep Comp Sharing Compliant?
An appraisal management company places a documented, independent layer between loan production and the appraiser. At R3 AMC, orders are assigned automatically from a panel of more than 500 active appraisers, drawn from a database of more than 20,000, so no loan officer selects or contacts the appraiser. Every report is reviewed against USPAP and agency guidelines before delivery, and the review does not direct the value conclusion.
R3 AMC also built two programs that address the real need behind most comp check requests without crossing the line. Listing Agent Engage is a Dodd-Frank compliant automated comp-sharing system that shares comparable sales data with the listing agent, so relevant sales reach the appraiser through a documented, compliant channel rather than a phone call from production. The Heads-Up program gives the lender early notice when an appraisal is likely to come in below the contract price, so the loan officer learns about a potential gap before the report is final and can plan accordingly. Neither program asks the appraiser for a value, and both leave a record.
What Should a Loan Officer Do If the Value Comes In Low?
If a completed appraisal comes in below the contract price or the expected value, the compliant path is a reconsideration of value. The loan officer gathers specific, verifiable information such as comparable sales that closed before the effective date and were not used, or factual errors in the report, and submits it through the AMC. The appraiser reviews the information and either revises the report or explains why the original conclusion stands. We walk through that process step by step in how to dispute a low appraisal through the reconsideration of value process.
R3 AMC supports reconsiderations while maintaining appraisal independence, and uses ValueTest.ai research reports to support quality control and reconsiderations of value. The reconsideration request is routed through R3 AMC, not from the loan officer to the appraiser, which keeps the independence record intact.
How Should Lenders Train Production Staff on This?
Most comp check requests come from habit, not bad intent, so training works. Lenders should make three points clear to every loan officer and processor. First, all appraiser contact about value goes through the AMC or the lender's appraisal desk. Second, comparable sales can be shared as information but never attached to a value request. Third, the reconsideration of value process is the only route for disagreeing with a delivered value, and it has to be supported by data.
Written policies help, and so does the AMC relationship itself. When loan officers know the appraiser was assigned automatically and that the AMC will handle every question, there is simply no one to call for a comp check. The Fannie Mae Appraiser Independence Requirements are a useful reference for the policy language, and R3 AMC provides training support to lender clients on compliant appraisal communication.
Frequently Asked Questions
Is a comp check illegal?
For mortgage work covered by AIR, a loan officer must not seek an anticipated or desired value or request comparable sales from an appraiser before engagement. A preliminary value opinion is appraisal work subject to professional standards; it is not a compliance shortcut. The precise legal requirements depend on the transaction and applicable rules, but using an informal value request to influence a mortgage appraisal is prohibited.
Can a real estate agent ask the appraiser for a comp check instead?
Not on a mortgage transaction. The independence rules cover anyone acting on behalf of the lender or with an interest in the transaction, and an agent asking for a value on the loan officer's behalf creates the same influence problem. Agents can share comparable sales as information, which is what Listing Agent Engage does through a documented, compliant channel.
Can a loan officer send comparable sales to the appraiser?
Yes, after the appraiser has been engaged, appropriate comparable sales may be supplied as information without a value target. AIR prohibits requesting or providing comparable sales before engagement. Submit the information through the lender’s independent appraisal process so the communication is documented.
What happens if a comp check is discovered after closing?
The investor can treat the appraisal as non-compliant and demand repurchase of the loan, and the lender may have to document corrective action with regulators. The appraiser may be referred to the state appraisal board. The cost of a single repurchase typically far exceeds the value of the information a comp check would have provided.
Does R3 AMC allow lenders to talk to appraisers at all?
R3 AMC handles communication with the appraiser on the lender's behalf. Lenders can submit property information, request corrections, ask for clarification, and file reconsiderations of value, all through R3 AMC. Production staff do not select or contact appraisers about value, which protects the lender's independence record on every file.
Need help now? Call R3 AMC at (702) 658-1191, email orders@r3amc.com, or send an inquiry through the R3 AMC contact page.
Key Takeaways
- A comp check is a request for a value before the appraisal is complete, and it is prohibited under AIR and the Dodd-Frank appraisal independence rules.
- The rules target influence, so a vague question about whether the deal "will work" is just as much of a problem as naming a number.
- Loan officers can share factual property information and comparable sales as information, request corrections, and ask for a reconsideration of value after delivery.
- An AMC with automated assignment and a documented communication channel removes the opportunity for a comp check altogether.
- R3 AMC's Listing Agent Engage and Heads-Up programs address the real need behind comp checks without touching appraiser independence.
- Train production staff on three rules: all value communication goes through the AMC, comps are information only, and disagreements go through the reconsideration process.
