Here is the appraiser's response:
"First, borrower suggested that two sales could have been used as comparable sales. These sales closed in September, 2013 and June, 2012 respectively, which makes them 15 and 30 months old. Borrower states that the 12 month window for comparable sales is arbitrary. However, the date of sale is an important factor in the selection of comparable sales. In fact, most lenders prefer to have comparable sales that have closed within the last six months, and twelve months is the maximum limit. This is due to the fact that market conditions do change and market conditions are an important factor in property valuation. Lenders demand that estimated market values are supported by current sale data. For these reasons, sales that are over 12 months old have not and cannot be included in the analysis for this property. Again, this is a lender mandated rule and not an appraiser decision.
Second, the borrower states that no adjustment has been made to the comps for new windows, updated kitchens, or wood flooring. However, all of these factors are taken into account when determine the quality and condition ratings. We do not break out and make adjustments for individual items. All items are taken into consideration and an overall quality and an overall condition rating are established. For example, the subject has updated kitchen, new flooring, new windows, one renovated bathroom, and roof is 7 years old. It is given a C3 condition rating. This is considered a rating of "good" or "updated." The MLS listing for indicates that the interior this home is basically 2 years old and includes new flooring, new appliances, new carpet, new furnace, new roof, new cabinets, new hardware, new ceiling fans, new base molding, new paint, new concrete drive, etc. This home does not have exactly the same updates or same materials as the subject, but is rated as equivalent to
the subject in overall quality and condition. The MLS listing for states that this home has an updated kitchen with granite countertops, new laminate flooring, new carpeting, new roof, new windows, new furnace, new central air, etc. This sale was also given an equivalent condition rating. In summary, we do not make adjustments based on specific features, but rather on the entire package.
Third, borrower states that no adjustments have been made for site size. The subject property backs up to a ravine and while the overall size is bigger, it does not have more usable land. The ravine does create a nice view, but is not a larger usable yard. Therefore, it is not considered value superior to some of the smaller sites. No site adjustments were deemed necessary and none have been made."
Summary: "We consider 2 year old carpet and hardwood floors throughout the house to be equivalent in value."