What goes into a CMA
A comparative market analysis is how a licensee helps a seller set a price. It looks at three groups, each answering a different question:
- Recently sold properties — what buyers actually paid.
- Currently listed (active) properties — the competition the seller will face.
- Expired listings — prices the market rejected.
Listings indicate the top of value and offers the bottom, so sold properties remain the anchor. What does not belong: tax assessed values, insurance replacement costs, and original purchase prices, which reflect assessment, insurance, and history rather than market behavior; pending foreclosures, rental listings, and builder cost estimates, which mix in other uses and construction cost; and the seller's mortgage balance, desired net, or neighbors' opinions, which have no bearing on market value.
AVMs are not appraisals
The result of an automated valuation model is not an appraisal — by itself or signed by an appraiser. No one inspects the property, so the model cannot address actual physical condition. The trap is believing a certified appraiser's signature converts the output; it does not. Nor do the dollar thresholds: they govern who must appraise, not what counts as an appraisal. An AVM is also not a broker price opinion, because the federal definition of a BPO expressly excludes automated valuation models.
Giving the applicant copies
For credit secured by a first lien on a dwelling, the creditor must give the applicant a copy of each appraisal and other written valuation — and AVM reports and BPOs are written valuations, so all of them go out, not just the appraisal.
The timing: promptly upon completion, or three business days prior to consummation, whichever is earlier. That runs before consummation, not after. Copies are free, although a reasonable appraisal fee may be charged.
Delivery is automatic, not request-driven; the applicant need not ask in writing at closing. A separate notice of the right to a copy is due within three business days after application, and confusing that notice deadline with the delivery deadline is the trap.