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Staying Within the Lines: CMA and BPO Requirements

June 2026

Competitive market analyses (also known as comparative market analyses, or CMAs), broker price opinions (BPOs), and letter opinions are common tools to help customers or clients understand property value. These tools, however, must be used within the limits set by Oregon law and administrative rules. The following summarizes what Oregon law and administrative rules require.

Understanding the Terms

A CMA is a pricing analysis a broker or principal broker provides when pursuing a listing, helping a seller set a price, or helping a buyer determine an offer price.

A BPO is a pricing analysis provided by a broker or principal broker outside of a listing or buyer representation agreement.

A letter opinion is a written document expressing the licensee's conclusion about a recommended listing, selling, or purchase price, or a rental/lease consideration, resulting from a CMA or BPO.

Required Elements for Letter Opinions

Oregon administrative rule requires that letter opinions for both CMAs and BPOs be in writing and include:

  1. Purpose and intent of the analysis
  2. Brief property description
  3. Basis for the value, including market data or capitalization computation (income capitalization)
  4. Any limiting conditions
  5. Disclosure of any existing or contemplated interest the licensee has in the property
  6. Licensee’s signature and date
  7. Unless the licensee is also licensed by the Appraiser Certification and Licensure Board, a statement that the analysis does not meet Uniform Standards of Professional Appraisal Practice (USPAP) requirements
  8. A disclaimer that the analysis is not an appraisal and that an appraiser should be hired if an appraisal is needed

These requirements must be met for every letter opinion issued.

Collateral Analyses

Oregon allows two special types of analyses for financial institutions:

  • A Lending Collateral Analysis is provided for a lender’s internal use connected to a loan under $250,000.
  • A Default Collateral Analysis is provided for a lender’s internal use when evaluating what to do with a defaulted loan.

These are permitted only when:

  • The analysis is for the lender’s internal use only.
  • The requirements for letter opinions are followed.
  • The licensee discloses their relationship with the lending institution to the buyer and seller if:
    • The licensee has a current, active listing agreement on the property; or
    • The licensee represents the seller in a pending transaction on the property.

Keep in mind that these analyses are for a lender's internal use and are not a substitute for an appraisal.

When Price Opinions Become Appraisal Activity

A licensee risks unlicensed appraisal activity when they:

  • Provide a valuation not tied to a transaction.
  • Provide a historical or retrospective value (value as of a date) rather than a current price recommendation tied to a transaction.
  • Prepare analyses that are not for a permitted collateral purpose.

If you have further questions about unlicensed appraisal activity, please contact the Appraiser Certification and Licensure Board.

Best Practices for Licensees

Here are practices to help make sure your work meets the requirements:

  • Confirm the analysis is tied to a transaction, or that it qualifies as a lending or default collateral analysis for a lender's internal use.
  • When approached by lenders or other third parties, confirm the purpose of the analysis and whether the lender's internal-use requirement applies.
  • For questions about a specific situation, contact your managing principal broker or private legal counsel.

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