So why not sign it? Its an appraisal and must have a signed certification. Nothing wrong with a staged assignment, but nothing in USPAP that allows conveying an opinion of value, indication in direction of value from a benchmark, or range of values etc without a signature. So, you may think its way beyond the scheme of comp checks, but its the same thing, maybe just more professionally prepared. Toe mat o. Toe mah toe.
Frome the horses mouth ...
"FREQUENTLY ASKED QUESTIONS
196. Providing a draft of a report
Question:
My client has asked that I provide a draft of my appraisal report prior to issuing the report in final form. Is this permitted under USPAP?
Response:
USPAP does not explicitly define or address drafts of reports. When clients, other intended users, and appraisers use the term “draft,” they may mean many different things, from preliminary spreadsheets to a written document that contains all that will be in the “final” report except it is labeled as “draft” and does not contain signatures.
Report drafts have traditionally been part of certain types of appraisal practice but have never been considered acceptable in other types of appraisal practice. (My emphasis added)
State-regulated appraisers should be aware of applicable state laws and regulations. Many laws define a “report” as any communication, written or oral, of an appraisal.
Whatever a “draft” may be in a particular context, it would always be part of “appraisal practice,” because it is a valuation service provided by an appraiser. When performing a service that is considered appraisal practice, but for which there are no applicable Standards Rules, an appraiser must still comply with the portions of USPAP that apply generally to appraisal practice. These include the DEFINITIONS, PREAMBLE, ETHICS RULE except for the Record Keeping section, COMPETENCY RULE, and JURISDICTIONAL EXCEPTION RULE.
The second sentence of the PREAMBLE states: It is essential that appraisers develop and communicate their analyses, opinions, and conclusions to intended users of their services in a manner that is meaningful and not misleading. Additionally, the ETHICS RULE states: An appraiser must not communicate assignment results in a misleading or fraudulent manner. Therefore, if an appraiser communicates with intended users prior to completion of an assignment, the communication must not be misleading.
The purpose of issuing a “draft” cannot be to allow the client to improperly influence the appraiser.
See Advisory Opinion 21, USPAP Compliance for further guidance."
If you don't want to provide "drafts", then don't. Just don't tell me I'm in violation of USPAP if I do.