I would wager dollars to donuts that is a lender requirement, not an AMC requirement.
As to the OP, my response would have been, "see commentary on page X," because commenting on variances from predominant value has been a "thing" for at least 20 years. So, I always addressed it on the front end.
You'r correct and I agree with you completely. It is Not just because its yours/my opinion, its just plain fact. I dare say that many CR have only done a cursory reading of that document. I myself have never read the selling guide completely. Its a difficult read and much of what we appraisers need to know is scattered all through that Guide.
It is Standard Practice because of an expectation of Lenders,
driven in part by the FNMA Selling Guide. Here is what happens. Many Lenders/AMC's pick and choose what items they deem important. I guess that's their prerogative. I don't agree with that at all, but I understand time is money and its their perspective of what is and isn't important. I just know it is what it is and live with it. Often I comment on something because of the Selling guide that the AMC never ask for or was not aware of or they for some reason don't think it's important. Truth is frankly I don't care what they think. I am the appraiser not them.
Bear with me this will be long. The assignment below is literally a Cookie Cutter. Mt Bragadocious turned it down and I think I know why, Simply He don't want to do any 'Splanin' because volume is his game. Fast N Cheap and AMC Phone Monkey Dot Com Loves this Dude!
The attached Pix is where my current subject(purchase money) is located. Someone reading the report would think "oh very conforming and uniform!" Slam Bam Thank You Ma'm Report.
Nope! My subject 2br attached SFR(not a condo)- has the lowest GLA in the complex(as far as i can tell). It is apprx 100-110 sft smaller than all the other sale in the prior year. All of the other 2br Sale are within 25sf of each other.
So I have to explain SF bracketing. That's not going to be hard because the Developer had to adjust original planned foot prints to comply with set backs(terrain rolls a little bit). Fortunately three comparable sale were within the last 6 months, so I don't have to explain that, There were some other sale older in date, but they would not help in the GLA Bracketing. This gets worse. The subject had another accepted offer prior to this one. It fell apart because buyer got cold feet. Agent put back on market...two days later Pending again. This development is strong(ave DOM 5 days or less) and in high demand. Whats the Problem? Well both offers were close to but less than Listing Price. OK Cool. Problem is
both offers are above the the three
most recent comparable sale! So the offers are not Bracketed by the most recent 3 sale. You know i will have to explain that assuming the Opined MV is above them. It will be above them(not a lot) because I have
SOLID market Appreciation Time Adjustment data. I also have the contract to purchase. The Buyer even though they are getting a loan has not made this subject to that loan, Essentially a Cash Offer. Thats pretty strong.
Whats my major Point. Simple, we as appraisers must do better. We are killing our profession report by report. Fast N Cheap Model is not helping any of this at all.
I can only do what I can do....I am but one island in a Universe of many islands and its hard to compete with all them islands.
Hope all that makes sense to somebody. Maybe I just have it all wrong. Color me a Fool then! Peace