You should consider yourself lucky that this is your first REO sale. In my market, 75% of the contract sales (appraisals) I do are REO sales as many of our sub-markets, the REO sale is the market! With a market drop in some areas of up to 55% since market highs in Dec, 2005, I will have minimum of 2/3 of the comps as REO and the 3rd as a "short sale". My 4th "sale" as a pending and my 5th as an active are also REO.
In your sales history, where you are reporting the 3 yr sales history of the subject, typically there are 2 unqualified sales where the bank has had the property deeded in their name and then deeded to another bank/ REO seller and then on the comps it likewise are numerous unqualified sales. I always make comments in this area of the report as to type of transaction, i.e. REO/ bank owned prop. sale.
I completed a ERC assignment last month in an area that the REO market was the market as over 75% of the relevant comparable sales were either REO or "short sales" . I went into great detail in my narrative on the foreclosure rate and the trend of the monthly increases and the declining market rate. I received an email from the ERC consultant requesting that I exam 4 of the comparables that the other appraiser used. Subject was a non-pool home and other appraiser used the highest of 9 non-pool sales as one of the comps. It was a normal arms-length transaction. The other 3 comps were pool homes and of the 20 "relavant comparables" (pool homes) sales, the comps represented the 16th, the 19th, and the 20th highest pool sales. Again, all were sales from Mr. & Mrs. Smith to Mr. & Mrs. Jones, all qualified sales. According to the ERC consultant, the spread of 34% between my appraisal and the other was the highest she had ever seen as a 3rd appraisal was ordered. My reply was that since the REO sale has become the market and that there are not two different markets, the REO sale was weighted heavier since all the closed sales in the report and the three actives that were pending were all REO that the REO was the market based on the trend and the 120 day forecasting. I have not performed a follow up on the 3rd appraisal or if the subject has been listed yet.