So then, if we're doing a GSE-related appraisal, if we don't have enough comparable properties in the neighborhood to develop meaningful trends on the MC addendum, we shift to competing properties in the market segment to complete the one unit housing trends of the neighborhood analysis portion of the 1004. That is somewhat less than straightforward, and, in my opinion, misleading on the face of it (the "face" being the forms themselves) - but that's alright because somewhere in the report we've explained all this and explained the information the trends reflect.
If we're doing an FHA, we report trends of all one unit housing regardless of comparability to or competitiveness with the victim property.
So, we have two "correct" ways to complete the appraisal, and they are not the same, and in some market areas are absolutely contradictory. The GSEs have been given their out by the interpretation that USPAP's requirement not to mislead is couched it terms of the intended users of the appraisal. But, in doing so, it seems to me that they completely disregard the prospective borrower as an intended user of the appraisal. I don't look forward to the conversation with a borrower who raises questions about the information in the 1004 prepared for a GSE lender.