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I do believe the inclusion of the comment regarding the local MLS is the problem. NO, the house was not offered for sale in the "usual manner". It was not even a "typical" FSBO. However, there is an OFFER to buy and that offer has been accepted hence the purchase agreement, the mortgage application and the resulting appraisal assignment. So, YES, the subject is currently being offered for sale, by the owner of public record and is encumbered by an executed purchase agreement.
By logic of the quoted statement, properties offered by a builder in a new subdivision, not listed in MLS, would also not be considered as OFFERS to sell. Ahhhhh....I don't think so.
The builder is trying to sell those properties even if one specific property is not listed on the MLS. He is clearly offering them for sale. Not a good analogy.