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The workfile must include:
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..... and all other data, information, and documentation necessary to support the appraiser’s opinions and conclusions......
Seems to me, that would have to be the basis they're using to say the comps considered but not used are required. Personally, I'd think that the comps that you didn't use only tell you what the subject's value isn't, and not what it is, but then, really, that is part of the process. So I think it could be argued either way. I guess what they are looking for is did you use sound reasoning in your selection of comparables. I think the downside to having only the comps you used in the file is it leaves you open for an accusation that you pre-selected your comps. And that leaves you open to an accusation that you were working towards a target.
I once had a seller file a complaint against me because I didn't "make value". When I received the nastygram from the state asking for my rebuttal, among other things, they required that I submit MLS printouts for the comparables that I used and MLS printouts for the comparables that I considered but didn't use, along with a brief explanation for each as to why I didn't use them. So I would say the request from your state is not unusual, even if it is a liberal interpretation of USPAP. In my case, the file was closed with no action taken, but not before they ran me through the wringer and tried to make me sweat. At the time I swore the accusatory tone and 'guilty until proven innocent' approach was just their attempt to put the "fear of God" into me.
My guess as to why they want the search criteria is that they are looking for some kind of proof that part of your search criteria wasn't something like: $220,000 to $240,000. By keeping a variety of comparables that you didn't use in the file, I would think it would help make the case that you didn't search by price range, even if you didn't keep a printout of the criteria used. And maybe that's the point in asking for the comps you didn't use, as in, looking to determine if you were willing to consider that the subject's value might be something other than what you ended up with by having a variety of prices in your potential comps.