Comment: Real property appraisal consulting assignments encompass a wide variety of problems to be solved. However, the purpose of an assignment under this STANDARD is always to develop, without advocacy, an analysis, recommendation, or opinion where at least one opinion of value is a component of the analysis leading to the assignment results.
I don't see that in this case.
Standards Rule 5-2
The content of each written real property appraisal consulting report must be consistent with the intended use of the appraisal consulting assignment results and, at a minimum:
state the identity of the client and any intended users, by name or type;(note54)
Comment: An appraiser must use care when identifying the client to ensure a clear understanding and to avoid violations of the Confidentiality section of the ETHICS RULE. In those rare instances where the client wishes to remain anonymous, an appraiser must still document the identity of the client in the workfile, but may omit the client’s identity in the report.
Intended users of the report might include parties such as lenders, employees of government agencies, partners of a client, and a client’s attorney and accountant.
state the analysis, recommendation or opinion developed;
state the intended use of the appraisal consulting assignment;(note55)
state information sufficient to identify the real property pertinent to the appraisal consulting assignment, and state the physical, legal, and economic characteristics of the property, properties, property types, or market area pertinent to the assignment;(note56)
state the effective date of the appraisal consulting assignment results, the date of appraisal pertinent to each opinion of value used in an analysis in support of the appraisal consulting results, and the date of the appraisal consulting report;(note57)
state the scope of work used to develop the assignment results;(note58)
Comment: Because intended users’ reliance on assignment results may be affected by the scope of work, the report must enable them to be properly informed and not misled. Sufficient information includes disclosure of research and analyses performed and might also include disclosure of research and analyses not performed.
When any portion of the work involves significant real property appraisal or appraisal consulting assistance, the appraisal consultant must describe the extent of that assistance. The signing consulting appraiser must also state the name(s) of those providing significant real property appraisal or appraisal consulting assistance in the certification, in accordance with Standards Rule 5-3.(note59)
summarize the information used in the appraisal consulting analyses, the appraisal consulting methods and techniques employed, and the reasoning that supports the analyses, opinions, and conclusions;
Comment: If the value opinion used in the appraisal consulting assignment was not performed by the consulting appraiser, the appraisal consulting report must include:
the information required in Standards Rule 3-2, or
a statement of the appraisal review results, and a reference to the appraisal review documentation retained in the appraisal consultant’s appraisal consulting assignment workfile, or
a statement supporting the use of that appraisal as an extraordinary assumption in the appraisal consulting assignment.
If an opinion of value was developed by the consulting appraiser, the appraisal consulting report must include the information required to comply with Standards Rule 2-2(a) or (b)(ii) through (x). Standards Rule 2-2(c)(ii) through (x) is also permitted if the client is the only intended user of the assignment results.
state the appraiser’s appraisal consulting recommendations (if any), and conclusions or opinions;
clearly and conspicuously:
state all extraordinary assumptions and hypothetical conditions; and
state that their use might have affected the assignment results; and
include a signed certification in accordance with Standards Rule 5-3.