If the tax value supported the loan amount, we would just use the tax value. In most cases, we are referring to an old appraisal that we have in file. We only use them when the equity is obvious. We have added verbiage to include current and projected use of the property & zoning designation. We have added narrative to describe the method used to confirm the physical condition, narrative to describe the analysis that was performed and the supporting information that was used in valuation, narrative to describe market conditions and if using an existing Appraisal, verifying the original market value has not changed due to various conditions. Not sure if this will pass the test or not. Was hoping someone had a sample that have pleased the Examiner's.
What is your narrative though? Just boiler plate you are adding to each eval? Is someone actually going out to look at the property and take a picture in its current state? Do your communities reassess annually, or are you using tax values based on a 5-6 year old community assessment? How are you verifying current market conditions... are you obtaining and reviewing comps to prove your point?
Regardless of how obvious the equity position is, it is 2015 now... if you are not taking the guidance reissued in December of 2010 seriously, you can expect to be criticized as you are. Those guidelines, detailed in the link Joker provided, clearly state that using the straight up tax value without showing your methodology to back into it, is not acceptable.
In our shop and in operating in a dense multi-community metro area, we just get an appraisal for nearly every deal now. Generally the only exception we make is if the appraisal on file is less than a year old, and then we do a full investigation and write up detailing why the appraisal is still a good reasonable value.