One of our members identified a potential issue regarding the contract required to conduct as auction.  For your consideration and review the comment follows below:

After a review of the propsed reguations, we believe that there is a conflict in the Proposed 18VAC25-21-10.
Page 4, 18VAC25-21-110 Contracts; Paragraph 1.a. regarding providing an adequate description of the property.  1.a. says that if the description list cannot be given at the time of the contract, then it must be delivered before the sale and attached to the contract before the sale.
 
In paragraph 8 below, it is stated that in 8.b. (top of page 5) .... "A legible executed copy of the contract and any addendums shall be given to the owner at the time of execution."
 
The 1.a. implies that you can commit the seller to a contract, but you do not have to deliver a description of items for sale until a later date, but before the sale.  In 8.b. you must provide a description at the time the contract is executed.  This is difficult where many items are to be sold and an inventory might take a week to produce. 
 
Also, 8.b. needs to have inserted. "of the contract" at the very end of the sentence or else it becomes  humorous implying that the owner of the goods will be executed.  8.b. probably should be removed and allow 1.a. to remain.