3.6. Review Appraiser’s Use of Information Not Available to Appraiser.The scope of work for an appraisal review assignment involving a federal acquisition typically exceeds that of the usual appraisal review because Uniform Act regulations require the reviewer to determine whether the appraisal report under review can be the basis for the establishment of an offer of just compensation.161 In making that determination, the review appraiser may need to consider information that was not available to the appraiser who prepared the appraisal report under review.162 In light of the intended use (i.e., establishing a basis for offer of just compensation) and intended user (i.e., agency management), the reviewer is required to consider all available information in making a recommendation. A recommendation based on outdated or incomplete information would fail to meet the agency’s obligation to determine a current offer of just compensation, and would not conform to the intent of the Uniform Act and its implementing regulations. 

Consideration of information not available to the original appraiser is also consistent with USPAP requirements.163 The current USPAP document expressly contemplates that review appraisers may need to consider such information to produce credible assignment results: 

Information that should have been considered by the original appraiser can be used by the reviewer in developing an opinion as to the quality of the work under review. 

Information that was not available to the original appraiser in the normal course of business may also be used by the reviewer; however, the reviewer must not use such information in the reviewer’s development of an opinion as to the quality of the work under review.164 

Accordingly, a review appraiser’s use of subsequent information necessary to produce credible assignment results for the scope of work does not require a jurisdictional exception to USPAP. Of course, an appraisal reviewer may find that an appraisal report under review was prepared in accordance with these Standards and that the opinion of value reported was reasonable and reliable as of the effective date of the appraisal, and yet still find that the opinion of value is unreliable as the basis for an offer to purchase by the government because of changed circumstances or new information that has become available. In such an instance, the review appraiser must clearly explain all pertinent findings in the review report to avoid any impression that the appraisal report under review was not accepted because of its quality or the reasonableness of the opinion of value as of the effective date of the appraisal. In these circumstances, some agency reviewers accept but do not approve the appraisal report. 87