3.1.1. Government Review Appraisers.Government review appraisers are often assigned administrative duties in addition to the technical review of individual appraisal reports. Those administrative duties vary from agency to agency and may range from contract administration or counseling management for general valuation issues to assisting the agency to meet both its non-appraisal and appraisal obligations under the Uniform Act. Some of these duties may fall outside the scope of valuation services as defined in USPAP.145 These administrative duties are also considered to fall outside the scope of these Standards and are therefore not covered in the following discussion. 

The review of appraisal reports by a qualified reviewing appraiser is required. The federal regulations implementing the Uniform Act require agencies to have an appraisal review process that at a minimum requires the following: 

(a) A qualified review appraiser shall examine the presentation and analysis of market information in all appraisals to ensure that they meet all applicable appraisal requirements and support the appraiser’s opinion of value. The level of review analysis depends on the complexity of the appraisal problem. As needed, the review appraiser shall, prior to acceptance, seek necessary corrections or revisions. 

The review appraiser shall identify each appraisal report as recommended (as the basis for the establishment of the amount believed to be just compensation), accepted (meets all requirements, but not selected as recommended or approved), or not accepted. 

If authorized by the agency to do so, the staff review appraiser shall also approve the appraisal (as the basis for the establishment of the amount believed to be just compensation), and if also authorized to do so, develop and report the amount believed to be just compensation. 

(b) If the review appraiser is unable to recommend (or approve) an appraisal as an adequate basis for the establishment of the offer of just compensation and it is determined by the acquiring agency that it is not practical to obtain an additional appraisal, the review appraiser may, as part of the review, present and analyze market information in conformance with § 24.103 to support a recommended (or approved) value.

(c) The review appraiser shall prepare a written report that identifies the appraisal reports reviewed and documents the findings and conclusions arrived at during the review of the appraisal(s). Any damages or benefits to any remaining property shall be identified in the review appraiser’s report. The review appraiser shall also prepare a signed certification that states the parameters of the review. The certification shall state the approved value, and if the review appraiser is authorized to do so, the amount believed to be just compensation for the acquisition.146 

Federal agencies have adopted various policies and rules to implement these regulations.147 Therefore, review appraisers should refer to the agency-specific review standards for a detailed discussion of appraisal review requirements. Agency appraisal review standards generally set appraisal review requirements from USPAP as minimum appraisal review standards. 

In accordance with agency requirements, prior to approving an appraisal of property having more than nominal value, the review appraiser for each agency should prepare a written review report indicating the scope of work for the review and the reviewer’s analysis and support for the action recommended. It is the review appraiser’s responsibility to determine whether the appraisal is adequately supported, complies with recognized appraisal principles and practices, complies with the appraiser’s contract (or assignment letter) and these Standards, and conforms to all governing legal premises prescribed by written legal instruction. 

Appraisals provided by an agency to the U.S. Department of Justice in support of a request to initiate condemnation proceedings shall be reviewed by the Appraisal Unit of the Department. It is the responsibility of the Appraisal Unit to ensure that credible, reliable, and accurate appraisals are available for litigation purposes, including settlement negotiations and trial. In this regard, the Appraisal Unit shall confirm both technical conformance with these Standards and the reasonableness of the appraiser’s opinion of value. In addition, the Appraisal Unit shall determine the suitability of the appraisal report for trial purposes: it will identify weaknesses and strengths of the report under review and recommend actions that the government’s appraiser and/or trial counsel can take prior to trial to improve the appraisal report and provide better support for its conclusions. Appraisal reports may be found to be unsuitable for trial purposes even if they are in technical conformance with these Standards and the appraiser’s opinion(s) of value are reasonable.148 Due to the intended use and intended user of these appraisal reviews, review appraisers within the Appraisal Unit shall not develop their own independent opinions of value.