Is the review appraiser acting as an appraiser under USPAP? How do USPAP standards apply?
For appraisal review activities related to acquisition performed under the Uniform Act, all of the review appraiser’s actions are specified by, and are considered to be part of the appraisal review process required by 49 CFR Part 24. Note that, even though §24.104 does require the review appraiser to comply with §24.103 appraisal requirements when developing an independent approved or recommended value, it also specifically cites this work as being part of the review itself. USPAP is not an appropriate measure of the review appraiser’s activities. Compliance with USPAP standards is not required by this regulation. Appraisal and appraisal review reports are to be prepared in accordance with the Uniform Act regulation, which the FHWA believes is consistent with, but not necessarily identical to, USPAP. The FHWA believes that appraisal reviews performed in compliance §24.104 requirements do comply with USPAP Standard 3.
