Commercial Appraisal Review Template (Not Form)

[Funky Obsolescence]

Hi Everyone.

I’m an assessor but also a Certified General appraiser, and I need to write a rebuttal of an appraisal we received for court submission. The goal is to demonstrate that the appraiser used incorrect methodology in determining value. As far as I know, we are not currently able to provide our own opinion of value or submit a separate appraisal report.

I assume that, since I am a Certified General, any report I produce must be USPAP compliant, even in my role as an assessor. However, I haven’t found much online to confirm this. ChatGPT provided some compelling insights, though I’d like to verify its accuracy.

My Questions:​

1. Since I am a Certified General preparing a rebuttal for court submission, does my report need to be USPAP compliant?

2. I was planning to write a rebuttal letter, but after researching, it seems I might actually need to prepare a formal appraisal review report. However, I haven’t been able to find any commercial appraisal review templates, only standardized review forms.

Below is a summary of what I gathered from ChatGPT. Feel free to review at your leisure or peril.

Looking forward to your thoughts.

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CHAT GPT EXPLANATION​

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BEST PRACTICES FOR A CERT GEN WORKING AS AN ASSESSOR

Just because you hold a Certified General license doesn’t automatically mean everything you do in your role as a government assessor must be USPAP compliant. It depends on:

1. The Nature of Your Work – If you’re performing appraisal or appraisal review assignments as defined by USPAP, then compliance is required. But if your work is strictly for tax assessment purposes and follows local/state laws that do not require USPAP compliance, then it may not be necessary—even if you hold a Certified General license.

1. Jurisdictional Exception Rule – Many government assessors operate under laws that supersede USPAP requirements. If your state’s laws or policies govern your work and do not require USPAP compliance, then you may fall under the Jurisdictional Exception Rule, meaning you are not obligated to follow USPAP just because you’re a Certified General.

1. Scope of the Assignment – If you are not developing an opinion of value and are only analyzing another appraisal’s methodology without providing a formal review conclusion, then your work may not qualify as a USPAP-defined appraisal review, and compliance wouldn’t be required.

Comparison to Your Non-CG Coworkers:

• If your non-certified coworkers perform the same review or rebuttal work without needing USPAP compliance, then your certification alone does not change that requirement—unless your office or state specifically dictates that Certified Generals must follow USPAP in all work.

• However, if your office requires Certified Generals to comply with USPAP in all appraisal-related work, then you may be held to a different standard than your coworkers, but that would be a policy decision—not necessarily a USPAP mandate.

BOTTOM LINE:

Your Certified General license does not automatically require that your work be USPAP compliant if:

• You are working under local/state assessment laws that supersede USPAP (Jurisdictional Exception).
• The assignment is not an appraisal or formal appraisal review as defined by USPAP.

DOES OUR REBUTTAL NEED TO BE USPAP COMPLIANT?

A formal review conclusion under USPAP Standard 3 means that you are providing an opinion on the credibility of the appraisal report you are reviewing and not necessarily developing your own opinion of value.

What a Formal Review Conclusion Includes:

1. Assessing Credibility: You determine whether the opposing appraiser’s report is credible based on USPAP compliance, appropriate methodology, and proper application of appraisal principles.

1. Stating Your Conclusion: You must explicitly conclude whether the report is credible or not credible based on your analysis.

1. Following Standard 3 Requirements: You must define the Scope of Work, identify the appraisal under review, disclose assumptions, and ensure your review report meets USPAP requirements.

What It Does Not Require:

• You are NOT required to develop your own opinion of value unless that is part of your assignment.

• You can critique the appraiser’s methodology and assumptions without giving a new value conclusion.

What You Are Doing vs. a USPAP-Compliant Review:

• If your document only critiques methodology, identifies errors, and supports why the appraisal should be thrown out, but does not explicitly conclude whether the report is credible or no, then it may not meet the definition of a formal “appraisal review.”

• If you explicitly conclude whether the opposing appraisal is credible or not, then your work likely falls under USPAP Standard 3 and should be fully compliant.

Bottom Line:

Since your document is meant for court submission and argues why the opposing report should be rejected, it may be seen as an appraisal review. However, if you are not making a formal credibility conclusion and are only highlighting errors and methodological flaws, then it might be more of a rebuttal or litigation support report, which may not require USPAP compliance.

The question here is if this is a formal review opinion on credibility or just a technical rebuttal.

 

[glenn walker]

Hi Everyone.

I’m an assessor but also a Certified General appraiser, and I need to write a rebuttal of an appraisal we received for court submission. The goal is to demonstrate that the appraiser used incorrect methodology in determining value. As far as I know, we are not currently able to provide our own opinion of value or submit a separate appraisal report.

I assume that, since I am a Certified General, any report I produce must be USPAP compliant, even in my role as an assessor. However, I haven’t found much online to confirm this. ChatGPT provided some compelling insights, though I’d like to verify its accuracy.

My Questions:​

1. Since I am a Certified General preparing a rebuttal for court submission, does my report need to be USPAP compliant?

2. I was planning to write a rebuttal letter, but after researching, it seems I might actually need to prepare a formal appraisal review report. However, I haven’t been able to find any commercial appraisal review templates, only standardized review forms.

Below is a summary of what I gathered from ChatGPT. Feel free to review at your leisure or peril.

Looking forward to your thoughts.

---------------------------------------------------------------------

CHAT GPT EXPLANATION​

---------------------------------------------------------------------

BEST PRACTICES FOR A CERT GEN WORKING AS AN ASSESSOR

Just because you hold a Certified General license doesn’t automatically mean everything you do in your role as a government assessor must be USPAP compliant. It depends on:

1. The Nature of Your Work – If you’re performing appraisal or appraisal review assignments as defined by USPAP, then compliance is required. But if your work is strictly for tax assessment purposes and follows local/state laws that do not require USPAP compliance, then it may not be necessary—even if you hold a Certified General license.
2. Jurisdictional Exception Rule – Many government assessors operate under laws that supersede USPAP requirements. If your state’s laws or policies govern your work and do not require USPAP compliance, then you may fall under the Jurisdictional Exception Rule, meaning you are not obligated to follow USPAP just because you’re a Certified General.
3. Scope of the Assignment – If you are not developing an opinion of value and are only analyzing another appraisal’s methodology without providing a formal review conclusion, then your work may not qualify as a USPAP-defined appraisal review, and compliance wouldn’t be required.

Comparison to Your Non-CG Coworkers:

• If your non-certified coworkers perform the same review or rebuttal work without needing USPAP compliance, then your certification alone does not change that requirement—unless your office or state specifically dictates that Certified Generals must follow USPAP in all work.

• However, if your office requires Certified Generals to comply with USPAP in all appraisal-related work, then you may be held to a different standard than your coworkers, but that would be a policy decision—not necessarily a USPAP mandate.

BOTTOM LINE:

Your Certified General license does not automatically require that your work be USPAP compliant if:

• You are working under local/state assessment laws that supersede USPAP (Jurisdictional Exception).
• The assignment is not an appraisal or formal appraisal review as defined by USPAP.

DOES OUR REBUTTAL NEED TO BE USPAP COMPLIANT?

A formal review conclusion under USPAP Standard 3 means that you are providing an opinion on the credibility of the appraisal report you are reviewing and not necessarily developing your own opinion of value.

What a Formal Review Conclusion Includes:

1. Assessing Credibility: You determine whether the opposing appraiser’s report is credible based on USPAP compliance, appropriate methodology, and proper application of appraisal principles.
2. Stating Your Conclusion: You must explicitly conclude whether the report is credible or not credible based on your analysis.
3. Following Standard 3 Requirements: You must define the Scope of Work, identify the appraisal under review, disclose assumptions, and ensure your review report meets USPAP requirements.

What It Does Not Require:

• You are NOT required to develop your own opinion of value unless that is part of your assignment.

• You can critique the appraiser’s methodology and assumptions without giving a new value conclusion.

What You Are Doing vs. a USPAP-Compliant Review:

• If your document only critiques methodology, identifies errors, and supports why the appraisal should be thrown out, but does not explicitly conclude whether the report is credible or no, then it may not meet the definition of a formal “appraisal review.”

• If you explicitly conclude whether the opposing appraisal is credible or not, then your work likely falls under USPAP Standard 3 and should be fully compliant.

Bottom Line:

Since your document is meant for court submission and argues why the opposing report should be rejected, it may be seen as an appraisal review. However, if you are not making a formal credibility conclusion and are only highlighting errors and methodological flaws, then it might be more of a rebuttal or litigation support report, which may not require USPAP compliance.

The question here is if this is a formal review opinion on credibility or just a technical rebuttal.

Is this assessors office so small that you guys don't have access to a real estate attorney that can give you guidance on what your role is ? I would think you representing the assessors and an employee would want to be under jurisdictional exception not stepping out from under it and becoming a licence reviewer under USPAP and exposing your self to personal liability.

I think you need legal advice from your assessors office attorney before doing a USPAP compliant review and attaching your license to it. As far as the template I can't help you but others can. I'm more concerned about your legal and liability exposure once you are no longer protected by your jurisdictional exception. Remember once your naked you may hold some personal liability and a heavy hitter could name both the County and you the appraser both liable so you and your attorney need to determine what hat your wearing before doing anything.

 

[George Hatch]

It seems to me this is a legal question which is probably covered in your state's assessor materials. Not an appraisal standards question as such. It may not be an appraiser licensing issue, either.

 

[KHS445]

My experience, in Michigan, is that the Assessor values the subject property using whatever valuation method is used to value all other properties within the jurisdiction. You then explain why your valuation method is more fair, consistent and superior to that used by the other sides appraiser. You should be able to point to your Assessor’s manual that states this is how properties in the State of Minnesota are to be assessed.

Now when it comes to the other appraisal you can mention the comps are not from your jurisdiction, the sales are outside of your required sales study range, you can point out why the comparables they used are not considered comparables by the Assessing Office. In other words you do not review the valuation or provide an opinion thereof, you only point out the differences between the provided report and the assessing guidelines provided by the State.

The first thing I do when called upon to contest an assessment is pull a copy of the assessment card and look at the methodology and check for accuracy regarding the site and the improvements. I then search for sales, listings, etc of the most similar properties within the jurisdiction. I also look for the most similar properties within the jurisdiction that have not sold and request copies of those assessment cards and then compare the pricing, depreciation, site valuation, etc to ensure the Assessor has been consistent across all properties. You would be surprised how often I find mistakes and inconsistencies.

It is not your job to prove the valuation provided by the property owners appraiser is wrong, it is to show that you have followed your State Assessment Guidelines. Now you should make notes as to how the provided appraisal does not comply with the State Assessment Guidance or is inconsistent in some way or another. You don’t argue value, you only argue methodology and simple show that you have consistently followed the State Assessment Guidelines Lines and your estimate of value is correct based these guidelines.

Additionally, at least in Michigan, the Assessor bases their site valuation on a land sales study and then the depreciated cost of the improvements. Most appraisals will use the sales approach and possibly the income approach if the leases are such that they have an impact (negative) on the subject property’s value. Consult your attorney, but USPAP generally comes into play when you are advocating a value, and I also believe you may be exempt from USPAP as an Assessor. However, any legal advice you receive from members of this forum will be worth what you pay for it.

 

[sputnam]

1- Maybe. If your review includes an opinion of value, it is also an appraisal and had to comply with USPAP Standards 1, 2, 3, & 4. It applies whether you agree, disagree, state a range, or state your own point value for the subject property.

2- I've never seen a published review template. Most appraisers/reviewers develop their own, often based on what their mentor used, during the early years of their career.

Do Not... review the appraiser. Review the appraisal.

 

[Marty S.]

I would highly recommend doing the review in compliance with USPAP Standards 3 & 4, even if your status as an assessor does not require it. Here's the line of questioning your do NOT want to have happen to you on the witness stand:

Property Owner's Attorney: Sooooo, did you do this review in compliance with USPAP Standards 3 and 4?

You: No.

Attorney: Your Honor <addressing the judge>, I move that this witness' testimony and report not be admitted to evidence since they admit under oath that they did not conform to nationally accepted standards of appraisal review.

<well, that could be the end of the conversation and you have to go back to your office and hear from your coworkers every day how you were kicked off the witness stand>

Or:

Attorney: So, you are a state certified general appraiser and you did not follow USPAP requirements AND there is no Jurisdictional Exception to invoke?

<then repeat the Attorney's request of the judge to have you kicked off the witness stand>

And then: Attorney: Furthermore, since this Certified General Appraiser admits to not doing this review in compliance with USPAP Standards 3 and 4 (which is a requirement of all General Certified Appraisers in this state), I request that the court refer this matter to the State Board of Appraisers for potential fines, suspension and/or revokation of this appraiser's certification.



So, I highly recommend that you do the review in compliance with Standards 3 & 4, and that will be one less thing that the attorney will poke you about on the witness stand.

Been there; I still have the scars. (FYI: In my career, I have been on both sides of the assessment appeal world - as the government assessor and as as an expert witness -- among other various appraisal and review positions.)

Also, you didn't say if you are doing residential work or commercial work, but this is a link to the Appraisal Institute's residential review form:

https://www.appraisalinstitute.org/...d097797dae/AI-reports-residential-review-form

If commercial, do a Google search for commercial appraisal review template, and you'll find some examples like this one from Texas: https://member.texasbankers.com/App...mercialrealestateappraisalreviewchecklist.htm

CalTrans has this one: https://dot.ca.gov/-/media/dot-medi...xhibits/chapter-17/17-ex-06a-updated-a11y.pdf

As always, check to see if the forms or templates you find online are USPAP-compliant and then add or subtract material as you need it.


Marty

 

[Funky Obsolescence]

Hi Everyone.

I’m an assessor but also a Certified General appraiser, and I need to write a rebuttal of an appraisal we received for court submission. The goal is to demonstrate that the appraiser used incorrect methodology in determining value. As far as I know, we are not currently able to provide our own opinion of value or submit a separate appraisal report.

I assume that, since I am a Certified General, any report I produce must be USPAP compliant, even in my role as an assessor. However, I haven’t found much online to confirm this. ChatGPT provided some compelling insights, though I’d like to verify its accuracy.

My Questions:​

1. Since I am a Certified General preparing a rebuttal for court submission, does my report need to be USPAP compliant?

2. I was planning to write a rebuttal letter, but after researching, it seems I might actually need to prepare a formal appraisal review report. However, I haven’t been able to find any commercial appraisal review templates, only standardized review forms.

Below is a summary of what I gathered from ChatGPT. Feel free to review at your leisure or peril.

Looking forward to your thoughts.

---------------------------------------------------------------------

CHAT GPT EXPLANATION​

---------------------------------------------------------------------

BEST PRACTICES FOR A CERT GEN WORKING AS AN ASSESSOR

Just because you hold a Certified General license doesn’t automatically mean everything you do in your role as a government assessor must be USPAP compliant. It depends on:

1. The Nature of Your Work – If you’re performing appraisal or appraisal review assignments as defined by USPAP, then compliance is required. But if your work is strictly for tax assessment purposes and follows local/state laws that do not require USPAP compliance, then it may not be necessary—even if you hold a Certified General license.
2. Jurisdictional Exception Rule – Many government assessors operate under laws that supersede USPAP requirements. If your state’s laws or policies govern your work and do not require USPAP compliance, then you may fall under the Jurisdictional Exception Rule, meaning you are not obligated to follow USPAP just because you’re a Certified General.
3. Scope of the Assignment – If you are not developing an opinion of value and are only analyzing another appraisal’s methodology without providing a formal review conclusion, then your work may not qualify as a USPAP-defined appraisal review, and compliance wouldn’t be required.

Comparison to Your Non-CG Coworkers:

• If your non-certified coworkers perform the same review or rebuttal work without needing USPAP compliance, then your certification alone does not change that requirement—unless your office or state specifically dictates that Certified Generals must follow USPAP in all work.

• However, if your office requires Certified Generals to comply with USPAP in all appraisal-related work, then you may be held to a different standard than your coworkers, but that would be a policy decision—not necessarily a USPAP mandate.

BOTTOM LINE:

Your Certified General license does not automatically require that your work be USPAP compliant if:

• You are working under local/state assessment laws that supersede USPAP (Jurisdictional Exception).
• The assignment is not an appraisal or formal appraisal review as defined by USPAP.

DOES OUR REBUTTAL NEED TO BE USPAP COMPLIANT?

A formal review conclusion under USPAP Standard 3 means that you are providing an opinion on the credibility of the appraisal report you are reviewing and not necessarily developing your own opinion of value.

What a Formal Review Conclusion Includes:

1. Assessing Credibility: You determine whether the opposing appraiser’s report is credible based on USPAP compliance, appropriate methodology, and proper application of appraisal principles.
2. Stating Your Conclusion: You must explicitly conclude whether the report is credible or not credible based on your analysis.
3. Following Standard 3 Requirements: You must define the Scope of Work, identify the appraisal under review, disclose assumptions, and ensure your review report meets USPAP requirements.

What It Does Not Require:

• You are NOT required to develop your own opinion of value unless that is part of your assignment.

• You can critique the appraiser’s methodology and assumptions without giving a new value conclusion.

What You Are Doing vs. a USPAP-Compliant Review:

• If your document only critiques methodology, identifies errors, and supports why the appraisal should be thrown out, but does not explicitly conclude whether the report is credible or no, then it may not meet the definition of a formal “appraisal review.”

• If you explicitly conclude whether the opposing appraisal is credible or not, then your work likely falls under USPAP Standard 3 and should be fully compliant.

Bottom Line:

Since your document is meant for court submission and argues why the opposing report should be rejected, it may be seen as an appraisal review. However, if you are not making a formal credibility conclusion and are only highlighting errors and methodological flaws, then it might be more of a rebuttal or litigation support report, which may not require USPAP compliance.

The question here is if this is a formal review opinion on credibility or just a technical rebuttal.

 

[Funky Obsolescence]

Thanks everyone for the input. And yes, we do have attorneys working for us but you might or might not be surprised how much they don't know about the appraisal process. Marty, your answer was bang on. Thank you! It is a commercial property and I appreciate the links.

 

[WestMichiganCG]

Hi Everyone.

I’m an assessor but also a Certified General appraiser, and I need to write a rebuttal of an appraisal we received for court submission. The goal is to demonstrate that the appraiser used incorrect methodology in determining value. As far as I know, we are not currently able to provide our own opinion of value or submit a separate appraisal report.

I assume that, since I am a Certified General, any report I produce must be USPAP compliant, even in my role as an assessor. However, I haven’t found much online to confirm this. ChatGPT provided some compelling insights, though I’d like to verify its accuracy.

My Questions:​

1. Since I am a Certified General preparing a rebuttal for court submission, does my report need to be USPAP compliant?

2. I was planning to write a rebuttal letter, but after researching, it seems I might actually need to prepare a formal appraisal review report. However, I haven’t been able to find any commercial appraisal review templates, only standardized review forms.

Below is a summary of what I gathered from ChatGPT. Feel free to review at your leisure or peril.

Looking forward to your thoughts.

---------------------------------------------------------------------

CHAT GPT EXPLANATION​

---------------------------------------------------------------------

BEST PRACTICES FOR A CERT GEN WORKING AS AN ASSESSOR

Just because you hold a Certified General license doesn’t automatically mean everything you do in your role as a government assessor must be USPAP compliant. It depends on:

1. The Nature of Your Work – If you’re performing appraisal or appraisal review assignments as defined by USPAP, then compliance is required. But if your work is strictly for tax assessment purposes and follows local/state laws that do not require USPAP compliance, then it may not be necessary—even if you hold a Certified General license.
2. Jurisdictional Exception Rule – Many government assessors operate under laws that supersede USPAP requirements. If your state’s laws or policies govern your work and do not require USPAP compliance, then you may fall under the Jurisdictional Exception Rule, meaning you are not obligated to follow USPAP just because you’re a Certified General.
3. Scope of the Assignment – If you are not developing an opinion of value and are only analyzing another appraisal’s methodology without providing a formal review conclusion, then your work may not qualify as a USPAP-defined appraisal review, and compliance wouldn’t be required.

Comparison to Your Non-CG Coworkers:

• If your non-certified coworkers perform the same review or rebuttal work without needing USPAP compliance, then your certification alone does not change that requirement—unless your office or state specifically dictates that Certified Generals must follow USPAP in all work.

• However, if your office requires Certified Generals to comply with USPAP in all appraisal-related work, then you may be held to a different standard than your coworkers, but that would be a policy decision—not necessarily a USPAP mandate.

BOTTOM LINE:

Your Certified General license does not automatically require that your work be USPAP compliant if:

• You are working under local/state assessment laws that supersede USPAP (Jurisdictional Exception).
• The assignment is not an appraisal or formal appraisal review as defined by USPAP.

DOES OUR REBUTTAL NEED TO BE USPAP COMPLIANT?

A formal review conclusion under USPAP Standard 3 means that you are providing an opinion on the credibility of the appraisal report you are reviewing and not necessarily developing your own opinion of value.

What a Formal Review Conclusion Includes:

1. Assessing Credibility: You determine whether the opposing appraiser’s report is credible based on USPAP compliance, appropriate methodology, and proper application of appraisal principles.
2. Stating Your Conclusion: You must explicitly conclude whether the report is credible or not credible based on your analysis.
3. Following Standard 3 Requirements: You must define the Scope of Work, identify the appraisal under review, disclose assumptions, and ensure your review report meets USPAP requirements.

What It Does Not Require:

• You are NOT required to develop your own opinion of value unless that is part of your assignment.

• You can critique the appraiser’s methodology and assumptions without giving a new value conclusion.

What You Are Doing vs. a USPAP-Compliant Review:

• If your document only critiques methodology, identifies errors, and supports why the appraisal should be thrown out, but does not explicitly conclude whether the report is credible or no, then it may not meet the definition of a formal “appraisal review.”

• If you explicitly conclude whether the opposing appraisal is credible or not, then your work likely falls under USPAP Standard 3 and should be fully compliant.

Bottom Line:

Since your document is meant for court submission and argues why the opposing report should be rejected, it may be seen as an appraisal review. However, if you are not making a formal credibility conclusion and are only highlighting errors and methodological flaws, then it might be more of a rebuttal or litigation support report, which may not require USPAP compliance.

The question here is if this is a formal review opinion on credibility or just a technical rebuttal.

Go ahead and message me. I've done rebuttals before. It's easy to follow Standards 3 and Standards 4.

 

[Marty S.]

Thanks everyone for the input. And yes, we do have attorneys working for us but you might or might not be surprised how much they don't know about the appraisal process. Marty, your answer was bang on. Thank you! It is a commercial property and I appreciate the links.

Here's a link to an additional publicly available commercial appraisal review template: https://mf.freddiemac.com/docs/appraisal_checklist.xlsx

It is from Freddie Mac and is focused on institutional-grade multifamily property and, even though the format is 'funky', most of the line-items are germane to most commercial property types. It is in Excel format so you can reasonably edit it and add columns for things like "adequate" or "not adequate", and maybe even for your comments.

In appeal hearings most jurisdictions, the assessor's value is typically entered into the record as-published and presumed to be correct, so it is up to the property owner to offer evidence of a different value -- the burden of proof is on the property owner. Mostly likely, I would assume that your appraisal review would not have to comply with Standards 1 and 2 since you do not have to proffer an alternative valuation, and that only Standards 3 and 4 apply. In your jurisdiction, do you have to defend the mass appraisal model and its inputs/assumptions as part of this appeal? That is, do you also have a Standards 5 and 6 component to your testimony?

Bonne chance!

Marty