Gray area? What gray area? I don't know why anyone would be confused. The appraiser doesn't control the distribution of the report; the client/lender does. It says so right at the top of this cert and that is entirely consistent with the Confidentiality section of the ETHICS RULE. The requirements of which haven't changed since it's inception.
They finally did clarify the "may use" clause from C#23 as "you might come into contact with this report but that doesn't make you an intended user of this appraisal". They should have done this the last time they revised the 1004. Then again, the last time they didn't have a subject matter expert on staff who understood USPAP.
Appraisers should send DW a box of cigars for that. Not even an activist judge or an appraiser with anti-licensing biases can feign "misunderstanding" of the meaning and intent of this cert as per this clarification.
Fannie/Freddie's form, their policies, their usage, and its all consistent - not conflicting - with USPAP. There's no reason for anyone to think the appraiser has the right to tell the client they can't distribute the report.