Scott,
Are you doing appraisals or not?
You will need to define for yourself and your clients exactly what you are and aren't doing. There's no reason a licensed appraiser can't also hold a real estate license, an SEC Series 7 License, car salesman license and a business license, all at the same time. No need to allow any of these licenses to go inactive simply because you're qualified to do other things.
With respect to your new job, there's a big difference between analyzing a commercial property and making recommendations about it for a client or employer in a capacity wherein you are clearly an advocate and not an appraiser; and valuing a property as an objective, unbiased and otherwise uninvolved appraiser. Just a hint here: whether or not you comply with SR2-3 by signing a certification for your appraisals is not the dividing line.
Let's say you do an analysis of an income property that includes a review of the income stream itself, a summary of comparable data, comparisons between that data and your subject, and concludes with some recommendations about exposure time, marketing time, and even potential pricing, etc. If a third party comes along and looks at your work product, and then interprets your work as an unbiased opinion of value then you have a problem. If that party can understand from looking at your work that you are not attempting to represent yourself as unbiased, nor in the capacity as an appraiser, then your work probably isn't going to cause problems.
You will not be able to do this kind of work by using standard appraisal report formats and then get away from being held accountable for it as an appraiser by excluding your certifications or using black and white photos or even by crossing out and substituting the word "Consulting Report" every time the form uses "Appraisal Report".
The term "Administrative" got used up there in one of the previous responses, as in "Administrative Review". Although I don't think it was you who brought it up, I'll address it anyway. Users of appraisal services do administrative reviews. What that means is that people who are engaged in making decisions about the property can review appraisal work in an administrative capacity. Even licensed appraisers can do this, if their function is to make a decision about the property rather than the appraisal. Examples of this would include if the person were working with the property as a property manager, or as a loan officer, or as a sales agent. However, the moment the focus of that activity switches from the disposition of the property to the quality of the appraisal report or the appraiser's work, then that person is engaged in a technical review as defined in the USPAP and all of those rules apply. If you're doing both, then you're doing both. Like most other types of valuation services, these functions need not be mutually exclusive.
Consider this. If tap dancing around the "value opinion" vs. "potential pricing" issue and playing with ambiguities doesn't appeal to you, you might try playing it straight and retaining your role as an unbiased appraiser, same as you would if you were an employee at a bank. Mere employment status doesn't automatically impugn your status as an unbiased appraiser unless you let it. It this applies to your situation, you can simply acknowledge that your work consists of developing appraisals and tailor them by using an appropriate scope of work, aimed specifically at your intended users and intended uses. Obviously, your clients will have different requirements than the average bank would have, and your work could look very different and still suffice within that scope.
The bottom line here is that it probably is easier to only own one hat. But if you do wear multiple hats, you will want to make sure that each hat is well identified in big bold neon letters, and that you never wear or even appear to wear the wrong hat for what you are doing. As others have already suggested, if you're worried about your license, you should contact your state board for clarification. They can probably assist you in erecting some fences that will keep your competing job descriptions from stepping on each other.
