A commercial appraisal review form is the document a review appraiser completes to evaluate whether an original commercial property valuation is credible, well-supported, and compliant with professional standards.1Appraisal Subcommittee. USPAP Compliance and Appraisal Independence To fill one out correctly, you identify the scope of your assignment, work through each approach to value the original appraiser used, check the data against independent sources, state a reasoned conclusion about whether the value is supported, and sign a certification that accurately describes what you did. Then you submit it through the channel the lender or Appraisal Management Company (AMC) specified in the engagement.
The form itself varies. The Appraisal Institute publishes standardized AI Reports templates for review assignments, and many lenders use proprietary versions. The sections below track what every version asks for.
Decide Which Review You’re Performing
Before you open the form, be clear on which of two assignments you accepted, because the type dictates what you can truthfully put in the certification.
- A desk review is done from your office using the original report, public records, and market databases. The focus is internal consistency: whether the math checks out, the comparables make sense, and the report meets USPAP requirements.
- A field review adds inspection. You visit the subject and the comparables cited in the report, usually from the street, to verify physical characteristics and neighborhood description. The effort approaches that of a full appraisal.
The engagement should also tell you whether the client wants an independent opinion of value or only an evaluation of the original appraiser’s work. That distinction changes what you must analyze and what fields on the form you have to populate.
Gather Your Inputs
You cannot credibly complete the form without the full original report package and independent market data to check it against.
- The complete original appraisal with all addenda: maps, photographs, rent rolls, supplemental data, the engagement letter, and any correspondence that spells out assignment conditions the lender imposed on the original appraiser.
- Public records for the subject and every comparable cited: county assessor data, recorded sales, zoning maps, and building permits.
- Market databases. Subscription platforms such as CoStar provide transaction history, lease rates, occupancy, and property characteristics for commercial assets, and cross-referencing the original comparables against them is where most problems surface.2CoStar. Who We Serve – Appraisers
- Competency in the property type and local market. USPAP’s Competency Rule requires it, so if you lack familiarity with the market, you must acquire that competency through study, association with a knowledgeable appraiser, or retention of one, before you accept the assignment.3mvfairhousing.com. Uniform Standards of Professional Appraisal Practice – Standards 1-4
Fill Out the Form Section by Section
Property and Assignment Identification
Enter the subject’s physical address, property type, the effective date of the original valuation, and the name and credential level of the original appraiser. For federally regulated commercial transactions, that appraiser should hold a Certified General Appraiser credential. Confirm the credential is active and in good standing; a review that fails to flag an unqualified appraiser has missed its most basic function.
Then identify your own assignment on the form: desk or field review, whether you are developing an independent opinion of value, the intended users, and the intended use of the review. Scope errors here are one of the fastest ways to produce a non-compliant report.
Evaluating the Approaches to Value
Commercial appraisals typically apply some combination of the sales comparison, income capitalization, and cost approaches. Judge whether the original appraiser chose the right approaches for the property type, and then test the work within each one.
- Income approach. For income-producing property such as office, retail, apartment, and industrial, this is usually the most relevant method. Check reported income and expense figures against market norms. Verify the capitalization rate against recent comparable sales. If a discounted cash flow was used, trace the assumptions about rent growth, vacancy, and discount rate back to market evidence.
- Sales comparison approach. Confirm that comparables are genuinely comparable in size, age, location, and property type. Check adjustment amounts for reasonableness; large, unexplained adjustments are a red flag. Verify sale prices and dates against public records or market databases.
- Cost approach. Most useful for newer or special-use properties. Verify the land value estimate and the cost data source, and test whether depreciation estimates for physical deterioration, functional issues, and external factors fit the property’s age and condition.
If the original appraiser leaned heavily on one approach while ignoring another the market would clearly support, such as skipping the income approach on a fully leased office building, say so on the form and explain why that choice weakens the final value conclusion.
Stating Your Conclusion
The form requires a direct statement of whether you agree or disagree with the original value. A vague endorsement will not do. Spell out which data, methodology, or analytical choices support or undermine the number.
If the engagement asked for your own opinion of value and it differs from the original, use the form’s independent-value fields and support that figure with the same rigor expected in a full appraisal: market data, comparable analysis, and clearly stated assumptions. In the commentary sections, list the specific discrepancies you found, such as misreported square footage, outdated comparable sales, or unsupported income projections, and explain how each affects the credibility of the original report.
Certification and Signature
Every completed review form requires a signed certification. Under USPAP, it must state that the analyses, opinions, and conclusions are your own, that you have no present or prospective interest in the subject, and that your engagement was not contingent on reaching a particular result.4The Appraisal Foundation. USPAP If you performed a personal inspection, the certification must say so; if you did not, it must say that as well. Signing a certification containing inaccurate statements is itself a USPAP violation and can trigger disciplinary action.
Ethics and Independence You Have to Clear
Before accepting the review, USPAP’s Ethics Rule requires you to disclose to the client any current or prospective interest in the subject or the parties, and any services you performed regarding the subject within the three years before accepting the assignment, whether as an appraiser or in any other capacity. If a confidentiality agreement with a prior client prevents that disclosure, decline the assignment.
Independence also means refusing to let the lender’s desired outcome shape your findings. Pressure from loan officers to make the numbers work is the dynamic federal interagency guidelines were written to prevent, with the appraisal and review function kept separate from loan production.5Federal Deposit Insurance Corporation. Interagency Appraisal and Evaluation Guidelines If you encounter that pressure, report findings based solely on the evidence.
Submit the Review and Handle What Comes Back
Most lenders and AMCs receive completed reviews through encrypted digital portals. Upload the form, your supporting documentation, and the signed certification through the platform named in the engagement. Turnaround expectations typically run three to five business days from acceptance, with complex properties or field reviews taking longer.
If your review identifies significant problems, such as unsupported comparables, mathematical errors, or a value conclusion that does not follow from the data, the original appraiser may get a rebuttal opportunity to provide additional evidence or clarify methodology. The lender decides whether the rebuttal resolves the issue or whether the original appraisal remains inadequate for underwriting.
A review that concludes the original value is unsupported has direct consequences for the loan. If you determine a property is worth $8 million rather than the originally appraised $10 million, the lender must recalculate loan-to-value using the lower figure. For a borrower seeking a $7 million loan, that shifts LTV from 70% to 87.5%, likely above the lender’s risk threshold, and the borrower then has to reduce the loan amount or increase the down payment.
Keep the Work File
USPAP’s Record Keeping Rule requires you to retain the complete work file for every review, including the original appraisal, your analysis, market data, correspondence, and the final review form, for at least five years after preparation. If you testified about the assignment in a legal proceeding, retention extends to at least two years after that proceeding’s final disposition, even if that runs past the five-year mark.
One boundary worth knowing: the Equal Credit Opportunity Act’s rule requiring creditors to give applicants copies of appraisals and written valuations applies to loans secured by a first lien on a dwelling of one to four units, including business-purpose loans secured by such property.6Consumer Financial Protection Bureau. 12 CFR 1002.14 – Rules on Providing Appraisals and Other Valuations For purely commercial collateral such as office buildings, warehouses, and retail centers, the ECOA copy requirement does not apply.7Consumer Financial Protection Bureau. Equal Credit Opportunity Act Valuations Rule Small Entity Compliance Guide Keep the file anyway; it protects every party if the loan defaults or the valuation is later challenged.