Understand appraiser workfile retention and confidentiality obligations when switching AMC panels

Steps

1. Confirm USPAP's Record Keeping Rule requires the appraiser — not the client or any AMC — to prepare and retain the workfile, and that this retention obligation sits with the appraiser regardless of which AMC engaged them.
2. Confirm USPAP's Confidentiality Rule restricts disclosing confidential assignment information or results to anyone other than the client, authorized due-process parties, state regulatory agencies, or authorized peer-review committees — meaning a new AMC on a new panel is not automatically entitled to a prior AMC's assignment results or workfile contents.
3. Note that USPAP does not explicitly assign 'ownership' of the workfile as a legal/property concept — this is typically addressed instead in the appraiser's engagement agreement with each AMC, which should be reviewed for its specific terms on report reuse, data handling, or panel-transition restrictions.
4. Advise the appraiser to check each AMC's panel agreement individually for any contractual claims to work product or data before assuming portability, or non-portability, of prior work.
5. If a dispute arises, treat it as a contract-law question between the appraiser and the AMC(s), not something resolved directly by USPAP or a federal/state appraisal regulation, and flag it for legal review.