Exhibit C Narrative Format.pdf

EXHIBIT EXHIBIT C – NARRATIVE FORMAT– APPRA

To provide uniformity for GSA files, the text of the Appraisal Report, as defined by USPAP 2-2(a) shall be divided into four parts as outlined below:

FORMAT

To provide uniformity for GSA files, the text of the Appraisal Report, as defined by USPAP 2-2(a) shall be divided into four parts as outlined below:

PART I - INTRODUCTION

1. TITLE PAGE. This shall include (a) the name, street address and GSA building control number of the property, (b) the name of the individual(s) signing the report, and (c) the effective date of the appraisal.

2. TABLE OF CONTENTS

3. LETTER OF TRANSMITTAL.

4. SUMMARY OF SALIENT FACTS AND CONCLUSIONS. Summarize the important data and conclusions in a concise manner, including:

Property Identification, Purpose of the Appraisal, Scope of the Appraisal, Date of Value, Site Description, Improvement Description, Percentage of Current Occupancy, Zoning, Highest and Best Use, Value Indications (by Cost, Sales Comparison, and Income Capitalization Approaches), discount, capitalization and growth rates used, Final Estimate of Value.

5. PROPERTY IDENTIFICATION. Identify the property by name, location, and address. A legal description, deed book and page number or plat reference is preferred.

6. SCOPE OF THE APPRAISAL. The asset is to be appraised is set forth in the Statement of Work (SOW) as of the effective date of value, or such other date(s) and in such other condition(s) as may be specified by the GSA Project Manager for the assignment. However, the hypothetical condition of ownership by a private sector purchaser is to be assumed. The types of value to be estimated include “as is”, “as rehabilitated”, and “interim as is” market value for the land and improvements merged. The “as is” land value is also required.

The estimates of value are for the fee simple estate. “As is” fair market value, as defined by GSA appraisal policy, is based on the market value of the real property in its current physical condition and use as of the effective appraisal date with the following Assignment

Conditions: (1) assume private (non-government) property ownership in a build to suit methodology; and (2) continued stabilized occupancy by the Federal government.

“As rehabilitated” fair market value, as defined by GSA appraisal policy, is a current market value reflecting an effective date that is within

(45) days of the date of the final appraisal inspection. “As rehabilitated” value opinions: (1) are intended to reflect the current expectations and perceptions of market participants, based on available market data; (2) requires an extraordinary assumption indicating the construction rehabilitation has been completed as of the date of value. This assignment condition ensures that the intended user understands that: (1) the rehabilitation is not completed as of the inspection date of the appraisal; (2) the analyses performed to develop the opinion of value are based on a hypothesis, specifically that the improved subject property is assumed to have the rehabilitation completed when in fact it is not completed as of the inspection date; (3) the rehabilitation process must be completed in a good and workmanlike manner consistent with sound construction practices as determined by GSA; (4) the improvements must be completed in a reasonable time from the effective date of the appraisal based upon the scope of the rehabilitation; (5) market conditions at the time of completion shall be similar to market conditions as of the effective date of the appraisal; (6) assume private (non-government) property ownership; and (7) continued stabilized occupancy by the Federal government.

The Fee Simple interest will be appraised, subject to any legally binding agreements, such as out-leases.1 The existing tenants may continue to occupy the property regardless of the hypothetical change of ownership. Although the existing tenants may continue to occupy the property under private ownership, assume that a private owner would require that market derived rents and terms would dictate their continuing occupancy. Additionally, for any current or expected vacant spaces, assume that they would be subject to market derived lease up, rents and terms.

1 No federal government-owned property has any legally binding leases because such agreements between government agencies are prohibited by law. To compensate for this, GSA has developed Occupancy Agreements (OA’s) that spell out the business agreements for occupancy of the spaces by tenant agencies. The OA’s are patterned after private sector leases, but are not legally binding. However, they represent a commitment by both the tenant agency and GSA that the agency will occupy the space for the term specified in the OA. In some cases, the leased fee estate may be analyzed where actual leases encumber the subject property between GSA, as landlord, and a private tenant through a formal out-lease.

“Interim use” fair market value, as defined by GSA appraisal policy, is current market value reflecting an effective date that is within (45) days of the date of the final appraisal inspection. If the existing improvements are determined to have little or no contributory value, the contribution of the existing improvements may not be in proper balance with the total property. A potential buyer may be more likely to base an investment decision on the risk and reward associated with a future use of the property rather than the current use. The current existing use may continue until it is economically feasible to absorb the costs of converting the property, either by razing and replacing the existing improvements or by rehabilitating them. Some functionally deficient improvements that clearly do not resemble the ideal improvement do create an increment of value over the value of the land as though vacant. Also, the interim use may have value to the property user to the extent that the income generated by the improvements defrays the costs of carrying the property, and the cost of demolishing the improvements. Based upon your market analysis, if this scenario presents itself during the appraisal process, the as is fee simple, fair market value, with the existing improvements as an interim use, shall be estimated.

Consideration shall be given to air rights in the value conclusion, if applicable. A separate report section is required for any air rights analysis.

The operating statement developed by the production appraiser must reflect market derived income and expenses that would be incurred by a private sector owner assuming application of competent property management practices observed in the local market.

Although the fee simple interest in the property is to be appraised, an analysis is to be done regarding the anticipated market derived income and expenses. Although not legally binding, the OA’s represent a commitment by both the tenant agency and GSA that the agency will occupy the s pace under the terms specified in the OA. This commitment is to be considered in the analysis of the property’s anticipated occupancy.

7. PROPERTY RIGHTS APPRAISED. The property rights to be appraised are the Fee Simple Estate, subject to any legally binding agreements, such as out-leases.

The Fee Simple estate is defined as:

Absolute ownership unencumbered by any other interest or estate, subject only to the limitations imposed by the governmental powers of taxation, eminent domain, police power, and escheat.

8. REQUIRED DEFINITION OF VALUE. The value to be appraised is the Market Value which is defined as:

The amount in cash, or on terms reasonably equivalent to cash, for which in all probability the property would have sold on the effective date of the appraisal, after a reasonable exposure time on the open competitive market, from a willing and reasonably knowledgeable seller to a willing and reasonably knowledgeable buyer, with neither acting under any compulsion to buy or sell, giving due consideration to all available economic uses of the property at the time of the appraisal.

The report will contain this definition and only this definition of Market Value within the content of the report, or any addenda or glossary attached to the report.

9. INTENDED USE AND USERS OF THE APPRAISAL. The intended use of the appraisal is to provide an opinion of the value of the asset for analysis by GSA in determining the appropriate strategy for the asset. The intended user of the appraisal is the GSA.

10. DATE OF VALUE. The date of value will be the date of the latest comprehensive inspection of the asset by the principal appraiser. The GSA COR on the appraisal contract has the authority to change the date of value due to exigent circumstances.

11. EXHIBITS.

PHOTOGRAPHS. Pictures of the subject shall show at least the front and rear elevations of the major improvements, a street scene, and any salient features (significant deferred maintenance or other value impacting conditions or features). Each subject photograph shall indicate the date the photograph was taken and the camera’s direction of view. When a large number of buildings are involved, including duplicates, one picture may be used for each type of building as long as the photograph is labeled to indicate that it represents a typical building type. Views of the comparable data are to be included. All graphic material shall include captions.

MAPS. Legible location maps of the subject property and the comparable data must be included. The scale of the maps must be sufficient to allow the GSA reviewer to understand the relevant market locational characteristics including physical and topography barriers, transportation corridors and relevant neighborhood linkages.

12. STATEMENT OF LIMITING CONDITIONS AND ASSUMPTIONS. The appraisal shall clearly and accurately disclose all assumptions, extraordinary assumptions, hypothetical and limiting conditions to which the valuation is subject and that are used in the report.

Each assumption or condition must be reasonable and supportable in the context of the appraisal. The appraiser must ensure that assumptions and limiting conditions are appropriate to the property being valued and refrain from boilerplate that has no bearing on the appraisal, the reporting process or the conditions of employment.

13. APPRAISER’S CERTIFICATION. All appraisers who sign any part of the report will provide a certification as required by the licensing board in the state, commonwealth, territory or district where the property is located, and by USPAP. This shall include a statement that signatories have no undisclosed interest in property, that the statements included in the appraisal report are true and correct, that they have personally inspected the interior and exterior of the premises, date and amount of value estimates, etc. Any hypothetical conditions required by these specifications must be included within the certification.

PART II - FACTUAL DATA

14. REGIONAL AND CITY ANALYSIS. In a concise manner, discuss the pertinent aspects of the asset's city and or region (e.g. geographic, legal, social and economic factors). Include a succinct description of the regional market for the asset's property type. This data should include such information as affects the appraised property together with the appraiser’s conclusions as to significant trends.

15. NEIGHBORHOOD DATA. Clearly define the asset's neighborhood, including boundaries, land use patterns, transportation issues, vacant land (especially developable land), as well as the lifecycle of the neighborhood (e.g., developing, stable, declining, redeveloping).

Include a description of the local market for the asset's property type, and any other characteristics that have an impact on the asset’s value, either positive or negative (vacancy rates, market rents, absorption, efficiency factors, and R/U ratios). Provide a comparative analysis of the subject property within the context of its market. The Market Rentable/Usable (R/U) factor estimated for the subject must be appropriately analyzed, quantified, and supported in this section. The appraiser shall refrain from applying any statistics and language that can be construed as discriminatory in defining and describing the neighborhood.

16. PROPERTY DATA -

a. LEGAL DESCRIPTION - This description shall be sufficient to properly identify the property appraised. If lengthy, it can be referenced and included in Part IV.

b. SITE – The site description will be based on information provided by GSA, the appraiser's inspection, and other data as may be gathered from publicly recorded or other reliable sources. Describe the relevant characteristics of the site (both positive and negative) that impact the site's use and value. Describe the site's location, size, shape, access, ingress/egress, soil, topography, utilities, mineral deposits, easements, off-site improvements, any excess land, and any other relevant factors.

Discuss any issues that impact the functionality of the site, such as drainage/flood plain, soil, visibility, developability, environmental issues or excess land. If an asset being valued shares an undivided site with a number of other assets that are not part of the asset being appraised, the production appraiser shall immediately contact the GSA Project Reviewer for the assignment to discuss the method by which a reasonable and adequately supported estimate of the land necessary to support the existing or proposed asset shall be allocated. An appropriate disclosure of the extraordinary assumptions and limiting conditions related to such an allocation of land must be made within the appraisal report.

While appraisers are not normally expected to be environmental experts, they should make a reasonable attempt to discover if there is contamination on the property. The appraiser shall note in the report any observed, suspected or other knowledge of environmental contamination. The impacts of any noted environmental issues will be appropriately addressed.

c. LEGAL RESTRICTIONS. Discuss the zoning that regulates the development of the site, or the most likely zoning that would regulate the development of the site under private ownership. Include relevant requirements such as permitted land uses, maximum building height, floor area ratio (FAR), and minimum setbacks and parking spaces. Discuss if the site and/or existing improvements (including the parking) are in compliance with the zoning regulations that impact the site. Discuss any other legal restrictions (binding agreements, covenants, easements, transferable development rights), and/or other regulations (historic designations or local comprehensive plans) that would impact the value of the site under private ownership.

d. IMPROVEMENTS - This description may be by narrative or schedule form and shall include dimensions, square foot measurements, and where appropriate, a statement of the method of measurement used in determining rentable areas such as full floor, multi-tenancy, etc. Briefly describe the exteriors and interiors of any existing improvements. Include age, condition, quality, functional utility (or inutility), gross building area, net rentable area, usable area, joint use spaces, core factors, number of stories, adequacy of parking, and any other relevant characteristics (GSA rentable area may not be the same as rentable area in a specific market). Describe if the asset’s leasing quality is considered to be Class A, B, or C (or lower) by market participants. If the property has a LEED certification, discuss the certification and its impact on value. If the property has a historic preservation designation, discuss the designation status and any impact on value. State and photograph any deferred maintenance observed during the inspection of the building. Discuss and quantify any immediate capital costs that a private purchaser would incur. The appraiser must address whether the GSA R/U factor is reasonable, based on the inspection of the appraised.

Analyze and discuss the subject property’s market rentable area compared to the rentable area reported by GSA. The market rentable area is to be used in estimating the asset’s value.

e. HISTORY - State briefly when GSA took possession of the property (include at least a ten-year history of the subject property) and, if possible, cite the deed book and page of the transaction. Include a copy of the deed in the report, if possible. State the purpose for which the improvements were designed, dates of original construction and major renovations, and/or additions.

f. REAL ESTATE TAXES. Estimate the real estate tax assessment under private ownership. State the tax rate and give the dollar amount of the tax estimate. Future trends or prospective changes in the level of taxes should be discussed.

PART III - ANALYSES AND CONCLUSIONS

17. ANALYSIS OF HIGHEST AND BEST USE. Describe the highest and best use of the site “as if vacant” and “as improved”, using standard appraisal guidelines of physically possible uses, legally permitted uses, financially feasible uses, and maximally productive uses. The analysis should tie the highest and best use to the analyses used in the descriptions of the regional and neighborhood markets, the site, and the existing improvements. In the “as if vacant” analysis, include a discussion of the size as well as the type of any buildings that represent the highest and best use. Determine whether the existing improvements represent the highest and best use of the site, including if they represent a viable interim use or a special purpose use. Consider whether any opportunities to increase income and/or value of the existing improvements are observed.

The appraiser shall prepare a financially feasible analysis including the financially feasible rent estimate. For land use to be considered financially feasible, the value of the land use must exceed its cost. The financially feasible rent is the rent necessary to justify new construction. This concept helps the analyst determine the timing of development, as well as the difference between the required rent and market rent based on known costs and expected returns to the investor.

The Government-owned assets over which GSA has stewardship often have unique design and construction, and many are over 50 years old. Therefore, the highest and best use analysis will be critical to determining strategies for the asset.

18. LAND VALUE. The appraiser’s opinion of the value of the land shall be supported by confirmed sales of comparable lands. Differences shall be weighed and explained to show how the sales indicate the value of the land being appraised. Adjustments should be made from the sales to the subject, either in dollar amounts or percentages for all applicable elements of comparison. Provide adequate summary descriptions of comparable land sales, including location maps. Comparable sales used should be confirmed by someone having personal knowledge of the terms and conditions of the sale as well as the motivation of the principals. Reference to public records and revenue stamps does not confirm the terms and conditions of a sale. Tie the land valuation to the highest and best use analysis. All appraisals must include a section estimating the market value of the asset’s underlying land as if vacant and ready for development. Vacant and ready for development means the improvements have been removed and all entitlements have been obtained for the highest and best use. Deductions for demolition costs and the costs and timing of entitlements shall not be considered in the value conclusion.

19. VALUE ESTIMATED BY COST APPROACH. The Cost Approach should be considered if it provides a relevant estimate of market value. It is particularly important when a lack of market activity limits the usefulness of the Sales Comparison Approach and when properties are not amenable to valuation by the Income Capitalization Approach. Since these characteristics pertain to some of GSA's Government-owned properties, the Cost Approach may be a viable method of valuation.

This shall be in the form of quantitative data, arranged in sequence, beginning with reproduction or replacement cost. The dollar amounts of physical deterioration and functional and external obsolescence, or the omission of same, shall be explained in narrative form. The reader should be able to follow the appraiser's logic to his/her conclusion of value.

Identify and describe the source used to estimate the replacement cost (or reproduction cost). The quantity survey or unit- in-place methods of estimating replacement/reproduction cost are preferred for most properties.

Describe and quantify direct and indirect costs.

Describe and estimate entrepreneurial profit.

Explain and quantify all applicable types of accrued depreciation, including physical deterioration and functional and external obsolescence. Include deferred maintenance costs. Discuss whether the accrued depreciation is curable or incurable.

Discuss the asset's total and remaining economic life, and effective age.

The Cost Approach may not be applicable to the valuation of all GSA assets. If GSA grants omission of the Cost Approach, at a minimum, the market value of the site is to be estimated, the total and remaining economic life and effective age of the improvements are to be quantified, and any applicable forms of obsolescence and/or depreciation are to be discussed. The elimination of the Cost Approach does not relieve the appraiser of the obligation to provide an estimate of the rent required to justify new construction as delineated in Section 20 which immediately follows.

20. VALUE ESTIMATED BY INCOME CAPITALIZATION APPROACH. This shall include adequate factual data (a) estimated gross full service market rent; (b) allowance for vacancy and credit losses; (c) an itemized estimate of total anticipated expenses including reserves for replacement; and (d) net operating income. Capitalization of net income shall be at the rate prevailing for the subject property’s type and location. The capitalization technique, method and rate used shall be explained in narrative form supported by an explanation of sources of rates and factors. The reader should be able to follow the appraiser's logic to his/her conclusion of value.

vacancy rates for similar properties.

Describe current rents, current tenant(s), and current and forecasted income and expenses.

Discuss supply and demand in the market, including the subject's competitive position. Explain the key functional and economic issues, both positive and negative, relating to the subject property.

Describe and analyze market rents (including escalations, concessions, length of the initial lease and the number and length of any renewal options, lease terms and conditions, tenant improvement allowances, expenses and any expense stops, etc.).

Federal leases may not be used as lease comparable data. Compare the market rents to the rents generated under current federal ownership based on any OA’s impacting the property. The use of comparable leases more than one year old must be adequately explained and justified.

Describe and analyze expenses in comparable properties, including fixed (ad valorem taxes and insurance), and variable (management, administration, utilities, cleaning, repairs and maintenance). Discuss the projected expense statistical data (ratios, units of comparison) of the subject property as if owned by a private owner.

Each rent comparable shall be weighed and explained in relation to the subject, and adjustments are to be made from the comparable to the subject. The rent comparable data should be adjusted in relation to the subject for physical attributes such as location, age/condition, parking, quality/aesthetics, access/visibility, core factors, and efficiency ratios. Quantify and describe the adjustments applied.

Discuss and quantify any immediate capital costs that a private purchaser would incur. Analyze any capital investments that are proposed by GSA, to determine which, if any, would also be incurred by a private sector purchaser.

Develop a stabilized operating statement, addressing stabilized capital reserves. The appraiser's conclusion should be based on comparison with similar rentals.

Estimate the value of the property using the Direct Capitalization method. Explain and support the overall capitalization rate used. Ideally, capitalization rates should be developed from the sale of similar properties, preferably in the market of the subject property. The source data for any mortgage and equity rates used should be included.

If applicable, estimate the value of the property using the discounted cash flow analysis technique. Discuss anticipation of change of the subject property and support anticipated changes. Explain and support the discount and exit capitalization rates used.

Market Rent The market rent underwriting for a build to suit project normally requires the underwriter to evaluate the following criteria within the lease rental structure: (1) development costs of the facility; (2) credit strength of the tenant/occupant; (3) the amount of the periodic rent; (4) the length of the lease, including options; (5) the allocation of expense responsibilities (type of lease – gross or net lease types); (6) the type of amortization, if any, of the return of capital during the lease term; (7) concessions within the lease (free rent, delay in payment of the rent, etc); (8) the potential alternative uses of the proposed or existing improvements based upon market analysis; and (9) the market rate of return on funds. The criteria discussed herein all focus on the degree of risk that the capital investor is prepared to accept. As the perceived risk increases in a transaction, the underwriting becomes more stringent.

The underwriting for the market rent is based upon the financially feasible analysis completed in the Highest and Best Use Section of the report. The capital investor would apply: (1) the total development costs (total capital investment); (2) a market rentable building area; (3) a market rate of return; (4) an operating expense adjustment which includes real estate taxes and insurance; (5) no vacancy adjustment; (6) an amortization adjustment to pay down part or all of the total capital investment over the term of the lease; (7) a long term lease period (the economic life of the courthouse); and (8) a market rate of return on funds to attract investor capital with the strength of a credit tenant that includes an amortization adjustment within the rate. See the financially feasible rent discussion

21. VALUE ESTIMATE BY SALES COMPARISON APPROACH. All sales used shall be confirmed by the buyer, seller, broker, or other persons having knowledge of the price, terms, and conditions of sale. Each comparable shall be weighed and explained in relation to the subject from this approach. The use of comparable sales more than one year old must be adequately explained and justified.

Adjustments should be made from the sale to the subject, either in dollar amounts or percentages for all applicable elements of comparison. The comparable sales should be adjusted in relation to the subject property for market and property conditions, location, core factors, efficiency ratios and other appropriate factors. The reader should be able to follow the appraiser's logic to his/her conclusion of value.

22. RECONCILIATION AND FINAL ESTIMATED VALUE. The appraiser shall interpret the foregoing estimates and shall state their reasons why one or more of the conclusions reached in items (19), (20), and (21) are indicative of the market value of the property. Discuss the appropriateness and reliability of each approach and logically explain the derivation of the final estimated value. Pure "averaging" is not defensible.

i These assumptions may have significant impacts on other criteria used in the appraisal to include vacancy and collection rates applied, and the capitalization and discount rates used in the report, PART IV - EXHIBITS AND ADDENDA

Items 23. – 27. may be located within the appropriate sections of the body of the report.)

23. PLOT PLAN AND TAX MAP

24. FLOOR PLANS: If floor plans are provided to the appraiser, only one representative floor plan is to be used in the report.

25. COMPARATIVE DATA MAP(s): The production appraiser must show the geographic location of the appraised property and the comparative data analyzed.

26. OTHER PERTINENT EXHIBITS. The production appraiser must include a copy of the Statement of Work identified in the accepted contract of work. The production appraiser must also complete and include the GSA – Narrative Market Value Appraisal Report Summary of Significant Conclusions and Statement of Work Reporting Requirements Checklist with the report indicating that the appropriate information required in the report has been included, and identifying the pages where such information is located.

27. QUALIFICATIONS. (Include the qualifications of all appraisers and analysts significantly contributing to the value(s) reported.)

APPRAISAL SOFTWARE

If a property requires a discounted cash flow (DCF) in the analysis, the software must have certain capabilities. It must calculate individual tenant cash flows, combine the individual cash flows into a single property cash flow, and calculate the data into present value. It must handle individual terms and conditions as well as variations in assumptions over time, and display the assumptions used. The reviewer must be able to follow the assumptions, data, and calculations used in a DCF analysis. Argus is an example of such software. Any discounted cash flow files used in the analysis are to be provided in electronic form and must be compatible with the most current version of that software as of the date of the report’s publication. Other spreadsheet files that are used in the analyses should be Microsoft Excel software or comparable and compatible software and should also be provided in electronic form in a separate file from the appraisal file.

PART V – APPRAISAL REVIEW

Purpose of this Review To complete a desk review, as defined, of the original appraisal under review (OAUR) that estimates the market value of the real property interests required by the Client in the scope of work. The appraisal review is the act or process of developing and communicating an opinion about the quality of the principal appraiser’s work. The desk review is limited to the data presented in the report, which shall be independently confirmed by the GSA reviewer. The reviewer has checked the accuracy of the calculations, the reasonableness of the market data, the logic of the value conclusions and the appropriateness of the methodology for compliance with the GSA scope of work and USPAP. The desk review does not include: (1) an inspection of the subject property; (2) an inspection of the comparable properties; and (3) a legal or business evaluation of the title and zoning data except as it directly relates to the appraisal conclusions. In accordance with USPAP and the Client’s Scope of Work, this appraisal review is to ensure that the information, data, and analyses developed in the LAR support and defend the principal appraiser’s conclusions of value contained therein.

Intended Use of the Review The intended use of the review determines whether the OAUR complies with USPAP and the Client’s Scope of Work. The appraisal review recommendation assists the Client with decisions regarding the asset management of the subject property.

Client and Intended User of Review The Client is GSA. The Intended Users are the Client and all federal agencies with regulatory oversight authority of the Client including but not limited to the Client’s auditors, the Office of Management and Budget (OMB) and the Department of Justice (DOJ).

Appraisal Standards for Review The OAUR shall comply with USPAP and the GSA Supplemental Appraisal requirements. The reviewer shall comply with USPAP Standards 3 and 4 and the GSA Scope of Work. The OAUR must be credible, not misleading and performed in a manner commensurate with that of the appraiser’s peers for an appraisal assignment of this type. The review appraiser’s analyses, opinions, and conclusions are to be developed and prepared, in conformity with the GSA Scope of Work and other applicable requirements, including, to the maximum extent practicable the 2022-2023 Edition of USPAP and the applicable laws, public policy, and other federal requirements that would normally take precedence over USPAP.

Date of Review The effective date of the review is the effective date of the OAUR value conclusions. The actual delivery date of the review transmitted to the Client is reported on the appraisal review checklist.

Authority of the Reviewer The reviewer has the authority to contact the principal appraiser and request changes, based upon potential deficiencies, to the OAUR. The principal appraiser must address the reviewers’ comments in accordance with Paragraph 5.1 – Deliverables within the SOW. The reviewer cannot require changes to the OAUR but must reach consensus with the principal appraiser on issues within the OAUR. If the principal appraiser and reviewer cannot reach consensus on review issues and an impasse occurs, the dispute is elevated to the Program Manager (FMVM) for a final review decision. In the event the appraisal review issues cannot be resolved between the FMVM and the principal appraiser, the OAUR will be referred to the Contractor Officer Representative (COR) for an evaluation of GSA’s contractual rights. The OAUR must be approved by GSA prior to any invoice payment.