As this is in relation to Appraisal Review take a look at the following further down in the commentary:
vi. Appraisal reviews that do not include the appraiser's estimate of the property's value or opinion of value.
I do fill in occasionally in reviewing appraisals and evaluations at our bank and as part of the process I could disagree with the value, but that does not mean I can provide a value. All that mean is we need to get another opinion of value from a different qualified appraiser or evaluator. That second appraiser or evaluation would also be subject to Reg. B, but the review forms would not be. Maybe checking to see if the person filling out the form can state a value if they disagree and if that value is based on reevaluation of the property may help figure out your conundrum.