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Rollout of 3.6 Receives Mixed Feedback

 by Isaac Peck, Publisher

 UAD 3.6 and the redesigned Uniform Residential Appraisal Report went into broad production for all lenders on January 26, 2026. After a limited production period that began in September 2025, appraisers across the country are now completing and submitting appraisals under the new system. Full mandatory adoption for all GSE-bound appraisals takes effect on November 2, 2026.

The profession is just over two months into the full-live phase, and the early returns are mixed. Appraisers who have worked with the new format describe a report that is more narrative and more flexible than the legacy forms it replaces. The format’s promised reduction in revisions, but the transition has also exposed real friction. Software platforms are still catching up, the adaptive form structure has a learning curve, and mobile data-collection tools remain unreliable in the field.

As we reported in our Fall 2025 issue, the biggest promise of the rollout was to speed up the review process and reduce the back-and-forth between appraisers and lenders. Whether it delivers on that promise depends largely on how quickly the technology and training catch up to the standard. That question is now being answered in real time.

Here is what Working RE is hearing from appraisers, lenders, and software providers in the first months of the transition.

The First Appraisals
The first fully compliant UAD 3.6 appraisal was completed, submitted, and accepted on November 14, 2025. In an episode of the Appraisers Update Podcast, host Brian Reynolds spoke with appraiser Adam Winstead about the experience. Winstead completed the appraisal through North State Bank in North Carolina. The inspection itself was unremarkable. Reynolds called it “business as normal.” Winstead agreed with, “nothing out of the ordinary.”

The report was a different story. Winstead described the writing process as “a little tedious” with “a learning curve” because the software was brand new. “The user interface looks familiar,” he said, but he “did have to call tech support and get some guidance.” Inserting photos was clunky, but in the end, everything was uploaded and the local lenders were happy with the result. “The most important assignment I’d had. Ever,” Winstead described it.

In mid-February, AVSociety published a video panel hosted by Gynell Vestal titled “UAD 3.6 Appraisals: What Appraisers Are Seeing in Day-to-Day Work,” featuring appraisers who have completed 3.6 assignments alongside software developers whose platforms have been GSE-verified. Among the panelists were Billy Lumadu, a staff appraiser at IRM Solutions who has completed 11 UAD 3.6 assignments, Jim Stafford, an independent appraiser in Frisco, Texas, with two completed, and Winstead.

The appraisers on the panel were broadly positive about the format itself. The new report structure walks appraisers through their analysis in a logical sequence rather than burying key reasoning in addenda. Stafford pointed to Highest and Best Use as an example: “You click the four boxes and then below that you explain why it’s the highest and best use. It’s all just right there instead of trying to find their analysis of the Highest and Best use hidden in the addendum somewhere,” he said. Jones added that there is “space throughout the report to present your commentary contextually so that it’s not buried at the back of the report.”

Specificity and concrete narrative were a common theme in the discussion of how 3.6 will require a retraining of appraisers’ “muscle memory.” Jones noted how the new format pushed appraisers toward “specific and concise” commentary rather than the sometimes-vague language that residential appraisers can fall into. “Treat this as a narrative instead of a form,” Winstead added.

Lumadu, having completed more 3.6 reports than any other panel member, noted that he has seldom received requests for revisions among his 11 assignments. The only callback was a lender requesting two additional relevant rows in the sales grid. “That’s the point of 3.6,” Lumadu said. “Less revisions.”

Time and Fees
One of the most common concerns among appraisers is that UAD 3.6 will dramatically increase the time required to complete a report, with some estimating three times the workload. The panelists acknowledged the concern, but the actual numbers from the field tell a more specific story.

Lumadu’s first report took roughly four and a half to five hours. By his tenth and eleventh, he was completing single-family assignments in about an hour and a half. Multifamily properties still take longer. His most recent two-unit report ran four to five hours, and a four-unit report took close to a full day. Stafford’s first report took two days. “Every time I got frustrated, I had to walk away for a while,” he said. His second took about a day. Both appraisers said the breakthrough came around the fifth or sixth assignment. “Once I got to like that six or seven range, it was a little bit better,” Lumadu said.

A lot of that front-end time involves manual data entry. Without MLS import, comp data, or automated field population, appraisers are typing everything by hand. “Right now, you have to mainly enter everything,” Lumadu said. “It’s tedious. I mean, it is tedious.” Stafford added that using his software’s inspection app at the property took him “twice as long as it normally would” because the tools were not yet fully functional. The appraisers agreed that once integration and automation tools are in place, the time gap should narrow. “My theory is once we get over this initial hurdle and the software companies are able to bring out their full suite of tools they have planned, it’s not going to take us that much longer to complete a 3.6,” Stafford said, “and it’s going to feel a lot more natural once you get the hang of it.”

Fees are harder to assess. The panel was candid but cautious, noting the antitrust implications of appraisers collectively discussing pricing. What emerged was a picture of uneven compensation. Winstead said he now charges a narrative fee for 3.6 work and has made that clear to clients going forward. “They’re different reports now, so you need to be compensated for your time,” he said. Stafford was able to negotiate double his standard fee for his first assignments, though he acknowledged that the arrangement was based on a longstanding client relationship. Lumadu, who works for an AMC, said he received the same fee split on all 11 of his 3.6 assignments as he does on legacy reports. “Fees are above mine right now,” he said. “I just get fee splits.”

The fee picture is likely to remain uneven as the rollout progresses. Independent appraisers with direct client relationships have more leverage to charge for the additional work. AMC-dependent appraisers may not, at least until volume increases and 3.6 becomes the default rather than the exception.

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Software and Transition
The technology is not where it needs to be yet, and the appraisers on the panel said so directly.

The core challenge? Software vendors supporting UAD 3.6 have had to build almost entirely new systems. The older appraisal platforms were built around static forms that stayed the same year after year. A report that grows, shrinks, and reveals new sections based on what the appraiser enters requires a completely different technical foundation. Most companies spent a couple of years just getting that core functionality stable enough for appraisers to complete reports at all, even if it meant doing a lot of the work manually. The more advanced pieces, from integrations to automations and quality of life tools that smooth out the workflow, are still in progress.

In the meantime, appraisers are doing everything by hand. Lumadu completed all 11 of his assignments using paper sketches, a laser measuring device, and his iPhone for photos because there was no specific mobile data-collection app and no automated comp imports. He described it as the fastest approach available right now. Stafford, who tested multiple platforms, found that the inspection tools added time rather than saving it. Both said the biggest single improvement vendors could deliver right now is MLS data import, which would eliminate the most time-consuming manual step in the current workflow.

One point the panel made clearly: mobile is not required. Despite widespread talk about the need to “go mobile” for 3.6, the appraisers who have actually completed assignments confirmed that traditional data-collection methods work. The only new data points they needed to capture at the property were front door height and ceiling height. Everything else was the same information they had always collected. The difference is in how that information is reported, not in how it is gathered.

Where It Stands
The appraisers who have completed 3.6 assignments are broadly positive about the format. “The software companies surely are stepping up, and we can enter this brave new world,” Vestal said at the end of the panel discussion.

But it is worth remembering that these are early adopters, practitioners who chose to go first, in most cases because they wanted to. The broader profession, much of which has not yet touched the new report, is watching from a distance with real concerns about how much longer the work will take and whether compensation will reflect that.

The time data from the first wave is encouraging but limited. Lumadu’s progression from five hours to ninety minutes over 11 assignments suggests a manageable learning curve for appraisers who can dedicate the time to it. But most appraisers are still running legacy 1004 orders alongside the transition, and few have the volume of 3.6 work needed to build that fluency.

The fee picture is even less resolved. Independent appraisers with direct client relationships may be able to charge a narrative fee. AMC dependent appraisers (who make up most of the profession) have less leverage to negotiate, and the early data suggests they are absorbing the additional work at the same rate of pay. What this means in practice is that the economic adjustment lags behind the technical one. Until lenders, AMCs, and regulators settle on a clearer framework for valuing the added labor, appraisers are likely to experience a period where expectations rise faster than fees.

Full mandatory adoption of all GSE-bound appraisals takes effect on November 2, 2026. The format may be an improvement, but the tools are not ready, the fees have not adjusted, and most of the profession has not yet written its first report. Time will tell.

About the Author
Isaac Peck is the Publisher of Working RE magazine and the President of OREP Insurance, a leading provider of E&O insurance for real estate professionals. OREP serves over 10,000 appraisers with comprehensive E&O coverage, competitive rates, and 14 hours of CE at no charge for OREP Members (CE not approved in IL and AK). Visit OREP.org to learn more. Reach Isaac at isaac@orep.org or (888) 347-5273. CA License #4116465.