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UAD 3.6: Inside the Struggle Over Fees, Turn-Time and Software
by Frank Andorka, Managing Editor
Editor’s Note: Since this article was written, the GSEs created an exception to UAD 3.6 implementation for sellers who aren’t able to make the full transition to the new standard before Nov. 2. The exception runs through May 19, 2027. The GSEs will also allow resubmissions of UAD 2.6 appraisal reports through June 27, 2027. As of March 1, 2027, UAD 2.6 appraisals will no longer qualify for certain appraisal-related representations and warranties relief. For more, check out our full report at workingre.com
Nov. 2 is usually just another day on the calendar — but not this year.
That date is when UAD 3.6, the latest reporting “innovation” mandated by Fannie Mae and Freddie Mac (the GSEs), becomes the only way to file an appraisal report with those organizations — and its rocky implementation has been enough to give appraisers a bad case of heartburn.
Appraisers are being thrust into a whole new world. The new report has more than five times as many data fields, fundamentally changes how appraisers work and creates new questions around liability. It also arguably takes more time, depending on who you ask.
The new report also requires new software, which may increase costs given the substantial development expenses providers have just incurred to meet the new requirements. All this raises the specter of higher fees and sets the appraiser up for a struggle with their appraisal management company (AMC) and lender clients.
Timeline and Rollout
The rollout of UAD 3.6 has been hampered considerably by two problems: slow software rollouts and lenders dragging their feet. When Working RE covered Valuation Expo in Las Vegas at the end of August, the problems clearly came into view.
While most of the leading software providers received initial approval from the GSEs in late 2025 and early 2026, word on the ground at Valuation Expo (Val Expo) was that there were still plenty of bugs to work out. AMC executives privately shared that they had staff simultaneously testing all the GSE-approved reporting software so they could troubleshoot and support appraisers when they inevitably ran into problems trying to turn in assignments. Some of those bugs were being run back to the software companies in real time, with the appraiser, AMC, lender and software provider working through the problem together.
“All the software providers are in a state of development flux and bug chasing,” says Bruce Ford, a certified appraiser with NorCal Quality Appraisal in Rohnert Park, California. “I am still trying to decide what software providers are going to provide best-in-class software.”
The GSEs tested the major software providers on several different types of assignments, but there are so many nuances, data fields and report settings in the new format that bugs surfaced rapidly once appraisers began doing live work.
“I’ve taken one eight-hour class on UAD 3.6 but have had no orders for the new form yet,” Ford says. “This rollout is vastly different [from the rollout of 2.6], and the rocky road to success is still to be paved.”
The bigger problem in August was that lenders had barely begun ordering the 3.6 appraisals at all. Rocket Mortgage staff at Val Expo said they had ordered six UAD 3.6 appraisals. Rocket originates roughly six to seven percent of all residential mortgages in the United States. Several regional AMCs reported completing exactly two assignments apiece — and in each case, one of the two was a test run the AMC had ordered itself.
Scott Reuter, chief appraiser at Freddie Mac, summed up the bind on a panel at the show: “Appraisers cannot do a 3.6 assignment unless somebody orders a 3.6 assignment.”
Working RE also heard rumors software providers are planning to bump up their annual rates to compensate for the development of compatible software. However, at press time none of the larger software players have indicated any material change in pricing.
Even though many software providers are approved by the GSEs, appraisers are reportedly running into errors throughout the process.
“It’s 100 percent throwing sand in the gears that there’s not a singular approved software right now for appraisers to rely on,” says Josh Tucker, appraisal manager for Interbank in Oklahoma City, Oklahoma. “It was funny: I ordered a 3.6 report and got it three days late and couldn’t export it — right now, there are a lot of lenders who might come screeching to a halt on Nov. 2.”
All of this sets up GSEs and the lending community to blame appraisers if the UAD 3.6 rollout fails. They shouldn’t. After all, appraisers didn’t design the software and can’t order their own UAD 3.6 appraisals. If no one is using them, why should appraisers shoulder the blame?
More Than 900 Data Elements
There were approximately 190 data elements in UAD 2.6. There are now more than 900 in UAD 3.6. Reuter says it’s easy to be overwhelmed if appraisers just hear the number, but he assures the industry that appraisers were in the room when the form was developed.
“I want to make sure they don’t just hear ‘more than 900 elements’ and worry that they won’t be able to do it,” Reuter says. “They won’t have to fill out all those data points for every property. They are never going to touch the lion’s share of them, but we wanted to make sure we accounted for every potential contingency just in case.”
Lyle Radke, senior director of collateral policy at Fannie Mae, says Fannie and Freddie hold, between the two of them, $7 trillion in mortgage debt which, since it’s backed by the U.S. Treasury, is guaranteed by U.S. taxpayers. Therefore, it stands to reason collecting more data than before is important.
“From that perspective, the data is essential,” Radke says. “It’s how we manage risk. UAD 3.6 makes it easier for us to see and understand the data. If we didn’t have 3.6, we could still parse the data, but it would be much more challenging and time consuming.”
Radke says the new report will open opportunities for appraisers to work more collaboratively with lenders and AMCs instead of being forced into a silo.
“Right now, when an appraiser signs a report, they’re certifying that they’re accountable for everything,” Radke says. “There’s no means of collaboration. The new report allows flexibility that the current report doesn’t – opening the door to a more collaborative environment.”
What About Appraisal Fees?
Then there’s the question of what UAD 3.6 means for appraisers. Working RE talked to a senior AMC executive at Val Expo who indicated they are “trying to hold the line on fees.” The executive explained that the staff appraisers at their AMC had worked with UAD 3.6 long enough to become proficient and could now complete a UAD 3.6 appraisal in the same time as a traditional one. Even though they were trying to hold the line, the executive conceded appraisal fees have increased 10 percent so far.
Then there is Solidifi, an AMC based in Buffalo, New York. It sent out an email to several of their appraisers with the following statement (Working RE has reviewed a copy of the email provided by an appraiser):
We understand that UAD 3.6 may require additional time as appraisers become familiar with the new workflow. However, our clients evaluate fee requests based primarily on property and assignment-specific complexities. While there is a learning curve, completing 3.6 assignments now allows appraisers to gain experience gradually, improve efficiency and be better positioned to handle increased 3.6 volume as industry adoption expands. Based on the information provided, we do not currently have sufficient support of a fee increase above the standard for this assignment. If you would like to provide any additional complexities, we can send this off to the client.
Donna Halfpenny, owner and certified real estate appraiser of Halfpenny Appraisal Services in Riverside, Illinois, responded to Solidifi’s email on LinkedIn (lightly edited for clarity):
Hey, Solidifi! Yes, you.
What are you all doing over there? Do you not comprehend all that is involved in UAD 3.6? Certainly, you cannot, since you have sent [this email] out to your appraisers. The new appraisal form takes much more time, more research, more than 150 new data points, increased software fees and increased liability.
Lenders: This is how the company that represents you treats appraisers. How do you think regulators and states may feel? You know, you are required to oversee your third-party AMCs.
Back to you, Solidifi: I hope you realize you are proving why so many appraisers refuse to work with you. You would think you’d want the best appraisers to serve your clients. Yet you prove otherwise. Your motto seems to be ‘cheap and fast, no concern for quality.’
After that email, hip boots are needed. I was called ‘difficult.’ I am not being difficult. I am calling out issues because I truly care about the consumers and real estate professionals. Transparency needs to be prioritized.
And I dare you to send me a letter for calling you out like you did to another appraiser.
Sincerely, Donna Halfpenny
Halfpenny’s LinkedIn post captures the struggle that is materializing between many boots-on-the-ground appraisers and AMCs who are attempting to “hold the line” on fees. Appraisers are clearly saying: UAD 3.6 reports take longer to complete. Therefore, they should command higher fees.
Some AMCs are saying: Well, just practice more.
Not all AMCs are taking this approach, however. Working RE spoke to several regional AMCs at Val Expo that indicated they are taking more of a wait-and-see approach on appraisal fees.
“We need to wait for the market to determine the fees. Appraisers are going to tell us what their fees are,” one AMC executive told Working RE. “We do expect appraisers to get more acclimated and learn to do UAD 3.6 appraisals faster, but it’s too early to try to take a one-size-fits-all on appraisal fees for this new report.”
In a survey of 831 appraisers run by Corporate Settlement Solutions earlier this year who answered about fees, 66.7 percent expect to have to increase their fees. Of the 214 appraisers who had performed UAD 3.6 reports, that number jumped to 82.2 percent. Clearly, there will be some intense discussions about fee levels between AMCs and appraisers as UAD 3.6 becomes mandatory.
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Appraisal Turn Times
Pat Turner, owner and certified appraiser of P.E. Turner & Co. in Manakin Sabot, Virginia, worries about what UAD 3.6 will do to appraisal turn times. He argues UAD 3.6 is part of a long-term goal of the two GSEs.
“Freddie Mac and Fannie Mae have been trying to put appraisers out of business for the past 50 years,” Turner says. “They say we need to modernize and streamline the appraisal process. We have gone from a roughly 15-page report to a 41-page report. How does that speed things up or streamline anything?”
Turner argues that the expanded report will inevitably lengthen the turnaround times for appraisers. In the end, consumers will bear the burden of having a UAD 3.6 appraisal.
“It costs too much for the amount of time it takes to do one,” Turner says. “It’s insanity. I have a colleague who has been an appraiser for 30 years. It took her four hours inside the house to use this new form. No one is ready for this: not the lenders, not the underwriters — no one.”
Josh Tucker concurs with Turner.
“There’s no way this is going to be done without extending turn times for appraisers,” Tucker says. “We’re still entering everything manually, but the inspection apps aren’t working properly in conjunction with 3.6. There’s no way we can do this without raising fees.”
Desiree Mehbod, a certified real estate appraiser at eAppraiser Co. LLC in Reston, Virginia, says she’s confident her turn times won’t change — because she’s just not using it.
“The new system is built in a way that creates unnecessary alerts, adds extra workload for appraisers, shifts more liability on to us and moves the profession in the wrong direction,” Mehbod says. “I’m not planning on doing UAD 3.6. Because of that, my turn times haven’t changed at all.”
Kelly Cahill, owner of Speedwell Appraisal Services in Middleton, New York, says she completed her first UAD 3.6 report in August. She says maybe it won’t delay things on the appraisers’ end as much as everyone fears.
“My first order did take a bit longer because I was getting used to where all the data is,” Cahill says. “It’s a completely different format to get used to. However, I can see how this will be a total game changer. Ultimately, my reports will be done quicker once I get used to the format. My completion and delivery to the client was actually very smooth.”
Cahill says she now has four UAD 3.6 orders on her desk, which is almost half her workload in an average week. She believes the Nov. 2 deadline isn’t unreasonable if appraisers take the time to get used to the format.
The same Corporate Settlement Solutions survey mentioned earlier found that 78.3 percent expect an extended turnaround time among the 816 appraisers who answered the question. The number barely diminished among those who had actually completed at least one UAD 3.6 appraisal. Of the 214 appraisers who have completed at least one report, 75.7 percent still expect longer turnaround times.
How Does the Liability Shift?
Brad Bassi, an appraiser and designated member of the Appraisal Institute, says appraisers should be concerned about how UAD 3.6 will shift more liability onto their shoulders.
“The problem is appraisers are being asked to report on things, like volume of windows and above-grade measurements, where they don’t have the market data to make an adjustment,” Bassi says. “They don’t have the volume of windows or the above-grade information of the comparables, so they are collecting and reporting on these things but don’t have enough information to analyze it. It’s going to leave them exposed.”
Isaac Peck, president at OREP Insurance, says one potential issue facing appraisers with the shift to UAD 3.6 is what their liability insurance will cover should they make a mistake with one of those ‘more than 900’ data points.
“First of all, part of our take here is ‘more data, more problems,'” Peck says. “There are now hundreds of additional data fields that appraisers are responsible for reporting on, so just by that metric alone, there is an increased risk of one of those fields being incorrect. It just increases the canvas upon which an appraiser might misreport something.”
Peck says the good news for appraisers, from a liability standpoint, is that the new report includes the following language in both Certifications 25 and 26: “The appraiser and supervisory appraiser (if applicable) shall have no liability for any use of this appraisal report not related to the mortgage finance transaction and related activities for which this appraisal report was prepared.”
Seeing this language appear twice, in two separate certifications, is a clear win for appraisers, Peck says.
“To have Fannie and Freddie explicitly add this liability language to the certifications is a big victory for appraisers,” Peck says. “It helps counterbalance some of the other changes they’ve made with UAD 3.6.”
Second, many of the additional data fields appraisers must report are also potentially problematic.
“I agree with Brad Bassi and the comments he’s made around volume of windows and the above-grade measurements, but I also think that the condition reporting on things like foundation, roof, kitchen and bathrooms is also going to create some misunderstandings among consumers,” Peck says. “For example, an appraiser might mark a roof ‘new’ or ‘like new’ and then six months after moving in, the roof might start leaking. It would be easy for a borrower to misunderstand the purpose of the appraisal and try to bring a claim against the appraiser.”
Are many of the new data fields, like commentary on the condition of the roof and foundation and even the presence of “Accessibility Features for Individuals with Disabilities,” going to create confusion and increase demand letters and even lawsuits from borrowers?
“Probably, but not in a super material or radical way,” Peck says. “At least that’s the view we have right now.”
The Bottom Line
Whatever appraisers think about UAD 3.6, it’s coming Nov. 2. Joel Baker, senior product professional at a la mode technologies in Oklahoma City, Oklahoma, says it doesn’t pay to do anything but prepare.
“The biggest misconception is that this is the end of the world,” Baker says. “A lot of appraisers have tied workflow to sense of self, so it’s difficult to internally challenge the process.”
John Dingeman, chief appraiser at Class Valuation, says change is inevitable, so embrace it.
“I’m taken aback by appraisers who say they still want to use their tape and pen sketch,” Dingeman says. “There’s a real opportunity for appraisers to move to paperless filing and digital sketching. UAD 3.6 doesn’t eliminate those skills: It just enhances them.”
As the industry rushes toward the Nov. 2 deadline, appraisers’ stress levels will continue to rise. The only question is: What will things look like when the smoke clears? Only time will tell.
About the Author
Frank Andorka is the Managing Editor of Working RE magazine, published by OREP Insurance, a leading provider of E&O insurance for appraisers nationwide. Andorka has more than two decades of experience as a writer and editor and is based out of Cleveland, Ohio.