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Nobody is Ready for UAD 3.6
by Isaac Peck, Publisher
I just got back from Valuation Expo, the nation’s largest and most dynamic conference for real estate appraisers and valuation industry stakeholders. More than 800 people made it to Las Vegas this year.
Appraisers, chief appraisers at appraisal management companies (AMCs), lenders, regulators, software developers, service providers, insurance professionals and more convened to talk about the latest technology and explore where the profession is headed.
The mood was elevated and positive—many attendees were genuinely invigorated and excited about the future. And yet, despite all the positivity, another reality was plainly clear from the conversations: Nobody is ready for UAD 3.6.
While many of the leading software providers received initial approval from Fannie Mae and Freddie Mac (the GSEs) in late 2025 and early 2026, word on the ground is that there are still plenty of bugs to work out.
AMC executives privately shared that they have staff simultaneously testing all the GSE-approved appraisal reporting software so they can troubleshoot and support appraisers when they inevitably run into bugs and errors trying to turn in an assignment. Some of those bugs are being run back to the software companies in real time, as appraisers, AMCs, lenders and software providers work together to find a solution.
In other words, while the GSEs tested the main appraisal report software providers on several different types of assignments, there are so many nuances, data fields and report settings that bugs are surfacing rapidly now that appraisers are finally doing live assignments.
In addition to the software challenges, part of the problem is that most lenders haven’t begun ordering UAD 3.6 reports at all.
I spoke with several regional AMCs. Each had completed just two UAD 3.6 assignments—and in each case, one of the two was a test run the AMC had ordered itself.
When asked how UAD 3.6 was going at Val Expo, several Rocket Mortgage staff said they had ordered only six appraisals so far in the new format. Given that Rocket Mortgage originates roughly six percent to seven percent of all residential mortgages in the United States, their readiness two months out is indicative of industry readiness at large.
If one of the largest mortgage lenders in the country has only done six UAD assignments, how many appraisers have actually completed a UAD 3.6 assignment? The answer is very, very few.
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Scott Reuter, chief appraiser at Freddie Mac, summed up the bind on a Val Expo panel: “Appraisers cannot do a 3.6 assignment unless somebody orders a 3.6 assignment.”
With many reporting software providers still scrambling, some of the largest lenders just barely getting adjusted, and with many AMCs working through their first UAD 3.6 order, it’s fair to wonder how this transition is going to go.
Those with the most pessimistic view are predicting that mortgage markets may grind to a halt on Nov. 2 due to the general lack of readiness across the software, AMC and lender sides.
Meanwhile, Fannie Mae and Freddie Mac are predicting mass adoption will take place in September and are indicating confidently that there will be no extension of the Nov. 2 compliance date.
Deadline Reality
The Nov. 2 deadline is keyed to the date an appraisal is submitted to the Uniform Collateral Data Portal (UCDP)—not the date the loan application was taken, not the effective date of the appraisal and not the date the appraiser delivered it. If a UAD 2.6 report reaches UCDP on or after Nov. 2, the portal will return a fatal error, and the submission will come back “Not Successful.”
Nov. 2 falls on a Monday, which makes Friday, Oct. 30, the last business day to get a 2.6 report into the portal. Working backward from there, the practical deadline moves up considerably. An appraisal assignment ordered in mid-October still must be scheduled, visited by the appraiser, written up, submitted to the AMC, reviewed by the AMC, delivered to the lender and submitted to UCDP—all before Oct. 30. A 2.6 assignment ordered on Oct. 15 and delivered Nov. 3 isn’t a late file. It’s a rejected one.
That is why lenders intending to run 2.6 to the wire need to be off it by roughly the second or third week of October, and why appraisers should expect the ordering mix to shift sharply over the next several weeks, whether their clients have said anything yet or not.
The GSEs have already started the countdown, though appraisers won’t see it directly. Under a schedule published in June, every UAD 2.6 submission this month and beyond will return a Warning message in the Proprietary Edit Findings section of the Submission Summary Report, reminding the submitter to transition. Lenders see these in UCDP; appraisers generally don’t. On Nov. 2, the Warning becomes Fatal: Rejected.
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Appraiser Risk?
For appraisers, one risk in all this is that the industry’s lack of readiness becomes the appraiser’s problem. When a report won’t transmit, when a field won’t populate, when a revision request comes back three times because the AMC’s system can’t read the file correctly—it is the appraiser who eats the turn-time and, often, the fee.
An appraisal software executive shared with me privately that he fears appraisers may be (wrongly) blamed if the rollout goes poorly and the market is disrupted. It would be easy to sell a narrative that “appraisers weren’t ready,” or that appraisers can’t handle the new report format. Such a view clearly misses the point. After all, appraisers don’t control the development of the software, nor do they control when UAD 3.6 reports start getting ordered, to Reuter’s point.
The practical takeaway for the boots-on-the-ground appraiser: The next 30 days are a crucial window to practice with UAD 3.6 assignments, find a software vendor that will actually work with you and revisit whether your current fees reflect what a 3.6 report actually takes—at least if you wanted to do that before the report format is mandatory.
Will we see an avalanche of UAD 3.6 orders in September and October, and will the transition happen smoothly by mid-October? It seems unlikely.
This is a developing story. Check back at WorkingRE.com for the latest.
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 or AK). Visit OREP.org to learn more. Reach Isaac at isaac@orep.org or (888) 347-5273. CA License #4116465.
by Richard Pinto
40 years appraising and do not want to spend my time or money learning anymore. Changes to are profession are constant and confusing. Some buriocrat decides they need an 1004MC ,then its not needed a few months later….but half the lenders still need it. Appraisers have never been given any respect and always take the brunt of the consequences when things go south. I’ve had enough bullying in my 40 years as an Appraiser and can bearly make a living since the Pandemic. I wiil quietly retire when UAD 3.6 is implemented and I wish I had chosen a career path where I was valued as a professional and not just as a scapegoat.
-by Paul W. McDaniel
I have completed many UAD reports, however, most of my work is for private clients who want old 1004’s or GPAR report. At this late point in my career I have no intention of or need to go to 3.6. I’m grateful for that.
-by Jim Anderson
I’m totally ready for UAD 3.6! I’ve completely transitioned to private work.
Problem solved!
-by Patricia Lucas
Good for you; do you have many clients/staying busy? I’d like to go that route myself not sure how to transition. Any advice?
-by Kevin kelly
I’ve been watching this for over a year now and now it’s finally here. UAD 3.6. I’ve taken courses, watched anemic educational videos from software providers promising that this is going to be so much easier and better in the long run. No more form filling. Hey, I’m ok with form filling. I’ve streamlined my workflow utilizing AI to produce a rock solid appraisal report. I don’t need a new one size fits all report, new software, endless educational classes, hardware updates, guaranteed software bugs and dealing with lousy customer support about why my file won’t transmit because it’s too big or why my photos won’t upload properly. I’m not raising my fees, I’m just refusing to participate. It’s a huge headache and waste of time. So this is a signal to me to transition to more private work, do FHA and VA work until they join the rest of the lunatics out there that think this is a good idea. In about a year or so, I plan to retire after 35 years as a residential appraiser in CT. It makes no sense to me to be part of this 20 car pile up.
-by Brad Bassi
Isaac great seeing you at the conference. I got the same vibe. Although my work is private party. I went for the express purpose of seeing who has a general-purpose form that has AI tied to it. Answer, not many. But along with that I kept hearing the issues over ordering, acceptance by appraiser and delivering. The person that commented the appraiser will get blamed is pretty close to right on. Seems like it was the appraisers’ fault for all the bad credit structure in 2005,2006,2007 and 2008. See a similar theme again. But I trust the residential appraiser will survive but they will be losing their minds along the way. But like always they will figure it out. Hope all is well and that you made it back home safe and sound. I came back with an ugly head cold. Be well.
-by David
If the object was (and still is) to get appraisers out of the industry, the whole idea of the moves the government and the GSEs have made over the past two decades makes complete sense. Look at each problem (which they caused) and their solutions (which aren’t solutions at all) and then ask yourself, “Why?” Call me a conspiracy theorist, but I see agendas being implemented over time, not quickly mind you, that cause things to happen in sequence towards an end result. The bad thing is, the bureaucracy responsible has built-in plausible deniability for anyone involved. Each appraiser I speak with thinks this the UAD 3.6 is a complete cluster f*** and will cause more problems than give any solutions, even when “running smoothly.” The appraiser is merely the scapegoat and will be blamed for the issues they have cause to happen in the first place. It’s so easy to blame a silent minority for any problems, so the answer is, “just get rid of them.” Watch out for the knife coming after the pat on the back with the reassurance that the appraisers aren’t going anywhere. Aren’t going anywhere? Right. The government and their programs are not the solution for anything. How many millions of dollars has been spent on UAD 3.6 over how many years? Fannie and Freddie never were able to become more efficient themselves and we watched Fannie Mae effectively go bankrupt more than once, yet are somehow relied upon to solve issues to this day. If you think this argument is all hokum, look at the way they hijacked common language in appraisals so that one cannot state the word “good” or “average.” I see this as a form of fascism and if you don’t see it, please read more history. Everything they do is about control, not autonomy, not liberty, not freedom. Their regulations inhibit innovation and increase costs for everyone. Government needs to find solutions from outside of itself, not inside. Of course, this would mean a few folks might lose their jobs and we simply can’t have that, can we? If you are worried about the appraisal fees for the 3.6 appraisals, start with a base of one thousand dollars per 3.6 appraisal, otherwise, you may rightly go out of business. Think about it.
-by P. Bergman
Thank you for your reply-as a residential appraiser of 30 years I see the same past mistakes and dire warning of the future of residential real estate appraisal-all in the hands of big government and their “GSE” counterparts-All of the changes to UAD and now to the 3.6 for is all about the appraiser on the ground doing the research into the housing stock in the United States so they can sell it to AI— or as I refer to it as the “eye in the sky”…then what happens to the information? Appraisers use their knowledge of local markets and experience to produce an appraisal report. An appraisal report represents INTELLECTUAL PROPERTY-not just raw data. Appraisers need to stand up for our profession-mortgage brokers only care about the next closed closed “deal”. They don’t care about what is in an appraisal except the “number”, and will not be happy when appraisals take more time and cost more money.
-by James John Meyer
Government creates the crisis so it can provide the remedy. The government and the GSE have been destroying the appraisal practice for decades. I mostly do VA appraisals and our region saw a revised fee schedule on 05/01/2026. The fees for all VA appraisers are set by VA in Wisconsin at $650 so I don’t think they will allow VA appraisers to raise their fee for 3.6 appraisals or revise the VA fee schedule for 3.6..I won’t being 3.6 for many reasons.
-by Gary Belt
You mean Ai can’t just swoop in and wave its magic wand and fix everything with the software providers, AMC’s, lenders and appraisers regarding UAD 3.6?!? Color me shocked! I think this may be the proof that 30 minute appraisals slopped together with Ai isn’t the answer this industry needs. Imagine if AMC’s, reviewers, lenders, etc actually read appraisal reports after they came out of CU (no, using keyword searches is NOT the same as reading) and assignments weren’t given out to the lowest bidders and they weren’t reading page after page of “Extra Comments” that clearly indicate the author cannot defend their value or adjustments. I guess that would just make too much sense, so let’s force this awful “fix” on the industry.
-by Rob
I think the biggest hurdle will be agreeing on fees for the 3.6 appraisals. I already turn down a lot of lending work due to low fees. If the fees aren’t acceptable, appraisers should not be accepting 3.6 orders. I know I won’t do a 3.6 for the same fee as a legacy appraisal. None of the lenders I work with have even discussed fees yet. For once appraisers have some leverage over lenders. All appraisers in all markets need to be increasing fees across the board for 3.6 assignments. These opportunities rarely ever come around. We need to take advantage of this one.
-by David John Simonetti
I have told other appraisers, different AMC’s that all appraisers should be doubling ALL their fees whenever 3.6 goes into effect since scope of work creep has been happening for years. The AMC’s/lenders will choke on the bad news and try to get rid of the boots on the ground through AI or robots.
-by Patricia Lucas
Agreed
-by Patricia Wright
I find this so problematic and an example when big government gets involved in businesses that they know nothing about except to check boxes and no idea what the boxes mean. Really- what does the ceiling height of rooms, or distance from the ground to front door, or if an EV hookup is in the house, or if broadband is available have anything to do with trying to determine market value of a home. The appraiser’s research is based on MLS listings and data from realtors, and realtors will NOT be entering this data and so what is the point? If we don’t know about these features in a house that sold, how can appraisers determine if any of this is a factor for that buyer and his offer to purchase? This whole rollout is a waste of time and money, and the end result of it all is that this stuff should be in the seller’s property disclosure and not on the appraiser to be a home inspector. I am beyond understanding on who is responsible for this fiasco? No one to date has explained the benefits to the new data requirements put on the appraiser. If it was just a matter of redoing the forms to make data entered for appraiser’s easier, well, they have missed the mark, and the new requirements are just nothing to do with market values. GEEZ. If I was building a house, I could price these elements with a licensed contractor to give me a cost to build with certain features, but for market data from buyers> NO-O-O-O . I will not even try to do an appraisal from October on, until someone has this mess straightened out. Don’t the powers-to-be know that realtors don’t even know the difference in a built-in garage to an attached garage, or how to report finished SF. There are currently realtors entering data as 1 SF finished for an attic or basement, and when I have call to find out how can a basement have a 1 SF finished, they answer was – didn’t know if the finished SF met with ceiling height requirements, and the software would not let them enter the data, but the 1 sf entered was to recognize that was some finished SF. In the world moving to AI, it is going to be just plain troublesome and forget doing market analysis to determine an opinion of value based on data from MLS.
-by Doug
How many fewer appraisers will there be? Many will just retire or like one I know find other work. In some rural areas this will really sting!!
-by Todd Redington
I am rural area….. Ordered a case of calamine lotion last month….. and maybe a couple of bottles of other anti-sting medication ;-)
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