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> The Appraiser Coach ★★★★★ |
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.
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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. 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 the last 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.