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The short version: The deadline has not moved, but some lenders may qualify for a temporary exception.

What Happened

On September 30, Fannie Mae and Freddie Mac announced a temporary, one-time policy exception for lenders that cannot complete their UAD 3.6 implementation by the November 2, 2026, deadline. The mandate itself is not changing.

UAD 3.6 is the data standard behind the redesigned appraisal report. It replaces the familiar 1004, 1073, 1025, and related forms with a single, data-driven report.

How the Exception Works

• It belongs to the lender. Appraisers, AMCs, brokers, and agents do not request it.
• It is not automatic. Lenders must request the exception.
• It ends soon. Approved sellers can submit new UAD 2.6 reports from November 2, 2026, through May 19, 2027. Mandatory use of UAD 3.6 begins May 20, 2027.
• Waiting has a cost. Beginning March 1, CU returns a collateral risk score of 999 on UAD 2.6 reports, and those loans will not be eligible for collateral representation and warranty relief for value. Most lenders therefore have a strong incentive to switch early.
• There is no second extension. The exception will not be extended.

What It Means for You

Agents and loan officers: Your appraisal may come back in either format, depending on the lender. Some wholesale lenders will move to UAD 3.6 before or on November 2, while approved exception holders may continue accepting UAD 2.6 afterward. Ask your lender which format it requires.

Buyers and sellers: The way I value your home does not change. Only the way the data is packaged for the lender changes.

Not every loan type follows this timeline. The November 2 Fannie Mae and Freddie Mac mandate is not a universal deadline for every mortgage program. FHA, VA, and USDA have their own requirements.

My Approach

I am prepared to deliver either format during the transition, but as previously noted the 3.6 report represents an unprecedented change for the appraisal industry as a whole, so whether you are working with me or another appraiser expect higher fees and extended turn times, especially in the short term.  I am relieved that there is at least some softening of this deadline.  It still seems that no one is fully prepared, and a ramp up (which this approach seems to lend itself to more) certainly seems like the more sensible option rather than the previous approach.  And again, this only specifically applies to mortgage lending, so the current forms will continue to be fine for private work (divorce, estate, cash purchase, pre-listing, tax appeal).  Let's not get ahead of ourselves, but as appraisers become more comfortable with the new format, you may begin to see some adoption for private work too.    

Questions about serving your clients during the UAD 3.6 transition? I am always happy to talk. Call me at 404-245-7577.

Cameron Horne, GACR253993
Comp One Appraisal Services, Inc.