Why Appraisers and Lenders Should Start Using the New UAD Forms Now

The last thing you need is for a deal to get delayed because the UAD 3.6 form is required after an appraisal revision.

The appraisal industry is approaching a major transition, and November 2 is the date every lender, appraisal management company, and appraiser working on applicable assignments needs to understand. On September 30, Fannie Mae and Freddie Mac changed what that date means for some lenders. They did not change where the industry is headed.

The transition to UAD 3.6 is not simply a new form to learn when the deadline arrives. It affects how appraisals are ordered, completed, delivered, stored, and revised. Waiting until the last minute to adopt this form could create problems that show up after the original appraisal is finished.

What changed on September 30

In Lender Letter LL-2026-08, Fannie Mae announced a one-time, temporary policy exception for lenders that cannot finish their UAD 3.6 implementation by November 2. Freddie Mac is offering the same exception. Both were issued in coordination with FHFA.

The mandate itself has not moved. Lenders that are ready on November 2 move to UAD 3.6 and need to do nothing further.

Lenders that are not ready must ask for more time. The exception is not automatic. Approved sellers must request it separately from each GSE they sell to. Lenders that do not sell directly to the GSEs do not request it themselves, but they need to align their plans with their investors or aggregators. The GSEs have also been clear that the exception will not be extended.

Asking for more time comes with conditions. The request must come from someone authorized to sign binding contracts. The lender must accept revised contractual terms and commit to a final implementation plan, including coordination with its vendors and appraisers. The exception is a commitment, not a pass.

The new timeline for excepted lenders

For lenders granted an exception, the move away from UAD 2.6 happens in four stages:

• November 2, 2026 to February 28, 2027: Both UAD 2.6 and UAD 3.6 reports are accepted through UCDP.

• March 1 to May 19, 2027: Both formats are still accepted, but 2.6 reports move into reduced functionality. They receive the highest collateral risk score (999 from Fannie Mae, 99 from Freddie Mac), and loans delivered on a 2.6 appraisal lose certain appraisal-related rep and warrant relief.

• May 20 to June 27, 2027: All new submissions must be UAD 3.6. A 2.6 report is accepted only as a resubmission of a report already on file.

• June 28, 2027: Support for UAD 2.6 ends for good.

The GSEs are strongly encouraging lenders to finish their UAD 3.6 implementation before March 1, even if they receive the exception.

The risk most people are missing

An appraisal may be completed on an old form before November 2. That does not necessarily mean the file is safe from the transition. The exception makes this risk harder to see, not easier.

Imagine this. An appraisal is completed in October on UAD 2.6. The loan takes longer than expected to close, or the underwriter requests a revision in late November. Whether that revision is simple now depends on the lender. If the lender holds an exception, the 2.6 report can be revised and resubmitted. If the lender does not, the old form may no longer be accepted, and the lender or client may need to order a new appraisal using the new form.

Now push the timeline out. A 2.6 report revised after March 1 carries a top risk score and loses rep and warrant relief. A 2.6 report that needs a revision after June 27, 2027 has no path forward on the old form at all.

That means more time. More cost. More work for everyone involved.

Revisions do not always happen immediately. A report may be reviewed weeks or months after completion, especially when a loan takes time to move through underwriting or sale. The form used today can affect what happens later.

Who is affected?

The UAD 3.6 transition applies to applicable residential loans sold to Fannie Mae and Freddie Mac. It does not apply in the same way to every assignment. FHA, VA, non-QM, and commercial work are not governed by this specific requirement.

Within that group, exception status now matters. Two lenders can order the same assignment in December and need different forms. The answer depends on whether each lender requested and received an exception.

That distinction matters. The goal is not to create unnecessary urgency around every appraisal. The goal is to make sure the right people understand where the deadline applies and what it means for their files.

Why waiting creates unnecessary risk

The exception buys time. It does not buy a better position. A lender that waits trades a November deadline for a March penalty, and the work still has to be done.

The new forms may be easier to use than they first appear, but the first assignment can still expose issues in a company's process.

Can the ordering platform select the correct form? Can the appraiser's software generate the report properly? Can the client receive it? Can the system store it for the required retention period? Can the report be retrieved if a revision or audit is needed?

These are basic questions. They are also questions that should be answered before the deadline, not during a time-sensitive transaction.

Software readiness is still shifting, even this close to the deadline. Appraisers should confirm their vendor's UAD 3.6 plan now. Lenders and AMCs should ask before assigning work.

Appraiser adoption is another part of the transition. Experienced professionals have established routines, and changing those routines takes time. The first new-form assignment may feel clunky. After that, the process can become much more manageable. Early practice gives appraisers a chance to work through the learning curve before the new process becomes mandatory.

What should happen now?

Lenders should decide now whether they will request an exception, and then tell their AMCs and appraisers the answer. Exception status is no longer an internal detail. It determines which form every order should be placed on.

Lenders, AMCs, and appraisal firms should begin testing the new forms on applicable assignments. They should confirm their software and ordering platforms are ready, review how revisions will be handled, and communicate the change clearly to clients and internal teams.

Appraisers should complete a new-form assignment before the deadline whenever possible. That is the fastest way to identify questions about workflow, fees, turnaround time, and report delivery. Appraisers should also be ready to work in both formats well into 2027.

Clients should also ask two questions when ordering an appraisal: Does this lender hold an exception? Is this assignment being completed on the form that will remain acceptable if a revision is needed later?

Those questions can prevent a difficult conversation after the deadline.

How AAG is handling the transition

AAG is supporting both formats through the transition. We are confirming exception status with each of our clients so every order is placed on the right form from the start. We also expect a second wave of lender transitions before March 1, and we are building appraiser capacity in both formats to support it.

The practical takeaway

November 2 is not a date to circle and ignore until it arrives. It is a deadline that requires preparation. The exception changes the timeline for some lenders. It does not change the destination.

Start using the new forms. Test the technology. Confirm the storage process. Explain the revision risk. Give appraisers and clients time to adjust.

The goal is not simply to deliver a report. It is to deliver a defensible report that will continue to support the transaction when questions come up.

The right preparation protects the deal, protects the timeline, and protects your reputation.

Need help or have questions? Connect with us here to talk about your UAD 3.6 readiness.

Source: Fannie Mae Lender Letter LL-2026-08, September 30, 2026. Freddie Mac is applying the same terms.