Mortgage brokers preparing for the Nov. 2 switch to UAD 3.6 just got some breathing room — depending on where they send the loan.
Fannie Mae and Freddie Mac are offering temporary policy exceptions to approved lenders that cannot meet the Nov. 2 mandate for the redesigned Uniform Appraisal Dataset, allowing those lenders to continue submitting legacy UAD 2.6 appraisals well into 2027.
But the mandate itself hasn't moved.
That could leave brokers navigating different appraisal requirements across their lender relationships: one wholesale lender could require UAD 3.6 before Nov. 2, another could make the switch on the deadline, and another could continue accepting UAD 2.6 after receiving an exception.
Nov. 2 Is Still The Deadline
The GSEs announced the exception Wednesday in coordination with the Federal Housing Finance Agency.
Fannie Mae's Lender Letter makes clear that lenders that successfully implement UAD 3.6 by Nov. 2 do not need to take any action.
Lenders that cannot meet the mandate, however, must request and receive an exception from each GSE to which they sell loans.
Under the exception, new UAD 2.6 appraisal reports can continue to be submitted through May 19, 2027. Beginning May 20, all new appraisal submissions must use UAD 3.6.
Legacy UAD 2.6 reports already in the pipeline can be resubmitted through June 27, with UAD 2.6 retiring completely June 28.
The Mortgage Bankers Association said it had been in “extensive engagement” with GSE leadership about implementation and welcomed the additional runway.
MBA President and CEO Bob Broeksmit said the exception should give lenders and appraisers additional preparation time while helping avoid “unnecessary disruptions, longer wait times, or higher costs for borrowers.”
The American Bankers Association had also pushed for more implementation time, warning that lender and appraiser systems were not universally ready to produce, transmit, and receive UAD 3.6 data.
What It Means For Brokers
The exception is aimed at Fannie- and Freddie-approved sellers, not individual brokers.
A lender that does not sell directly to the GSEs does not need to request its own exception. Instead, it must align its implementation with the investor or aggregator purchasing its loans.
For aggregators buying loans from third-party originators, the choice becomes more consequential. They must either ensure their TPO channels are submitting UAD 3.6 appraisals or obtain an exception and manage compliance across those originators.
That means brokers shouldn't assume every lender will handle the transition the same way.
Carrington Mortgage Services is one example.
The wholesale lender began rolling out UAD 3.6 to selected broker partners Oct. 1 and says all new applicable appraisal submissions must use UAD 3.6 beginning Oct. 15 — more than two weeks ahead of the GSE mandate.
Carrington said account executives will contact brokers with their individual rollout dates.
The staggered approach illustrates what the next several months could look like: UAD 2.6 and 3.6 operating alongside one another, with the applicable format depending partly on the lender receiving the loan.
Waiting Until May Comes With A Cost
The GSE exception isn't designed to make May 19 the industry's new UAD deadline.
Fannie and Freddie are encouraging lenders to complete their transitions sooner, and the economics of waiting become less attractive beginning March 1.
From Nov. 2 through Feb. 28, approved exception lenders can continue submitting UAD 2.6 reports with normal collateral-risk functionality.
Beginning March 1, however, Fannie Mae's Collateral Underwriter will return a risk score of 999 on UAD 2.6 reports submitted under the exception. Freddie Mac's Loan Collateral Advisor will return a score of 99.
Loans backed by those legacy reports also will not qualify for certain collateral representation-and-warranty relief for value.
Fannie is therefore “strongly encouraging” exception lenders to implement UAD 3.6 before March 1 to avoid potential effects on their businesses and processes.
Freddie's current UAD guidance carries a similarly direct message for lenders: start implementation now if they haven't already.
“It's going to take longer than you think to train staff, test, and fully transition,” Freddie warns.
Appraisers May Have To Support Both
The two-track transition doesn't stop with lenders.
Fannie has issued guidance for appraisers explaining that the lender exception does not change an appraiser's responsibility to adopt UAD 3.6. It can, however, affect which version a lender asks an appraiser to produce.
That could leave appraisers supporting both standards during the exception period depending on the client and assignment.
There's also a technical reason lenders and appraisal partners will need to know which standard applies at the beginning of a file.
The Uniform Collateral Data Portal does not permit UAD 2.6 and UAD 3.6 submissions to be mixed under the same Document File Identifier. If a report was originally submitted under UAD 2.6, subsequent submissions under that identifier must remain UAD 2.6, according to Freddie Mac's updated UCDP guidance.
Readiness Concerns Didn't Come Out Of Nowhere
The additional runway arrives after months of preparation — and warnings about what could happen if pieces of the appraisal ecosystem weren't ready at the same time.
NMP reported in June that delays in appraiser adoption could create appraisal bottlenecks and that lenders needed to review their vendors, workflows, and technology integrations ahead of Nov. 2.
More recently, NMP reported on Clear Capital's new appraisal-review workflow, which was designed to support both UAD 2.6 and UAD 3.6 while lenders had both formats moving through their pipelines.
The concern has now reached the policy level.
ABA said its members warned that moving forward without additional implementation time could create operational, market, and consumer risks. MBA similarly said the temporary exception should reduce the possibility of disruption, longer appraisal wait times, and higher borrower costs.
The appraisal software market is changing at the same time. ACI recently announced it will end access to the current version of its UAD 3.6-capable ACI Sky Workbench on Oct. 9 while it develops Workbench 2.0, which it expects to release in spring 2027.
The timing has sparked discussion among appraisers, but neither the GSEs nor ACI has publicly linked the software decision to the policy exception.
The Broker Play
For originators, none of this means learning how to build a UAD 3.6 appraisal report.
It does mean knowing what their lenders expect.
A broker working with several wholesale lenders could soon have partners on different implementation schedules. That makes it worth checking rollout dates before ordering an appraisal, particularly for files moving between lenders or approaching the transition dates.
And the exception shouldn't be mistaken for a six-month postponement of UAD 3.6.
The industry is still moving to the new standard. The difference is that, instead of everyone crossing the line on Nov. 2, Fannie and Freddie have given lenders that aren't ready a longer runway.
