Has Anyone Completed A 3.6 Yet

[Sandra Koutsopoulos]

Appraisers

Update your Fees​

As the industry continues to evolve toward UAD 3.6 and hybrid valuation products, maintaining accurate and current panel information has never been more important.
Clearbox is working to provide visibility into current market-based appraisal fees nationwide. To support this initiative, we are asking all appraisers to log into the Clearbox platform and update their fee schedules and coverage information.
While updating your profile, please also indicate whether you are willing to perform:

[td]•[/td] [td]Hybrid Appraisals[/td] [td]•[/td] [td]UAD 3.6 Desktop Assignments[/td] [td]•[/td] [td]Property Data Collection [/td]

Lenders and AMCs are increasingly looking for appraisers who are prepared for modernization and alternative valuation workflows. Ensuring your profile is current helps position you for future opportunities.
Please take a few minutes to review and update your information today. If you are already have an active account please login here. To create a Clearbox Profile, start here.

Thank you for being part of the Clearbox network.​

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Sign Up Today →​

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......I received this solicitation this morning.... My analysis of this brings me to the conclusion that ClearBox is trying to test the waters to see what appraisers are willing to accept for payment for the 3.6, Hybrids, PDC etc. Probably indicates they haven't received the feedback they're happy with yet to try to force-feed OTHER appraisers their version of C&R fees. I will not be responding to ClearBox.
I don't know whether I will do ANY 3.6 appraisals at all, though my intent is leaning toward doing them for my direct lenders, as they have paid me decently. My intent is NOT to do any for AMCs who charge tech fees, require bidding and want me to discount my normal fees etc.
At any rate, the more I read about other peoples' experiences with it (thank you everybody who has spent time and effort trying to get a handle on the 3.6), the less inclined I am to do them on a regular basis, if at all. It seems what the 3.6 requires is mostly superfluous to market value, and requires scads of irrelevant info that doesn't aid lenders in making collateral nor credit decisions. What it's all for is clearly NOT for lending security. Perhaps its all about selling info about ppl's private homes through database building, like charging furnace selling companies data on whose house has an old furnace that may need replacement soon. And of course there's all the other insidious ubiquitous 'spies' who plan to profit on what they see in a Borrower's home. From what I see, the 3.6 is an invasion of privacy, is an appraiser's (and occupant's) time-burner (at no pay), and provides no meaningful benefit in collateral asset evaluation.
Is there, somewhere, a justification statement from the GSE's as to WHAT necessary benefit to them the 3.6 will provide? GSEs: Convince me if you CAN! (I highly doubt it)

 

[J Grant]

How is that any different from what agents have been doing for years? We have all gotten ROVs where the agent used $/SF as a justification, while providing sales of much smaller homes that woudl naturally have a higher price per sq ft. The fact that they are using Chat or Claude now does not change the basic behavior.

Your comment supports my point - that AI is not any better than the crappy search results agents got without AI-

The difference is that the appraisal valuations are being entrusted to being performed by AI - AIVRE and the other software tout it - and the AMC's will use it for speed -the churn and burn appraisers having to work at speed to survive the AMC hamster wheel can not afford the time it takes to pore over the comps personally-

RE agents might not perform any better when they use AI , but they might well think that they are.

 

[Trihard]

Appraisers

Update your Fees​

As the industry continues to evolve toward UAD 3.6 and hybrid valuation products, maintaining accurate and current panel information has never been more important.
Clearbox is working to provide visibility into current market-based appraisal fees nationwide. To support this initiative, we are asking all appraisers to log into the Clearbox platform and update their fee schedules and coverage information.
While updating your profile, please also indicate whether you are willing to perform:

[td]•[/td] [td]Hybrid Appraisals[/td] [td]•[/td] [td]UAD 3.6 Desktop Assignments[/td] [td]•[/td] [td]Property Data Collection [/td]
Lenders and AMCs are increasingly looking for appraisers who are prepared for modernization and alternative valuation workflows. Ensuring your profile is current helps position you for future opportunities.
Please take a few minutes to review and update your information today. If you are already have an active account please login here. To create a Clearbox Profile, start here.

Thank you for being part of the Clearbox network.​

[td]


[td]
Sign Up Today →

[/td]



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......I received this solicitation this morning.... My analysis of this brings me to the conclusion that ClearBox is trying to test the waters to see what appraisers are willing to accept for payment for the 3.6, Hybrids, PDC etc. Probably indicates they haven't received the feedback they're happy with yet to try to force-feed OTHER appraisers their version of C&R fees. I will not be responding to ClearBox.
I don't know whether I will do ANY 3.6 appraisals at all, though my intent is leaning toward doing them for my direct lenders, as they have paid me decently. My intent is NOT to do any for AMCs who charge tech fees, require bidding and want me to discount my normal fees etc.
At any rate, the more I read about other peoples' experiences with it (thank you everybody who has spent time and effort trying to get a handle on the 3.6), the less inclined I am to do them on a regular basis, if at all. It seems what the 3.6 requires is mostly superfluous to market value, and requires scads of irrelevant info that doesn't aid lenders in making collateral nor credit decisions. What it's all for is clearly NOT for lending security. Perhaps its all about selling info about ppl's private homes through database building, like charging furnace selling companies data on whose house has an old furnace that may need replacement soon. And of course there's all the other insidious ubiquitous 'spies' who plan to profit on what they see in a Borrower's home. From what I see, the 3.6 is an invasion of privacy, is an appraiser's (and occupant's) time-burner (at no pay), and provides no meaningful benefit in collateral asset evaluation.
Is there, somewhere, a justification statement from the GSE's as to WHAT necessary benefit to them the 3.6 will provide? GSEs: Convince me if you CAN! (I highly doubt it)

They will use appraiser fees against each other. For example, if there is someone in your market that will do a 3.6 appraisal for $375. They will use that information to support paying everyone that fee. So if you ask for $1,000 for a 3.6 appraisal, they will come back saying that there are other appraisers who will do the 3.6 appraisal for $375. Why are you so expensive? It's a dirty game dealing with AMC scum. I have had AMC reps call me, and I tell them my 3.6 fee is $1.5k. At this point there is nothing to lose because my business can't survive if the standard fee for 3.6 is less than $1k.

 

[J Grant]

I asked AI with a prompt question ( anyone here is encouraged to do so) if RE agents' access to AI as well as the agents now influxing to perform PDC collections, is embolding them to challenge valuations more frequently and think of themselves as appraisers- the AI answer was yes (with explanations of why this is the case)

Another addition to the weaponization against appraisers. I rarely use language like that, but this is what it feels like. It is the reason appraisers are reacting the way we are about UAD 3.6.

Sure enough, this agent emailed me today, blathering on about value. I did not email her back. I have no idea yet what the value will be. I will let the market decide, but I will spend hours on my computer searching for the competing comps, poring over the photos, etc.

 

[J Grant]

AI Overview

Appraisers face a coordinated squeeze from all sides of the lending industry. Lenders, Appraisal Management Companies (AMCs), and federal regulators frequently use complaints, artificial intelligence, and deregulation to suppress fees, bypass appraiser independence, and deflect fair lending scrutiny away from the banks. [1, 2, 3, 4]
1. Weaponized Complaint and Bias Claims
Federal regulators and banks are deflecting fair-lending scrutiny by targeting appraisers. Lenders are filing frivolous complaints over standard real estate language (such as "diversified uses"), misconstruing these terms as racial bias. This forces appraisers to alter their methodologies out of fear of costly legal battles or disciplinary actions. [1, 2]
2. Deregulation and Algorithmic Replacement
Lenders and policymakers increasingly bypass traditional appraisers to cut costs and speed up turn times. The push for "appraisal modernization" includes the expanded use of Artificial Intelligence, Automated Valuation Models (AVMs), and hybrid/desktop appraisals. Lowering qualification standards and easing regulations for low loan-to-value (LTV) loans devalues the profession and shifts control away from licensed experts on the ground. [1, 2, 3, 4, 5]
3. The AMC Fee Squeeze
Legislation meant to guarantee "customary and reasonable" fees for appraisers is frequently bypassed. Instead, AMCs and lenders use their market dominance to under-price appraisal services, blacklisting appraisers who refuse to accept substandard fees. Many state appraisal boards are heavily lobbied or stacked with institutional members, making local enforcement of appraiser rights difficult. [1, 2]
How to protect yourself:

• Document and Notify: If your appraiser independence is violated or a lender pushes for specific values, document the pressure and notify the lender's Compliance Officer in writing. By federal law, a lender cannot fund a loan if independence is violated unless a full review or new appraisal is ordered. [1]
• Resources: Engage with organizations like the Appraisal Institute to stay updated on how to combat frivolous complaints and defend professional language. Utilize industry resources such as Working RE Magazine for ongoing legal strategies, whistleblower protections, and guidance on navigating pressures from agents and AMCs. [1, 2, 3, 4]
• Banks Misusing Complaints to Challenge Reports
  Feb 28, 2025 — Warning to Appraisers: Financial Institutions Misusing Complaint Process Over Misinterpreted Language. A troubling trend has emerg...
  Appraisal Institute
• What Trump's order to modernize appraisals will mean for ...
  Mar 20, 2026 — welcome everyone my guest today is Kenan Chen the EVP of strategy. and growth at Clear Capital to talk about some of the appraisal...
  2m
  YouTube·HousingWire
• Appraiser Pressure: What Agents/Brokers Need to Know ...
  
  

 

[J Grant]

AI Overview


President Trump’s appraisal modernization directives were outlined in Executive Order 14393 ("Promoting Access to Mortgage Credit"), signed on March 13, 2026. It instructed federal regulators to overhaul outdated appraisal standards to reduce homebuying costs and speed up mortgage pipelines. [1, 2, 3, 4]
Key Directives & Proposed Reforms:

• Technology Integration: Directs bank regulators and the FHFA to expand the use of Automated Valuation Models (AVMs), artificial intelligence (AI), desktop appraisals, and hybrid appraisals. [1, 2]
• Low-Risk Transactions: Instructs agencies to reduce unnecessary appraisal requirements and bureaucracy for low-risk, low-LTV (loan-to-value) loans. [1, 2]
• FHA/VA Alignment: Urges the Department of Housing and Urban Development (HUD) and the Department of Veterans Affairs (VA) to align appraisal standards and simplify qualification requirements. [1, 2]
• Rule Revisions: Requires the Fed, CFPB, FDIC, and OCC to establish clearer timelines for appraisals and cut overall red tape in mortgage lending. [1, 2]

Implementation Status:
Because it is an Executive Order, it acts as a directive rather than immediate law. Federal agencies are reviewing exis

 

[Sandra Koutsopoulos]

"...RE agents might not perform any better when they use AI , but they might well think that they are..."

So true! Many years ago, an agent at the ReMax office where I held my RE license, had me doing valuations for her foreclosing clients. Her BPOs were... frankly, ...an embarrassment! She'd pull "comps" from 2 miles away, different market, way different GLA, perhaps to get the listing with her 'high' estimated market value. She gave me one in Santa Ana (densely populated suburb) to do. 5 bedroom ranch, 1 bath, carpeted kitchen & dining area on a busy through street. I dinged it for 5 BR/vs 1bath, and carpeted kitchen/dining area, because that neighborhood had LOTS of children (5 BR good), but 1 bath (inadequate), carpeted area for kitchen food prep/eating (hard to clean), busy street (traffic/noise) and agent was unhappy with my value. So she gave lender new comps 1.5-2 miles away on quiet streets, vinyl/tile kitchen floors etc, and nearly 2 years later, the house sold below my FMV, as it was listed for sale too high for too long, and was a stale listing by then. Agent vs Appraiser: 2 hats, 2 mindsets.

 

[DWiley]

The difference is that the appraisal valuations are being entrusted to being performed by AI -

That is only true if the appraisers choose to do it that way.

 

[J Grant]

That is only true if the appraisers choose to do it that way.

The fact that they are allowed a choice about whether to use AI to auto-populate and develop adjustments ( or pick comps ), and provide narrative is scary, because there is no meaningful oversight on whether the appraiser will in addition, personally analyze the data and comps and form their own opinions.

If I were a younger appraiser entering today's landscape with heavy AI dominance, low fees, insane fast turn times, available AI being touted as a solution, including the fact that it provides an illustration of support (for its own conclusions lol ), why in the world would I care to take additional time - it is almost like that is penalized. The appraisers are being distanced from the market anyway with hybrids so it is just another sheet of data.

The fact that buyers do not pay 600k for data seems to escape those in charge. The buyer pays 600k for a unique property ( unique to itself, even if a tract home ).

What penalty or oversight is there for appraisers using AI to do practically everything?

 

[DWiley]

The fact that they are allowed a choice about whether to use AI to auto-populate and develop adjustments ( or pick comps ), and provide narrative is scary, because there is no meaningful oversight on whether the appraiser will in addition, personally analyze the data and comps and form their own opinions.

If I were a younger appraiser entering today's landscape with heavy AI dominance, low fees, insane fast turn times, available AI being touted as a solution, including the fact that it provides an illustration of support (for its own conclusions lol ), why in the world would I care to take additional time - it is almost like that is penalized. The appraisers are being distanced from the market anyway with hybrids so it is just another sheet of data.

The fact that buyers do not pay 600k for data seems to escape those in charge. The buyer pays 600k for a unique property ( unique to itself, even if a tract home ).

What penalty or oversight is there for appraisers using AI to do practically everything?

As far as I know there is nothing forcing any appraiser to use AI at all, much less rely blindly on AI analysis. Ever since I started in this business in the early 1980s, appraisers have had to make choices about tools/technology to use (or avoid). Just for example, I was using apps to collect data in the field over 20 years ago, but today only about 1/3 of appraisers use that technology. Some have long used apps to auto import MLS data. Some choose/chose not to use such apps. Choices around use of AI are no different than other choices over the past 4 decades.

I would also note that, despite attempts to characterize it otherwise, nothing in the design of UAD 3.6 was done intentionally facilitate use of AI.