3.6 Policy Exception

[timd354]

Just so everyone knows, the GSE's are incentivizing lenders to adopt UAD 3.6 before March 1, 2027 as they will no longer receive rep & warrant relief on UAD 2.6 appraisals after that date:


UAD 3.6 Policy Exception

Fannie Mae and Freddie Mac (the GSEs) are offering a policy exception for Sellers that need more time to complete their UAD 3.6 implementation. By obtaining a policy exception, Sellers will be able to submit new UAD 2.6 appraisal reports to the Uniform Collateral Data Portal® (UCDP®) from November 2, 2026 through May 19, 2027, and resubmissions of UAD 2.6 appraisal reports through June 27, 2027. However, starting on March 1, Sellers that submit a UAD 2.6 appraisal report will see reduced functionality in Collateral Underwriter® (CU®) and Loan Collateral Advisor® as detailed below. Sellers are encouraged to fully adopt UAD 3.6 as soon as possible, as this is a one-time policy exception that will not be extended.

……



March 1, 2027 – May 19, 2027 (Reduced Functionality Period): UAD 2.6 appraisal reports may be
submitted to UCDP, however, for these appraisal reports, the collateral risk score returned by each GSE’s
collateral review technology tool will be “999” in Fannie Mae’s Collateral Underwriter® (CU®) and “99” in
Freddie Mac’s Loan Collateral Advisor®. The loans secured by these appraisal reports will not be eligible
for collateral representation and warranty (R&W) relief for value. Sellers are strongly encouraged to
implement UAD 3.6 prior to March 1, 2027, to avoid potential impacts to their business and processes

 

[Tom4value]

I am taking the Bradford nighthawk seminar and they just announced today that the 2.6 usage will be extended into March 2027

That wasn’t “just announced”. I took the seminar in July and they said 2.6 usage will be available until May 2027 incase we need to make corrections on existing appraisals. I know because I asked why I need to pay $800+ a year when I am also going to pay per appraisal after the Jan. 1.

 

[glenn walker]

The Reps and Warrants loss is why your going to see every lender ramp up to speed. That's a biggy because you end up naked and you may even have to hold and portfolio those 2.6 appraised loans.

My guess is very small Hay Seed banks and Credit Unions will be last to use 3.6 or many will just get out of doing 30 year mortgages which is already happening as they can refer them to bigger banks.

 

[Dublin ohio]

Let beta testers like Dublin get the bugs out of appraisal software by next year.

I am using the released version. So far I have seen no real "bugs". Maybe a few things that could use some minor improvement, but other than that, I am having no issues with the software or the additional data points. Most of the so called new data points have been in my notes for years, with the exception of threshold height, which might add another 15 seconds to the inspection

 

[glenn walker]

Never fail to take advantage of A Crisis and no doubts any log jams will be avoided by expanding the use of waivers and by simply not ordering full appraisals.

Never underestimate the bigger plans are to whittle down the full appraisal orders to a much smaller percentage of the operations.

The Rural Complex and Oddballs will be the ones left so appraisers will work much harder then in the past and hopefully their fee's will be increased to make up for loss of time and volume.

 

[Sadie]

I think everyone thought 3.6 was going to be like the new forms that came about in 2005. It was a little bit of a PITA and did take some getting used to, but nothing on this scale. Perhaps if there had been more clarity form the onset, the outcome would have been more positive. How many years has this been in the works? But from what I have seen and read, its only been the past year to year and a half that nay actual work has been done. Was it all in the wish/planning phase until then? I honestly think that none of us, the lenders, the AMCs or the software companies want this to fail.

 

[gregb]

From an AMC I do not work with-

Dear Appraiser Partner –

The GSEs (Fannie Mae & Freddie Mac) announced today a new process for Seller Servicers who are NOT ready to comply with the new UAD 3.6 requirements by the 11/02/2026 mandate.



These Lenders may now apply for a policy exemption which will delay the requirement until May 19, 2027.



Please be aware of this new option and be prepared to receive orders for both the UAD 3.6 and UAD 2.6 until May 19, 2027.

 

[Dublin ohio]

I know because I asked why I need to pay $800+ a year when I am also going to pay per appraisal after the Jan. 1.

Bradford is not charging "per appraisal" unless you choose one of the plans that has limited units. Those plans have limited units because your are paying for the additional bells and whistles. I am going with the basic plan for $99 mo., which has unlimited units and includes the market analysis tool, but you have to use your own data, which I prefer to do anyway. I am not looking for speed

 

[J Grant]

Effectively, then, the hard stop date will be March, which is still a huge improvement. Gives us time to master the software or try alternative software as we transition to UAD 3.6 . I would assume nearly every lender would seek an exception.

 

[Dublin ohio]

I would assume nearly every lender would seek an exception.

I hope you're right, but I'm not holding my breath. We should probably know within the next two weeks if we see the 3.6 requests starting to disappear.