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Gse's UAD 3.6 Likely Delayed Til Late '27/'28 - (copilot Analysis Today)

Alsie35

Elite Member
Joined
Sep 14, 2020
Professional Status
Certified Residential Appraiser
State
Texas
As you read this, remember that a local "AF Nostradamus" predicted this outcome last year ;)

FROM COPILOT TODAY:

A realistic revised UAD 3.6 timeline starts with one unavoidable fact: nothing in the past six months suggests the ecosystem is anywhere near the pace required for a November 2026 mandate. The newest industry reporting reinforces this—Broad Production is technically open, but adoption is thin, readiness is low, and vendors are unevenly prepared. )

What follows is a phase‑by‑phase projection of where the rollout should be versus where it actually is, and the most plausible revised dates based on current conditions.

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1. Industry Prep (originally 2024–2025)
Where it should be:
- All training complete.
- All vendors fully verified.
- Appraisers trained and practicing in parallel.

Where it actually is:
- Training exists, but uptake is inconsistent.
- Vendor readiness is uneven; some are “ready,” others still working through XML and data‑structure issues.
- Only 26% of appraisers report feeling ready as of February 2026.

Revised projection:
- Industry Prep effectively extends through mid‑2026.
- The ecosystem will still be “prepping” well into Q3 2026.

---

2. Limited Production (originally 2025)
Where it should be:
- High‑volume test submissions.
- Lenders and AMCs validating workflows.
- Appraisers producing practice reports regularly.

Where it actually is:
- Limited Production never reached the intended scale.
- Many lenders and AMCs are only now beginning to test workflows.
- Broad Production launched January 26, 2026, but the announcement emphasized permission to submit, not actual adoption. ")

Revised projection:
- Limited Production effectively continues through all of 2026, overlapping with Broad Production.
- The “testing” phase is still happening now, months after it should have ended.

---

3. Broad Production (originally January 2026 → November 2026)
Where it should be:
- Widespread lender adoption.
- Majority of appraisers submitting UAD 3.6 reports.
- Old forms still allowed, but fading.

Where it actually is:
- Broad Production is technically open, but adoption is minimal.
- Lenders are not uniformly ready.
- Appraisers overwhelmingly remain on legacy forms.
- AMCs are still messaging “get ready,” not “we are live.”

Revised projection:
- Broad Production realistically runs from 2026 through mid‑2027.
- The industry will need at least 12–18 months of real Broad Production before a mandate is feasible.

---

4. Mandatory Use (originally November 2, 2026)
Where it should be:
- All GSE‑bound appraisals must use UAD 3.6.
- Legacy forms retired for new assignments.

Where it actually is:
- No evidence the ecosystem could meet a November 2026 mandate.
- Readiness gaps remain large.
- Vendor and lender adoption is far behind schedule.

Revised projection:
- Mandatory Use slips to late 2027 at the earliest.
- The most realistic window is Q4 2027–Q2 2028.

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5. Retirement of Legacy Forms (originally 2027)
Where it should be:
- Old URAR and related forms fully retired.
- All workflows standardized on UAD 3.6.

Where it actually is:
- Retirement cannot occur until Mandatory Use is stable.
- No GSE communication since 2025 has reaffirmed the retirement date.

Revised projection:
- Legacy form retirement moves to 2028–2029.
- A full year of stable mandatory use is required before retirement.

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Consolidated Revised Timeline (most plausible)
| Phase | Original Date | Realistic Revised Date |
|-------|---------------|------------------------|
| Industry Prep | 2024–2025 | Through mid‑2026 |
| Limited Production | 2025 | Through all of 2026 |
| Broad Production | Jan–Nov 2026 | 2026–mid‑2027 |
| Mandatory Use | Nov 2026 | Late 2027–mid 2028 |
| Legacy Form Retirement | 2027 | 2028–2029 |

---

Why this delay is structurally unavoidable
- Appraiser readiness is far too low for a mandate.
- Vendor readiness is uneven, and lenders depend on vendor stability.
- Broad Production adoption is not happening at scale, despite being “live.”

- GSE silence since late 2025 strongly suggests they are waiting to announce a delay until the data forces their hand.
 
Last edited:
| Mandatory Use | Nov 2026 | Late 2027–mid 2028 |
| Legacy Form Retirement | 2027 | 2028–2029 |


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Excellent Alsie. Everything else is noise. The Simps will disagree and insult those who aren't on their brown nose bandwagon, but this ^^^^^^ is all that matters.
 
If there really be a shortage of appraisers, I can get my high fees.
UAD 3.6 will make clients/lenders pay us higher fees. Is that real reason for the Abomination form?
 
Okay you can hold off on your retirement for another two years.
You laugh but late 2028, early 2029 has always been when ole’ Tommy Boy plans to trade in his iPad for Hawaiian shorts, knee high black socks and head south where it is warm!
 
3.6 will be mandatory when lenders are ready, no sooner no later.

At this point most lenders don't know the difference between 3.6 and 6-7. From where I sit, I agree with the OP but believe the timeline won't extend into 2028.
 
CoPilot might have it right... we will have to wait to find out. Lyle Radke has said that the timeline stands.
 
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