Aim High
Freshman Member
- Joined
- Sep 28, 2020
- Professional Status
- Certified Residential Appraiser
- State
- South Carolina
Appraisers have expressed multiple concerns regarding the new 3.6 report format, primarily centered on the significant increase in narrative requirements and the risk of additional liability. The redesigned form requires more detailed explanations for condition, quality, market trends, and adjustments, which increases report complexity and time required per assignment. Many appraisers are concerned that the expanded commentary expectations will lead to more revision requests from lenders and AMCs, particularly because the new form eliminates many structured checkboxes and replaces them with open-ended fields. There is also uncertainty regarding how examiners and underwriters will interpret the new data points, and whether inconsistent expectations across clients will create conflicts or unnecessary revision cycles. Additional concerns include a lack of clarity on how to address hybrid or third-party data collection, how the new format aligns with USPAP, and whether the increased workload will be supported by higher fees. Finally, appraisers worry that the more narrative-driven format may increase the chance of subjective interpretation, potentially leading to elevated E&O exposure if an underwriter disagrees with an appraiser’s professional judgment.
Many appraisers are also concerned about the financial and time burdens associated with transitioning to the new 3.6 format. The updated report structure is designed around mobile data-collection workflows, which for many appraisers means purchasing a new iPad or compatible tablet, updated lasers, new software subscriptions, and accessories. These costs are occurring at the same time that many AMCs are not increasing fees to compensate for the increased reporting workload. Beyond equipment, the required training classes, webinars, and software updates represent a significant time investment—often unpaid—and many appraisers expect a steep learning curve as they adapt to the new data fields, narrative requirements, and workflow changes. For appraisers who operate independently, this translates directly into less billable time, slower turnaround during the transition period, and increased operational costs that may not be recoverable.
