Why can some lenders still use the old appraisal form until 2027?

The deadline did not move. A side door opened.

If you need the tour of the new report itself, start with what changes on the report underwriters read. For launch-week snags, read what will trip up loan files first. This post is about one thing: the exception.

UAD 3.6 is still mandatory for new appraisal reports first submitted to the Uniform Collateral Data Portal (UCDP) on or after November 2, 2026. On September 30, 2026, Fannie Mae and Freddie Mac announced a temporary policy exception for sellers that cannot meet that date. A seller is a lender approved to sell loans to them.

Here is how it works, per the GSEs' joint notice:

• A seller representative "authorized to enter into a binding contract" fills out an online request with each GSE it sells to. Fannie Mae and Freddie Mac are separate requests.
• The seller has to commit to a final implementation plan.
• Lenders that do not sell directly to the GSEs do not request it, but they have to line up with their investors.
• Aggregators have to make sure their third-party originators either submit UAD 3.6 or request the exception.

The GSEs call it "a one-time policy exception that will not be extended." Think of it as UAD 2.6's farewell tour. The band is retiring. It just booked a few more dates first.

The farewell tour dates, and why March 1 matters

These dates come from the joint Fannie Mae and Freddie Mac timeline:

The quiet date is March 1. Rep and warranty relief for value helps protect a lender from being asked to buy a loan back later over the appraised value. After March 1, a 2.6 report from the exception gets none of it. A 999 sounds like a high score at the arcade. Here it means the GSE tools are no longer giving you their usual read.

If you see a different retirement date in a news story or a state alert, go by the GSE timeline. That is the one UCDP follows.

Why one house can get two different reports this winter

Picture a hypothetical broker in Sacramento who sends loans to three wholesale lenders. Lender A went live on UAD 3.6 months ago. Lender B got the exception and will order UAD 2.6 until spring. Lender C is not sure and will call you back. Same week, same kind of house, two report formats. Welcome to the tour.

The GSE rules add a few traps:

• No mixing under one file ID. Freddie Mac says UCDP "does not accept mixed standards (UAD 2.6 and UAD 3.6) under the same Doc File ID." An update or completion report has to match the original's format.
• Files that change lenders. UCDP does not let a lender reuse a Document File ID created by another lender's submission. If a loan moves from Lender B to Lender A, ask how the new lender will handle the old report before anyone promises a fast close.
• Late fixes. After May 19, 2027, a 2.6 report can only come back as a resubmission, and only through June 27, 2027. A revision request that sits in someone's inbox past that date has missed the last show.

One piece of good news: Freddie Mac says retiring 2.6 is about submitting reports to UCDP. It "does not preclude the sale of the loan to the GSEs."

What I see in the field

From my side of the table, the format is the container. The value inside it comes from the same place either way: closed sales, measured adjustments and a clear reason for the final number. A weak adjustment is weak in 2.6 and weak in 3.6. The new report just gives it fewer places to hide.

The appraiser learns which version to use from the engagement letter. When the order is vague, the file waits while somebody asks. That is the delay I expect most this winter. It won't come from the house. It will come from an order screen that says "standard" and means nothing.

The two formats also ask for different things at the property. UAD 3.6 wants more photos and more detail on kitchens, baths and any ADU. If the order says 3.6, plan for access to every room. If it says 2.6, don't assume the next lender on the same file will say the same thing.

My private work is mostly narrative reports that show the evidence step by step, so the switch doesn't change how I think. It changes which boxes the thinking goes in. I'd rather pack it once, in the right box.

A checklist for loan officers and brokers

1. Ask every wholesale lender two questions: Did you get the UAD 3.6 exception? Which format will my file use?
2. Ask about March 1. If a lender plans to stay on 2.6 past February 28, 2027, ask how it will handle files with no rep and warranty relief for value.
3. Put the version in the engagement letter, along with the inspection type. No form numbers.
4. Flag files that might switch lenders and check the report format before you move them.
5. Calendar May 19 and June 27, 2027. Push 2.6 revisions through early. The tour does not do encores.
6. Check FHA, VA and USDA files separately. The GSEs tell lenders to contact each agency for its own plan.
7. Tell borrowers and agents that the report may look different from lender to lender, but the value still comes from sales.

If your processors need the map of where everything moved on the new report, my free UAD 3.6 Class Workbook is on the free guides page. It has fewer pages than this timeline has dates.