UAD 3.6 goes live November 2: what will trip up loan files first?
The first snags are about timing and consistency. The format is set by each report's first UCDP submission date, so October orders can land on the wrong side of November 2. Updates must match the original report's format, and the new report's many fields have to agree with each other, or revision requests follow.
One date decides the format, and it is not the one you think
If you need the tour of the new report first, read what UAD 3.6 and the new URAR are and what changes on the report underwriters read. This post is the launch-week field guide.
Fannie Mae and Freddie Mac say UAD 3.6 is mandatory for all new appraisal reports submitted to the Uniform Collateral Data Portal (UCDP) on or after November 2, 2026. Both base the mandate on the report's initial UCDP submission date, not the loan application date and not the appraisal's effective date.
That is where the first files will trip. An appraisal ordered in October, inspected in October and dated in October is still a 3.6 file if it first reaches UCDP on November 2 or later. Fannie Mae's own advice is to allow enough time to order, receive and submit any UAD 2.6 reports before that date.
A lender that cannot meet the mandate has to ask each GSE involved for a policy exception. "The report was almost done" is not a policy exception. It is a feeling.
Updates and completions have to match the original
The second snag is the follow-up paperwork. Here is what the GSE FAQs say:
| Original report | Update or completion report |
|---|---|
| UAD 2.6 | Form 1004D/442 in UAD 2.6 XML, tied to the prior 2.6 submission. The process is unchanged. |
| UAD 3.6 URAR | A separate Restricted Appraisal Update Report or Completion Report in UAD 3.6 ZIP format, tied to the existing 3.6 URAR. |
UCDP does not accept mixed standards under the same Document File ID. The format of the update has to match the format of the original. So a construction loan with a 2.6 "subject to completion" report submitted before the mandate does not get its final inspection in 3.6. And a 3.6 file never gets a "442."
Two more transition notes. Because the trigger is the initial submission date, a 2.6 report that first hit UCDP in October is judged by that date. Since UCDP will not mix standards under one Document File ID, ask your investor how they want a late revision of that report handled. And if a loan moves to a new lender, UCDP does not let that lender reuse a Document File ID created by another lender's submission.
Write the version on the file's cover sheet. Your processor will not remember it in three weeks. Neither will you.
The order has to say what you want
Under the old forms, the form number told everyone the scope. Under UAD 3.6, the GSEs say the report supports traditional, hybrid, desktop and exterior assignments, and that the appraiser learns whether to use UAD 2.6 or 3.6 from the engagement letter.
Fannie Mae also notes that lenders may use a staged rollout, so requirements can vary by lender and by assignment. In plain words: two lenders in the same week may send the same appraiser different instructions for the same kind of house.
Before November 2, check your order screens and your AMC's templates for three things:
- Which UAD version the report should be delivered in
- The inspection type you actually need
- The loan program, since FHA, VA and USDA run their own timelines and the GSEs tell lenders to contact each agency for its plan
An order that says "1004, standard" after November 2 is like a menu that says "food." Someone will bring you something. It may not be lunch.
More fields means more chances for answers to disagree
The new report is built from data fields, and those fields are checked against each other. Freddie Mac published a lessons-learned job aid from early UAD 3.6 reports. The problems it lists are a good preview of the revision requests your files will see:
- Condition that does not match the defects table. One report listed missing floor coverings as a defect with a recommended action of "None." Freddie Mac's answer for that example: as is, the home rates C5; made subject to installing the flooring, it could rate C4.
- Reconciliation that does not match the comp weights. Canned 2.6 commentary did not line up with the comparable weight reported on the grid.
- Levels that do not match the room table. The levels in the unit and the level and room detail have to agree, and below-grade area counts as a level.
- Old words in new fields. Commentary still said gross living area, a term UAD 3.6 no longer uses.
- Typed answers where a pick list exists. Financing type and transfer terms are separate fields with set choices.
The GSEs' UAD Compliance API checks for data completeness, validity and reasonableness. It does not give you Collateral Underwriter findings. A clean compliance check means the fields are filled in properly, not that the value is supported.
I like this part. When the fields have to agree, a weak adjustment has nowhere to hide. Facts over feelings, now with a pick list.
What to collect from borrowers before the appraiser arrives
The new report asks for more about the house, so the inspection needs more access. Freddie Mac's UAD 3.6 photo job aid lists required interior photos of all kitchens, all bathrooms and the main living areas, including all bedrooms. Photos of below-grade areas and recent updates are required when they exist. Outbuildings need interior and exterior photos, and ADU interior photos are required when there is one.
Each kitchen and bath also gets an update status, a time frame and a condition status. The GSEs say the report collects more detail on ADUs, such as size, condition, rooms and location. So collect this at application, not the night before the inspection:
- Access to every room, including bedrooms used by tenants, roommates or a teenager who considers the door a constitutional right.
- Access to every outbuilding and ADU, with tenant notice if someone lives there.
- A list of updates with dates: kitchens, baths, flooring, roof, systems, with permits if there were any.
- Known unfinished items, like missing flooring or work in progress, so the order is set up as is or subject to from the start. My subject-to repairs post covers what that means for closing.
- New construction details. Freddie Mac says new construction is now reported as Fully Updated, and the home has to meet the new construction definition to rate C1.
A launch-week checklist for your desk
- List every open appraisal and the date it will likely first reach UCDP. Anything landing November 2 or later is 3.6.
- Tag 2.6 construction files that will need a completion report later, so it goes out in 2.6 and ties to the right submission.
- Fix your order templates: version, inspection type, loan program. No form numbers.
- Rewrite underwriting conditions that still ask for a "1004D" or "revised GLA" on a 3.6 file.
- Read the defects table and the condition ratings together the day the report arrives. If they disagree, ask early.
- Send borrowers the access list above with the appraisal fee notice.
If you want something to hand your processors, my free UAD 3.6 Class Workbook is on the free guides page. It walks through where everything moved. The value still comes from sales and supported adjustments. The report just asks to see the work, which good appraisers were already showing.
Key takeaways
- The format is set by the report's initial UCDP submission date, so October orders can still be 3.6 files.
- Updates and completions must match the original report's format; UCDP will not mix 2.6 and 3.6 under one Document File ID.
- Put the UAD version and the inspection type in every order, because the engagement letter now carries them.
- Expect revision requests when condition, defects, rooms and reconciliation fields disagree.
- Get access to every bedroom, ADU and outbuilding, plus update dates, at application.
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People also ask
Does UAD 3.6 apply to FHA and VA loans on November 2?
The November 2 mandate is for reports submitted to UCDP for Fannie Mae and Freddie Mac. The GSEs tell lenders to contact FHA, VA and USDA for their own implementation plans.
Can a loan with a UAD 2.6 appraisal still be sold after the mandate?
Yes. Freddie Mac says the retirement of 2.6 is about submitting the report to UCDP and does not prevent the sale of the loan to the GSEs.
Does passing the UAD Compliance API mean the appraisal is fine?
No. It checks that data is complete, valid and reasonable. It does not include Collateral Underwriter findings or review whether the value is supported.
Sources
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