UAD 3.6 Unpacked: FAQ
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As we prepare for the transition to UAD 3.6, one thing is clear: there are a lot of questions. From new reporting requirements to implementation timelines, we are all working to understand what these changes mean in practice.
During our recent UAD 3.6 webinar, attendees submitted hundreds of questions and below are the most common ones.
Implementation & Timeline
How will the UAD 3.6 mandate be enforced?
UAD 3.6 becomes mandatory for all new appraisal reports submitted to UCDP on or after November 2, 2026. The November 2, 2026 mandate is based on the initial UCDP Submission Date of each report. If a UAD 2.6 appraisal report is submitted to UCDP on or after November 2, 2026, UCDP will return a Fatal message resulting in a “Not Successful” submission.
Can I still submit revisions in UAD 2.6 after Nov. 2 2026?
Yes. From the mandate date on November 2, 2026, through the retirement date on May 3, 2027, lenders may continue submitting revisions to UAD 2.6 appraisal reports. If the appraisal report was submitted to UCDP in UAD 2.6 prior to November 2, 2026, any revisions submitted to the existing DocFile ID will remain in UAD 2.6.
Reporting & Form Changes
How different is the UAD formatting for things like transaction type or functional issues?
The biggest shift is no more abbreviations. UAD 3.6 moves to plain language throughout. For transaction type, fields like non-arm’s length are now dynamic. The appraiser can enter free-form text to describe the relationship between the parties, which is more useful than code. Functional issues are a good example of what we call enumerated fields. Instead of the appraiser typing free form answers, they're selecting from a defined list: None, ceiling height, floor plan, nonconformity, over improvement, under improvement, or Other with a describe box. That structure shows up often in the new form. Some lists are fixed, some have that open-ended "Other" option, but either way, it's a more controlled data environment than what lenders saw in 2.6 — which means the answers themselves may look different even when the underlying condition is the same.
Is the UCDP mandatory in 3.6? How about CU?
Yes to both. UCDP submission has always been required for conventional appraisals on loans sold to Fannie Mae or Freddie Mac: that doesn't change under 3.6. What changes is the format: UCDP currently accepts both UAD 2.6 XML files and UAD 3.6 ZIP files, but as of November 2, 2026, all new submissions must be UAD 3.6. Once a report is submitted, CU (Fannie Mae) and LCA (Freddie Mac) run just as they do today, and the redesigned UAD 3.6 SSR returns the CU Risk Score with Rep & Warrant relief eligibility on the Fannie Mae side, and the LCA Risk Score with the Collateral Rep & Warranty relief indicator on the Freddie Mac side. So UCDP remains the delivery requirement, and the risk scores come back through the SSR, the same relationship as today, just with an updated, more transparent SSR format.
Will there be information whether the property complies with zoning?
Yes, and it's more structured than what we're used to. Zoning lives in the Site section of the new URAR, with discrete data points and commentary placed together so reviewers can find everything in one spot rather than hunting through an addendum. Under the Zoning heading, the appraiser reports Compliance, the Classification Code and its Description, and, when applicable, the Reasons Illegal, the Impact, and whether the property is Rebuildable to Current Density/Use. That last set is a real improvement: under the legacy forms, a "legal nonconforming" checkbox often left reviewers guessing, whereas 3.6 requires the appraiser to spell out what the noncompliance is and what it means for the property. There's also a dedicated Description of Zoning Compliance field for supporting commentary, plus a Property Use subsection covering whether the property is Primarily Residential, the Residential Use, any Non-Residential Use, and any Non-Residential Modification. Zoning analysis becomes discrete, structured data with the appraiser's reasoning attached, which makes it easier for underwriters and reviewers to identify and evaluate zoning risk.
Is there a field for documenting the effective age of a building?
Yes, in two places: the Dwelling Exterior section, alongside the actual Year Built, and the Cost Approach section, where it supports the depreciation analysis. Because it's now a discrete data point rather than free-form commentary, reviewers can easily check that effective age lines up with the condition rating, described updates, and applied depreciation.
For properties that have multiple ADUs, how does UAD 3.6 allow the appraiser to show like comps with multiple ADUs?
Yes, ADU reporting is a huge uplift over 2.6. ADUs can now be reported specifically, whether located within the primary dwelling or as a separate outbuilding on site, and the structure supports one ADU or several with repeatable data blocks rather than trying to cram everything into commentary. That carries into the sales grid, where there's far better ability to reflect comps with multiple ADUs clearly. The dramatic difference is in clarity: 3.6's structure gives a much better understanding of what each ADU is and how it impacts value.
There is a section of UAD 3.6 that shows comps that appraisers considered but chose not to use. This will get ahead of comp specific concerns. However, is the ROV process changing when the lender challenges a comp that already exists in the “considered but not used” section?
The ROV policy itself isn't changing — it's still the borrower-initiated, lender-routed process from the 2024 GSE framework, and the appraiser must review each comp submitted and respond with support. What 3.6 adds is the "Additional Properties Analysed but Not Used" section, an optional but useful tool that lets the appraiser show which comps they considered beyond the grid. If a challenged comp already sits there, it can get ahead of the concern, but it doesn't shortcut the ROV. The appraiser still must address that comp with reasoning or by incorporating it. The structured format gives a cleaner, more auditable trail for both the response and the original analysis.
Does UAD 3.6 remove remaining economic life from the form?
Not removed, made conditional. Remaining Economic Life, along with data points like effective age and attic information, is now driven by a parent requirement set by loan type. These fields populate when the assignment is an FHA, USDA, or VA (government) loan, since those agencies' requirements are built into UAD 3.6. For conventional (non-government) loans, these data points and a few others won't appear in the standard output. So whether you see Remaining Economic Life on a given report depends on the loan type driving it, not whether the field still exists in the dataset.
Are SFR, condo, and 2-4 units going to be using the same form?
Yes. There's one dynamic URAR for all residential property types — single family, condo, 2-4 unit, manufactured, and co-op. There are no separate form numbers (1004, 1073, 1025, etc.). Instead, you enter the property and assignment characteristics at intake, and the report builds itself: condo sections appear for a condo, the Unit Interior section repeats for each unit in a 2-4, etc.
Will a “Land Only” appraisal also be on the new UAD 3.6 form?
No. Vacant land / land-only appraisals are not in scope of the UAD 3.6 and Forms Redesign project. The URAR is built for residential dwellings, those assignments fall outside of it. Land-only, farm tracts, commercial, and large undeveloped parcels continue to use their existing report types outside the 3.6 framework.
How is the appraiser’s comp search criteria captured by UAD 3.6 to create the market exhibits? Does it pull the data directly from the appraisers MLS source?
Not quite, UAD 3.6 is a reporting standard, not a data source. It defines the fields and structure for how the appraiser records and delivers their analysis; it doesn't run comp searches or pull from an MLS. The appraiser still develops their own market exhibits using their MLS, public records, and other market data, and may lean on software tools, Excel, or MLS-generated charts to support the analysis. Any data that flows in automatically, MLS integration, auto-populated fields, built-in charting, is a feature of the specific vendor software the appraiser uses, not something UAD 3.6 does on its own. The dataset standardizes how the conclusions are reported; the appraiser's independent analysis and data sourcing behind those conclusions doesn't change.
Lenders & Underwriters
What would you encourage lenders to proactively add to their engagement letter to support appraisers during UAD 3.6?
Review your current engagement letter against how 3.6 structures the report. The property scenarios haven't changed, but where they get reported has. The most useful addition is conditional guidance framed as "if X is present, then Y section should be included,". Good examples: waterfront and other site influences, energy-efficient features, and disaster mitigation items. It also helps to be specific about expectations that carry over but still trip people up such as exhibits, commentary, and photo requirements. The goal isn't to rewrite the letter around 3.6, just to make sure your directives align with UAD 3.6
What should Lenders do if we need a comparable rental schedule on a departing residence? What product should we order for UAD 3.6?
A departing residence is a non-subject property in the transaction, so this is exactly the grandfathered standalone case. Order the standalone Comparable Rent Schedule (legacy 1007/1000) — the GSEs have confirmed it remains acceptable for documenting rental income on a non-subject one-unit property even after UAD 3.6. You don't route this through the URAR's UAD 3.6 rent schedule, since that's for subject property assignments.
If you were educating an underwriting team or collateral review team on UAD 3.6, what are the three main points you would emphasize?
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First, get to understand the structure. The report is dynamic — no more fixed form numbers — so it expands and contracts based on property characteristics and scope of work. Learn the sections and conditional logic rather than a static page layout.
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Second, structure doesn't mean support or analysis. Standardized fields make the report cleaner and machine-readable, but they don't replace the appraiser's reasoning — reviewers still need to confirm the data is supported and the analysis holds together.
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Third, each section allows for narrowed focus. Because everything has its place, you can zero in section by section on what data, exhibits, and commentary should be present.
Appraiser Workflow
If it takes the appraiser longer to inspect and type a UAD 3.6 report, what feedback has there been from appraisers relating to fee changes?
It's early to read the trend, because many appraisers are just getting into the first iteration of their software and learning 3.6 itself. In some cases, writing up the report has been comparable to the legacy 2.6 forms; in others, the software or the added data requirements are taking more time up front. On fees, the industry signal points upward — recent appraiser surveys show a meaningful share expecting fee increases, driven by added inspection time, expanded scope, and new software costs, while a sizable group expects fees to hold steady. But the long-term picture isn't clear yet. Both turn times and fees are expected to be most volatile during this early adoption stretch and to normalize as appraisers gain reps and workflows settle. We need more completed reports and more field experience before anyone can call where fees land for good.
What has been the average turn around time for SFR UAD 3.6?
We don't yet have enough completed 3.6 orders to give a reliable average. Turn time varies by state, county, and market as always, but with volume still ramping during broad production, any number right now would be more anecdote than trend. We'll have a much clearer picture as order counts grow.
Are there hard stops to keep appraisers from finishing the appraisal if data is left out?
Yes and no. The dataset defines required and conditionally required fields, and vendor software enforces hard stops on the clear-cut ones. The UAD Compliance API, which connects appraisal software directly to the GSEs, adds another layer, checking completeness and validity before submission. But there are grey areas: because the report is dynamic, some fields become required based on scope of work or property complexity, and vendor software won't always catch every situation where a data point should have been included. Appraiser review is still necessary.
Are the SSR’s still going to flag the Appraisal for unacceptable appraisal terminology?
Yes. The GSEs' policies on unacceptable appraisal practices, including prohibited and subjective terminology, carry forward under 3.6, and the SSR still returns proprietary findings based on each GSE's requirements, which is where terminology flags live. Both GSEs have published rewritten message sets aligned to UAD 3.6, so the specific message codes are new, but the scrutiny is the same. One practical note: because 3.6 replaces much of the free-form addendum narrative with structured fields, there are fewer places for problematic language to appear, but the commentary fields that remain are held to the same standard.
Do you know if FNMA revised a new checklist for appraisals? Are the sample appraisals for review?
Fannie Mae hasn't issued a formal "checklist," but they've published UAD 3.6 job aids that serve a similar purpose — including Guidance for Appraisers through Lessons Learned, Photo and Image Requirements, and Inspection and Reporting Tips, all on the Fannie Mae and Freddie Mac UAD webpages. Reviewing your own internal checklist against 3.6 is worthwhile too — it builds a better understanding of the new structure and helps your existing review points cross over neatly to the 3.6 report. For samples, the GSEs published 12 URAR sample scenarios (Appendix D-1) covering different property types. For Opteon-specific 3.6 support and sample reports, reach out to your Account Success Manager and they'll get you what you need.
Have appraisers been asked to provide a comparable rental analysis on an ADU for the subject property you are appraising which is the borrower’s primary residence? If so, how did they handle it since a comparable rental section would not open if the occupancy is the primary residence?
Under 3.6, market rent is developed and reported within the Rental Information section of the URAR itself — the UAD 3.6 rent schedule. And the structure is more capable than the legacy forms here: rent schedules are repeatable per unit, so the appraiser can complete one for the primary dwelling, one for the ADU, or both, with each analysis clearly tied to its unit. The key on the lender side is making sure the rental analysis requirement is communicated at ordering so it's part of the assignment scope. The only place the 1007 name survives is the grandfathered standalone report, which the GSEs have confirmed remains available for standalone usage. Everything attached to a subject property appraisal runs through the UAD 3.6 rent schedule.
How are Short Term Rentals being handled in UAD 3.6? Opteon has their own proprietary form, but what have you seen from appraisers overall in regard to STRs?
UAD 3.6 doesn't specifically address STRs. The rent schedule is more flexible, and an appraiser can technically complete an STR within it, but that doesn't solve the core problem: STR income behaves like a business (seasonality, occupancy swings, active management), the supporting data isn't what MLS supplies, and a long-term GRM isn't compatible with STR income. That's why proprietary forms have grown in use — they capture the different data STR valuation requires, often with narrative analysis and sometimes a Certified General appraiser given the going-concern component.
How will requests for stand alone rent schedules be handled under UAD 3.6?
For subject property assignments, rent is developed within the UAD 3.6 rent schedule in the URAR itself — there's no separate standalone form. The legacy 1007 name survives only as the grandfathered standalone report, which the GSEs have confirmed remains available for limited standalone use, such as documenting rental income on a non-subject property or the rare case where market rent is needed after the URAR is complete and the original appraiser is unavailable. Otherwise, standalone requests tied to a subject property should run through the UAD 3.6 rent schedule.
Are rules about “discriminatory” language still going to apply?
Yes. The prohibitions on discriminatory and subjective language carry forward unchanged under 3.6 — they live in the Unacceptable Appraisal Practices policy, which the UAD 3.6 Policy Supplement incorporates. Lenders remain responsible for ensuring reports are free of prohibited language, and Fannie Mae's text-scanning tools still flag subjective terms like "desirable neighborhood" or "pride of ownership." If anything, 3.6's shift from free-form narrative to structured fields reduces the openings for that language, but the commentary sections that remain are held to the same standard.
ANSI still refers to the exterior measurement to get total sq.ft. Are the interior room dimensions still required or can they be obtained by the exterior measurement?
In UAD 3.6, the appraiser can provide either a computer-generated sketch or a floor plan (floor plans show interior walls). ANSI still governs the reported square footage and is based on exterior measurement — so if the appraiser takes interior dimensions, exterior wall thickness must be added to convert to an ANSI-compliant exterior figure. All ANSI rules still apply under 3.6; the old exception code is retired, so full ANSI compliance is now required.
If the loan is an investment property, does that impact how the UAD appraisal is ordered?
The main thing is to order the rent schedule along with the UAD 3.6 report when rental income analysis is needed for the loan. Occupancy can be a driver in how the report is built, but because 3.6 is driven by property and assignment data rather than form numbers, you can't rely on occupancy alone to trigger it — you need to specify that the rent schedule is part of the assignment at order intake so the rental analysis sections open. So while you're no longer selecting a "1007 add-on" the way you did before, ordering the rent schedule alongside the 3.6 report is what ensures it's captured.
Do UAD Completion Reports get submitted to the UCDP Portal?
When a Completion Report is submitted to UCDP under UAD 3.6, it must be in 3.6 ZIP format and associated with the existing 3.6 URAR submission — and the format has to match the original, so a 3.6 URAR can't be paired with a legacy 1004D. Note also that the Completion Report and Restricted Appraisal Update Report are now two separate reports rather than the combined 1004D/442.
What are common hard stops to be aware of?
The best source is the GSE documentation itself. Both Fannie Mae and Freddie Mac publish full lists of warning, overridable, and fatal findings, and we'd point your team there rather than working off a partial list. At a high level, UCDP runs three rule sets on a 3.6 submission: System Findings (is the ZIP complete and correctly structured), UAD Compliance Findings (does the XML meet the 3.6 spec), and GSE Proprietary Findings (each GSE's own requirements). Some findings are non-overridable. For example, a missing appraiser name or a C6/Q6 rating could require a corrected, resubmitted report. Also note the transition messages: a Warning on UAD 2.6 submissions starting August 6, 2026, and a Fatal message on November 2, 2026.
Does the Control + F function still work to search UAD 3.6?
Yes. When you're reviewing the PDF output of the report, Control + F works just as it does on any PDF. And because 3.6 is structured data, the underlying XML is fully machine-readable too, so searching and automated field-level lookups are easier than with the legacy forms.
With the new “pop outs” like for PUD, where are appraisers going to put non-required HOA dues? Would they be comments or no longer required if not PUD?
The Project Information section only appears for PUD, condo, co-op, and condo properties. If there's a need to disclose non-required fees, the appraiser can note them in the Project Information commentary when that section is present — or, if it isn't (because the property isn't a project type), in the Subject Property or Site section commentary.
With one UAD 3.6 form that will be used for all property types, how do you anticipate changes in scope of work if not ordered correctly? Ex. MU of SF, Condo instead of SF.
It'll be handled much like it is today. The scope still needs to be corrected with the client. The uplift is on the appraiser's side: because it's one dynamic report rather than separate forms, they don't have to switch forms or redo work already completed. They simply continue in the same report and update the characteristics that drive it, and the relevant sections adjust accordingly. So, a mis-order that meant starting over on a different form is now a matter of correcting the inputs and letting the report reflow.
When an appraisal is “subject to” in UAD 3.6, how is the final ordered? Is it still form 1004D?
No, the 1004D/442 is split into two separate reports under 3.6: the Completion Report (confirming the "subject to" conditions were met) and the Restricted Appraisal Update Report. So instead of one 1004D covering both functions, lenders now order the specific report they need. For a "subject to" completion, you'd order the Completion Report. Both reports are submitted to UCDP in 3.6 ZIP format and associated with the original 3.6 URAR submission. Note: the format must match the original. 3.6 URAR pairs with these new reports, not the legacy 1004D.
Technology & AI
Is Opteon AMC using Jaro?
Yes. Opteon AMC uses JaroDesk for order management, which includes our AI QC tool, Intara. Our JaroKit platform is currently in beta testing with our panel appraisers.
Do you know if AI will determine opinion of condition rating in photos?
It depends on the software. Some vendor platforms include computer vision tools that can suggest condition and quality ratings from photos, while others don't. Either way, the rating is the appraiser's professional determination, and the appraiser is responsible for reviewing anything the software suggests. The same applies on the review side: some QC and review platforms use image analysis to flag potential mismatches between photos and reported ratings, and some don't. As for the UCDP submission itself, the GSEs haven't announced any photo-based computer vision scoring in CU or LCA, their published feedback is driven by report data.
