10/14/2026
UAD 3.6 appraisal overhaul puts mortgage borrowers on the hook for higher costs - by Ryan Kingsley
(Scotman Guide)
NAMB President Michael Farrell says fragmented transition to the new appraisal model is distorting lender selection by mortgage brokers.
Haphazard rollout of a mandated appraisal overhaul is disrupting closing costs, lender selection and turn times for mortgage brokers as limited participation undermines smoother adoption.
Michael Farrell, who took over as president of the National Association of Mortgage Brokers (NAMB) in early October, says playing the blame game does nothing to help consumers, who are ultimately bearing the cost of industry-wide dysfunction.
“It’s basically all roads lead to chaos,” explains Farrell, speaking with Scotsman Guide during an interview Tuesday. “From an originator standpoint, it’s delay. Delays cost money. Delays cost the consumer money.”
Mandatory adoption of Uniform Appraisal Dataset (UAD) 3.6 was initially scheduled for Nov. 2, until Fannie Mae and Freddie Mac announced a limited extension in late September. The government-sponsored enterprises (GSEs) pushed mandatory implementation to May 2027 — but only for lenders granted waivers.
Closing cost discrepancies and delays
Some large lenders are already selling loans to Fannie and Freddie using UAD 3.6 appraisals and have been since the GSEs began accepting loan files with the modernized appraisals on a limited basis last November.
Many other lenders, however, have delayed implementation until recently, creating bottlenecks as the UAD 3.6 deadline approaches. Appraisal software providers and field appraisers have also dragged their feet on implementation, experts say.
But with Fannie and Freddie creating a dual appraisal track until next spring, Farrell says lenders who no longer order appraisals under the previous framework, UAD 2.6, are likely to lose business to lenders who will still accept files supported by the older framework until the last second.
The number of field appraisers equipped to do UAD 3.6 is so limited at this point, says Farrell, that demand bottlenecks are driving up prices for modernized reports. While older appraisals are being priced at around $550, modernized reports may cost borrowers closer to $850.
UAD 3.6 appraisals will also likely be more expensive because the new reports require that appraisers train themselves on the new data fields and spend more time at the property. On the loan side, Farrell advises brokers to anticipate an extra three to five days in processing and delivery of UAD 3.6 reports.
