Certification 25 and the Quiet Breach of Appraiser Confidentiality
A peer sent me Phil Crawford’s new podcast episode this morning, and I opened it without thinking much of it because I had assumed his retirement from the show meant he was done weighing in on industry developments. I have been following the news and the chatter around 3.6, but I haven’t been preparing for it. I have not taken any UAD 3.6 classes, have not attended any seminars, have not tested the form, and have not sat down to study the certifications line by line. I know the broad strokes of 3.6 and I know exactly why I refuse to participate in it, but I have never examined the fine print. So when I started listening and heard Phil’s tone shift from casual conversation to genuine alarm, I realized immediately that he had found something significant. Once I saw the screenshots of Certification 25 and 26 that he was talking about, it became clear that I had missed a critical change simply because I had never looked closely at the new “form”.
Most appraisers who follow my writing already know that I will not touch UAD 3.6. I have said it repeatedly and without hesitation. I have written about the direction this profession is being pushed, the fixation on data extraction, and the slow dismantling of the appraiser’s role. I covered it in “Flags Over Facts: The Road to Obsolescence” and again in “The Appraisal Profession’s Perfect Storm: A Veteran’s Take on a Dying Craft“, and everything I wrote then feels even more relevant now. But even with all of that, I had not seen Certification 25. I had no idea that two sentences had been added that fundamentally alter the relationship between the appraiser, the report, and the data collected inside the home.
In UAD 2.6, Certification 21 already allowed lenders and agencies to distribute the appraisal report without the appraiser’s consent. It was broad and uncomfortable, but it did not breach USPAP confidentiality, so appraisers let it stand. The new version in 3.6 keeps that same language but adds something entirely different. It allows the entities who receive the appraisal report to store, copy, reproduce, analyze, use & distribute all of its data for internal or external purposes without ever obtaining the appraiser’s consent. It applies to the entire report, including assignment results and interior photographs. It is not limited to physical characteristics. It is not limited to non confidential information. It is not limited to facts. It is everything.
Phil’s reaction made sense. He pointed out that USPAP requires appraisers to take reasonable steps to protect confidential information, yet Certification 25 asks the appraiser to certify that once the report leaves their hands, the data can be replicated and redistributed indefinitely. He questioned how an appraiser could sign that and still claim to be compliant with the Ethics Rule. He also questioned how any appraiser could believe that the sentence claiming they have no liability for misuse of the report would actually protect them if something went wrong. A certification is not a contract. It is a unilateral statement. It does not shield you when a homeowner discovers their child’s bedroom photos circulating somewhere they never consented to.
Listening to him, I kept thinking about how many appraisers have been told that 3.6 is simply a modernized form. I kept thinking about how many have been told that the changes are harmless or procedural. I kept thinking about how many have been told that the profession is evolving and that resistance is unnecessary. Yet here we are, with a certification that openly permits unrestricted data use by third parties, including agencies and jurisdictions that have nothing to do with the original assignment. Phil even raised the possibility of assessor offices using interior data to justify property tax increases, which is not far fetched in the current climate.
The most striking part of his episode was not the alarm in his voice but the silence he described from the organizations that should be addressing this. He said the Appraisal Foundation has offered no guidance on how appraisers can remain USPAP compliant under Certification 25. He said lenders and mortgage departments are unprepared for the implications. He said the rollout is happening in a matter of days, yet the profession is being asked to sign off on something that directly conflicts with long standing ethical obligations.
For me, this episode confirmed what I have been saying for years. UAD 3.6 is not about clarity or modernization. It is about data. It is about building massive property information repositories that extend far beyond valuation. It is about turning appraisers into data collectors for systems that will outlive the assignment and outgrow the profession. Certification 25 is not a small tweak. It is a declaration that once the appraiser enters the home, everything they document can be stored, copied, reproduced, analyzed, used and redistributed without limitation.
Phil ended his episode by saying that if appraisers sign Certification 25 without challenge, they are agreeing to a new definition of confidentiality. I agree. This is not a technical update. It is a shift in the foundation of the profession. And if appraisers do not understand what they are certifying, they will find out later, when the consequences arrive, that they signed away far more than they realized.
- Certification 25 and the Quiet Breach of Appraiser Confidentiality - September 29, 2026
- When Solidifi Tried to Silence Samnick - August 11, 2026
- Honoring Jan Bellas, Our Greatest Advocate - July 13, 2026
