The 3.6 Rollout: Chaos Now, Clarity Later?
UAD 3.6 has dominated the appraiser conversation on LinkedIn, yet the irony is that almost nobody truly understands it. That isn’t the fault of appraisers. Even the most experienced professionals and the people positioned as “3.6 experts” have more questions than answers. I recently listened to a panel of appraisers I respect immensely, and even they acknowledged the gaps. The truth is simple: people may be preparing for 3.6, but nobody is fully ready. Admitting that doesn’t make anyone less competent. It reflects the reality of the rollout.
What the industry does have is an abundance of opinions. Some defend the new structure, others condemn it. While the underlying intent of 3.6 may have merit, the rollout has been undeniably chaotic. Functional software is lagging, training has been insufficient, and critical questions remain unanswered. These issues trace directly back to the decision‑makers who pushed the system forward without adequate preparation. But assigning blame won’t solve the problem. The only productive path forward is patience.
Appraisers, underwriters, agents, and lenders will all need time to adjust. Agents will have to provide more accurate and detailed MLS data than ever before. Underwriters will face a steep learning curve and an influx of clarification requests. Lenders will need to be flexible with due dates and resist the urge to prioritize speed over accuracy. And yes, costs will rise. Any AMC or appraiser claiming otherwise should raise concerns. The workload required to produce a compliant, high‑quality 3.6 report is significantly higher than what legacy forms demanded. Quality work takes time, and time has a cost.
There is, however, a positive outcome that has received little attention. UAD 3.6 will separate the wheat from the chaff. AMCs that rely on low‑fee, high‑volume “rubber stamp” appraisers will struggle because those appraisers will not be able to hide substandard work behind the new level of required detail. While the purpose of 3.6 is to improve the quality of the appraisal report, an important side effect is that it will also highlight the quality of the appraiser. Not all appraisers operate at the same level, and 3.6 will make that impossible to ignore.
The industry has spent years drifting toward a fast and cheap model driven by private equity priorities. That model is incompatible with the demands of 3.6. Quality cannot be mass‑produced, and it cannot be rushed. Sometimes a system has to break before it can be rebuilt correctly. If 3.6 ultimately forces the industry to value accuracy, professionalism, and fair compensation, then the current mess may be the beginning of a much needed reset.
- The 3.6 Rollout: Chaos Now, Clarity Later? - September 18, 2026
- It’s Time to Take Out the Junk: AMC Practices Exposed - August 21, 2026
I have a question, what does knowing if a house has broadband have to do with appraising? Is that truly a factor of marketability? I understand in certain areas yes but come on.
Scott Taylor would you buy a house that didn’t have broadband Internet?
Tres Kirkland with Starlink available worldwide, what does it matter? I can get internet literally anywhere that I can see the sky
Justin Schubel but it is more expensive and is it as fast?
Tres Kirkland it might be more expensive in the big cities, but I can tell you from a rural area price is about equal and it’s much faster than the broadband provided in many rural areas. That being said it’s typically going to be rural properties that don’t have broadband. So when the big telephone companies are charging as much or more than Starlink, again, it becomes a moot point. Also, the point wasn’t the cost it was is it available?
I recent had a house that I flipped due to I could not get internet at the property and it was only two blocks where they had internet and being an appraiser with a home house that was a huge issue for me. When The internet provider could not get me a time frame when it would be offered.
Tres Kirkland there are solutions for that.
Tres Kirkland so are you gonna check all your comparables to see if they have broadband too?
Yes, I do. Has nothing to do with 3.6. In some counties here they transition from suburban to semi-rural very quickly as the crow flies and if Subdivision A has wired broadband it will typically sell better than subdivision B.
Starlink is 3X the cost or $1,200 a year more. You will already be dealing with a somewhat extended commute. Even the agents will note if their property has broadband and getting agents to put good data in a listing is almost a joke at this point. So they know broadband sells.
I ran into a mountain guy whom made a big deal about his newly acquired broadband line. Yes, broadband coaxial was available in the area in general. Where his rocky lot was, the line had not gone quite that far. He had been quoted 20k to 30k total line run and install costs. He was quite thrilled to report that during some introductory customer special, he talked xfinity into finally installing that line for free. Told me the guys were using pick axes and all manner of other hardware to get the line buried the long distance up to his property, took weeks to install only his line.
It’s all relative though. He could have signed up years ago and ran an overhead for a tenth the cost. Properly installed broadband? Available like municipal but not yet tapped in? Actually connected? Sure these are likely buyer concerns but it’s not necessarily going to translate as valid market adjustments.
Is broadband a protected class?
Scott Taylor well, it’s available everywhere I work. But, I can see it being an issue for some buyers.
Tres Kirkland it’s like people showing their utility bills- almost no one cares unless they are an absurd cost.
But no one advertises those.
My water bill last month was $450 dollars. I’m not sure the at home garden is worth it anymore. Next year we’re going with a tower, or boxes, something in a greenhouse if we can.
I don’t think that any house automatically comes with broadband. If there are two identical, adjacent subdivisions with identical houses and one subdivision has available broadband and the other doesn’t, it could be something of a factor. But, it’s become less and less of a factor by the minute.
Scott Taylor Does municipal water and sewer vs septic matter or cisterns? Do you review that information regarding the subject and the comparables? How about public roads vs private roads?
In areas where buyers are looking to work remotely, might this be an issue ??? How about communities where smart homes are an in demand or an important factor?
Howard Klahr exactly my point.
Howard Klahr I only use comps with similar utilities. More than likely houses within the market area will be similar but in a 1 mile radius of my town there is water/sewer and well/septic and some with paid assessment for city utilities and done that owe over $35,000. Those things matter
I know right?!!!
The collection of more irrelevant data points has fk’ng ZERO to do with the accuracy of the appraisal value or analysis. True analysis is determining what the MARKET values. A stupid form designed to feed a stupid algorithm is doubling down in stupidity. Coming from the company who’s greatest accomplishment is destroying the world’s economy….. Fannie Mae…. Who’s surprised?
They’re collecting those data points to simply get rid of us completely. They’ll input all of the data points into a regression analysis and that will be that. But, there will still be some guys around who always “make value” and the rest of us will be sitting on the front porch pettin’ the dog.
beautifully said.
Well the elephant is out of the room. It is patently clear that neither the lending industry or AMCs are prepared to discuss fees associated with UAD 3.6 compliant reports prepared properly. Without talking about specific fees, UAD 3.6 is going to triple the fee and no amount of running a quote auction is going to cure that.
Real estate appraisal is more about collateral verification and making a loan sellable than value.
Don’t count on it. Picked this up at the appraisers forum. Since this summer there has been an endless stream of appraisers whom lament how rude their amc’s are becoming, with refusal to allow fee raising. Turns out they have no special value to the amc, other than providing the amc’s business profits, and are instantly replaceable vendors. Imagine that.
Here is a question. What is going to happen when 2.6 appraisals are not fed through the system in time? Who is going to be “FALSELY” blamed? Are lenders and AMCs going to attempt to demand that appraiser redo the appraisal in 3.6 for free? Appraisers, stand your ground. Do not work for free, or peanuts. You and your expertise matter.
I’m curious whether any appraisers are still accepting assignments at $300–$350. I work exclusively with the VA, and since they set the fees — currently at $650 in my area — I’m satisfied. I’ve never worked for an AMC. The VA hasn’t announced a move to 3.6 yet, but once they do, I expect the fee to increase accordingly. In my experience, the VA has always been fair.
Good old VA. Veterans still to this day deserve sensible fair process in mortgage lending.
The rest of the American consumers? They don’t deserve anything similar what so ever.
Totally different processes. As the wealth of this country continues to be extracted, sent directly to institutional investors via the Whole Loan Sales program. As they continue to park corporate level money into residential housing.
I don’t think the EO on homes are for main street not wall street properly addressed the complete range of issues.
I’m not accepting any work, period. Sick of it. Last USPAP course when they harped on racism and protected classes was it for me.
Every single course seems to include fair housing. We get it already.
VA here as well. $700 for a basic report now. I ONLY work for the VA and attorney’s (private cases). More then enough work to keep me busy for as long as a I want. If the VA does in fact go to the 3.6 reporting……I WILL stop. Old enough to receive social security and invested for 30+ years. It WAS good….being an appraiser. The 3.6 format is nothing more than a glorified form filling job. We all know “they” will offer appraisers less money one way or another.
I think we will see flood gates open to private mortgage companies who will not have to use UAD 3.6. This is a FANNIE/FREDDIE thing.
In the article it stated “Agents will have to provide more accurate and detailed MLS data than ever before.”
We almost fell out of our chairs laughing.
Chaos. Disorder. Confusion. Anarchy. Bedlam. Turmoil. Mayhem. Havoc. Wishful thinking. Pipe Dream. Pie in the Sky. Fool’s Paradise. Delusion. Fantasy. Utopianism. Impractical. Humorous.
These…………are the words to describe the 3.6 rollout.
The end.
Yeah, I get a kick out of every comment I see that indicates agents are going to do more.
My thoughts exactly. I’m still laughing.
Logan has a rather positive outlook on the new forms. He’s an optimist. We need more optimists around. If only this could be true.
The seemingly impossible hypothesis; appraisal management companies will prioritize quality over speed and fee skimming profits. They will fit in the higher quality appraisers into service rotation more often. Because they care about the product quality. The long term viability of the valuation service industry and are not just predatory companies extracting profits and destroying small businesses like venture capitalists.
Let’s check in on the outsourced appraisal typing service guys and see what their take on 3.6 is. They provide the service that facilitates a substantial portion of the fast and cheap model.
Well this is odd. Not even mentioning 3.6. Ran this search on startpage; Appraisal typing service. Not appraisal chief, suntel, appraisal data entry service dot com, vdt data solutions, om data entry india, there is a lot of these. Not gosourceval (hey, that’s a website copy of the other one!) Many many more.
Found one.; ieimpact
https://ieimpact.com/blog?post=uad-3-6-required
Learned absolutely nothing. They’re good at taking up page space.
I’ve never looked at this. Check out the prices. Full time for less than a thousand a month or $6 an hour. What kind of American would go for that when they could hire local people and train them instead? No wonder there is a shortage of appraisers.
https://www.outsource2india.com/DataManagement/pricestructure.asp
This is the end result of the structural changes the amc industry caused to happen with their fast and cheap, disproportional assignment model. If we could have had the IVPI, a VA like rotational distribution to fairly and equally compensated appraisers, we’d have a hundred thousand more licensees, better product consistency. Appraisers would not have been enticed by greed to undercut others fees, and claim more work for themselves. Appraisers would have instead continued to follow traditional small business models, hiring locally, training their helpers. All they would need is to be approved on their local mortgage lenders appraisal panels, they’d get a fair share of work, and attention to detail would have remained the top priority.
This is an insightful line of research. It appears that the AI driven automated form filling software may replace the outsourced appraisal typist service. All these guys will need is the basic data assimilation, automation runs the rest all the way to the finish line. And they still will not hire or train new appraisers.
It is the structure of the disproportionately distributed appraisal order assignments which is the root cause of lacking work quality, as well as continued appraiser attrition. The imbalanced distribution is what facilitates and encourages the fast and cheap model. It does not matter how careful, accurate, skilled, or attentive the appraiser is. Because these other appraisers using these tools have infinite scaling capability to handle more orders. They’re counting cash, flipping volume, not caring about work quality or the effects lackluster fulfillment has on consumers.
When amc’s send more work to lower priced appraisers, the amc profits more, has continued incentive to cut everyone else out and only work with those types of firms. The model is so well established, these firms have now gone national, handling the complete work load of multiple top originators at one time. Some of them are cutting the amc’s out, acquiring work directly from the lender, bypassing amc licensing even though their activity falls under guidelines they register as an amc. If the francised appraisal firms and amc’s are allowed to continue with preferential assignment practices where grossly disproportionate assignment volume remains the status quo, they will most likely continue to do so.
Missing the IVPI Proposal yet? That was where all GSE work would have been distributed in a relatively equal fashion similar to the VA model, and relatively uniform customary and reasonable appraisal fees. The model entailed the act of appraisal distribution being a non profit enterprise. To prevent exactly what we are dealing with today with amc’s.
https://www.workingre.com/wp-content/uploads/2013/08/IVPI-Proposalfinal.pdf
The entire regulatory structure for appraisal valuation activity was predisposed to expect appraisers would not be employees, would be independent, and would be compensated fairly, with fairly distributed assignments. The failure of the amc industry lies in their disproportionate distribution modeling. What’s your fee and turn time?
You forgot to add clister-f&$k to the words describing 3.6
Forget the additional data required on the 3.6….look at what is MISSING. NO market analysis or check boxes for “Declining, In Balance, Appreciating”. NO Flood Map data or Flood Maps. NO Census Tract (yeah, no cares about this one), NO competing PUD information, and more. I spent my 1st order searching for where to put standard data, and there isn’t a place for most of it.
This is bizarre, considering Fannie Mae was pushing for detailed market analysis and time adjustments not long ago.
I’ve heard this 3.6 form is built to be read by AI, a counterfeit system in itself.
The missing, relevant data seems to be eliminating informaton that limits home loans, such as declining markets and requiring flood insurance.
The 3.6 is not providing a quality, professional appraisal report and analysis, the appraiser would have to keep pertinent data in the workfile, and/or try to include it somewhere in the “Supplementary” pages. In any case, the lender or underwriter would not readily see the appropriate analysis that isn’t included in the form.
3.6 is graded a “-F”, go back and start over, this won’t pass.
NOT USPAP compliant, in spite of demanding the “front door’s elevation above grade”.
Increased loan volume is the name of the game. When defaults happen, they’re monetized on the back end by the institutional investors whom are granted special privileges and first purchase opportunities at firesale pricing.
https://appraisersforum.com/forums/threads/fannies-own-statement-about-waiver-value-acceptance.243114/page-60#post-3633692
The big picture…. To clarify in the context of this other lateral conversation elsewhere.
We’re putting in the work for consumer protection primarily.
If proper valuation was the ultimate goal, they would pattern the new forms after something like the ERC form, where those Clients do care about quality of valuation.
If they want to wash out the bad appraisers, stop awarding work to the lowest bidders.
I’m not sure the point is to wash out bad appraisers. Im just saying it may happen…. but I’m not holding my breath. The industry is splitting in half. One half being AMC’s and dirt appraisers who are focused on volume and speed, PDC’s and Parea appraisers who will do for a nickel what I certified appraiser wouldn’t do for a dollar.
The rest of us are holding the line, but eventually I think this ends up in a divorce. GSE’s will go the direction of the cheap and fast and us on the other end will find ways to do our job more in line with quality.
They want to wash out ALL appraisers.
40% fee increase. Double the ETA
Donald J. Martin it’s hard to do that when the reps from Fannie and Freddie are telling the public that this is not necessary. Absolutely absurd that they expect so much more work and don’t think the appraiser should be paid a fair fee for all this research, analyzing and reporting.
I have over 40 years close to 45 in this profession, I took over my father’s business. He was an SRA and so was I though I retired that designation a few years ago as it didn’t seem to make much difference . I have kept my RA designatin with the MBREA. This is my second career with the first being a teacher of hearing impaired, Masters from Smith College, then a Director of Special Ed. I grew up partially in New Rochelle, NY and then in the Berkshires of MA from about age 12 on. We had a small horse farm. I skied and was a mountain ambassador for years at Mt Snow in VT. I was one of the last Presidents of the WMASS Chapter of the Appraisal Institute before it was shut down.
The worst came a few months ago when I appraised a condo in VT, 3 units, in a 140 y.o. building. No land went with the units… clearly stated and there was no lease. I asked the broker, lawyers to please describe the type of ownership — All said to just check Fee Simple that’s what everyone has done over the past 20 yrs. I explained it’s not that simple. The Regional Director for the National Lender told me to check Fee Simple AND Leasehold– no one care…….. I was shocked… The broker, whom I’ve known a long time was on board now when I explained my job is to protect the buyer and the bank’s interest… what if the building burns down? or the owner of the land dies or goes bankrupt? How are the owner’s protected? Well, I took a couple of days…. dug and dug…. I found something called Condominium Open Space Fee Simple ownership which described all the right of ownership being the same but without the land. I could not get any lawyer to confirm or address this. Everyone, including the banker said, just check it. It’s in my work file. It’s clear to me formerly as an educator and for years now an appraiser, that the lack of accountability is massive. I have seen examples where someone could not re-build because they actually did not really own the property etc…….
Yes, I am not learning the 3.6. I have private work and some small lenders who don’t sell to FNMA and don’t intend to even look at the form. How soon we forget. FNMA who brought you the Crash of 2008 along with help from Bill Clinton with the Gahamm-Leach-Bliley Act 1999 which over rode the Glass-Steagall Act 1933 which put major regs on banks so that a severe depression would not happen again….. Read the books on the Crash of 1929 & 2008. Appraisers in the early 2000s were blamed but it was Wall St, Banks….. I have tons of knowledge and experience but no one cares.
I have a wealth of experience, tons of knowledge and I am stunned how that is disappearing. I see younger appraisers who call for a slate roof, in good condition, to be removed because it’s ‘old’. For white paint inside a barn to be scrapped and repainted… .not paint but white wash. The list goes on.
So you really want me to scientifically be able to support every little thing? Then you do not want an Opinion of Value, which should be a range anyway. You want an analysis with a formula and an end conclusion. You seriously cannot replace what I have in my head. My knowledge……… That barn has significant value as there are many people with horses here and other barnyard animals. That small airplane hanger can be converted into an indoor arena, storage for the many tourists who leave vehicles here through he winter or summer depending… is the property near a ski resort or a lake resort… for those boats…
You have no idea. The older appraisers will leave as many professionals now are too young to know lacking the education and experience — this includes the bankers, brokers/agents, lawyers, realtors and the young appraisers. This is sad but this is the way many professions will go. Do you really believe ANSI is how the market views real estate? Appraisers know it is not. But we go along….. and wait
Great post. The brain drain continues. Nobody new will get the experience either. Waivers make sure the every day work which leads to qualified skills in the future, never happens. Like appraisers will instantly appear by way of watered down standards and be ready for complex challenges. I won’t even take complex work anymore, because of the distribution disparities. I’m not covering only hard work so the discounters can cherry pick all the easy stuff. The amc model ruined the entire industry. There is no safe place outside of mortgage lending, the new model is coming for everyone.
I think you all have taken your eye off the ball. Regulation is State controlled so the Assessing community is coming in the back door getting full experience credit for assessing and taking the test. There in lies the dilution of the industry.
“This too will pass”
Its a good thing that the Dustin Harris’s of the world have been training appraisers to build their business around the churn and burn of working with AMC’s (I know Dustin, only the good ones). UAD 3.6 is and will be a disaster.
Off topic, but for those keeping track at home Dustin Harris The appraiser Coach is a liar.
On Oct 20, 2024 Dustin released a podcast “The 1,000th Episode With Secret Guest” where in it he did a +/- 15 minute interview claiming to be speaking with me. He was not speaking with me and at no time did he indicate to his audience that he was not speaking with the real Bill Johnson.
As the above statement is true, this needs to be disclosed to the readers here.
Seek the truth.
File complaints on him. Might have him for misrepresentation. The guy is a slimebag. On his resume he went to christian college or claims to have been part of faith based organizations. Something like that, I can’t remember. He’s a snake oil salesman. Devil in disguise. Can never have enough, always needing more.
How to shut down competition, drive Americans out of jobs, support third world outsourcing, and claim famous top tier status. All you have to do is look the other way on systemic amc billing fraud and be morally comfortable with putting independent small businesses out of business by the tens of thousands increments over two decades until you’re the only one left. Appraisal Coach really did that. Sling let’s you do that. It’s hard to lay too much blame only at his feet. He’s only following the business model of about half the trade groups top managers, whom are all entangled in the amc industry with conflicts of interest as long as the longest day. They set up the entire thing where there was no longer equal work distribution, which allowed for amc undercutting and billions of dollars of fee raking. This industry has been pretending for decades, independent workers have been set up and exploited this entire time.
https://appraisersblogs.com/fannie-mae-releases-the-new-urar-redesign-spec/#comment-46894
Considering the podcast was from nearly 2 years ago and this is the first time I’ve publicly commented about it you can tell he is not on my mind, but the thought that I’ve been living rent free in his head for over a decade is hilarious.
Dustin, I know your reading this, so can we get a follow up to your blog from April of 2016? https://appraisalbuzz.com/never-had-a-raise-in-20-years/
I would love to hear you defend the lenders and AMC’s regarding their silence in paying C & R fees over the past 10 years and your spin on how great it will be to spend twice as much time on UAD 3.6 product for the same pay.
Seek the truth
what steps did you take to handle that? That is a hot mess. Please blast this info (assuming true) and call him out on it publicly.
Any takers on my bet that the average AMC fee for completing UAD 3.6 assignments will grudgingly rise to $350?
Why? Residential appraisers are the only known human beings on the planet to walk about without spines.
https://www.hud.gov/sites/default/files/SFH/documents/Modernization-of-FHA-MPRs-in-HB-4000.1-Drafting-Table-REDLINE.pdf
Proposed updated HUD guidelines, redline version. (save this as a pdf, they remove redline versions online after changes are confirmed. You may want to keep this as a handy reference.)
This is neat. Don’t worry about fee simple anymore; Fee Simple refers to an absolute ownership “that is the broadest property interest allowed by law, without durational limitation” If it’s hypothetically possible to be fee simple, pass it.
Mixed use commercial residential, now includes non residential in total area credit. “Total Floor Area refers to all Residential Space and Commercial/Nonresidential Space.” If it’s character resembles residential in some form or another, entire thing is residential for valuation purposes.
Pg 101. It’s official, finally. C5 is not eligible. No more fha financing on mildly run down properties unless full participation in the 203k programs are confirmed. If you remove horrendous floor covering to prep for a future improve, your loan is denied. But if you leave that run down floor covering there, might still be approved. Genius.
Pg 116. Look, we need to go to lunch. These are appraisers problems anyways, they’ll figure it out. Copy everything from FNMA. Minimum property standards are gone. Property eligibility criteria is the new standard. Mission accomplished.
No more appraiser testing of anything, running water, flushing toilets, observing hvac or water systems, etc. Take a guess. If it looks good enough, it is good enough. Water stained ceilings, inadequate attic assess? Simply ignore the issue. Don’t worry about distance requirements of well or septic anymore. You want a loan on a lava flow area? Approved.
Consumer protection mechanisms from predatory lending and seller misrepresentation? What an antiquated idea. We need more loan generation and we need it now.
Consumer protection is no longer what industry rules and regulations revolve around. Consumers will need to get into the loans, before they are informed there are problems. Brilliant.
The 3.6 is overly segmented and made complicated. The notion that it will be easier to read for the end user perhaps it is true. The same does not hold for the Appraiser. Irrelevant information, even different fields for the first and last names Too many drop downs, click,click, click, APN added plus MLS# and the grid itself is another piece of work with multiple, partitioned segments. If we didn’t have to put food on the table, pay our bills and live our lives, I would suggest a nationwide boycott, let the GSE’s feed into their models all the data mined from their 2.6 and their ‘value acceptance’ appraisals and have at it.
IMHO this whole danded thing is just another concoction by the GSE’s to establish the appraiser as the bad guy when we refuse to “fall in line” with their bullsheedo. After 20-30% of us either retire or refuse to do the 3.6 appraisal being crammed down our throars, they will just try and make us the fall guy agian, Just like it was back in 07-09. Remember that BS! 3.6 was designed to help the GSE’s scour data, and that’s it. It does not help the consumer, make anything (easier to read) let alone understand. It does not advance the industry, it futher serments it. But that is what they want, so they can eventually iae AI to generate a “value acceptance score” for the borrower.
I agree with a lot of this. At this point I wouldn’t be surprised if the 3.6 rollout keeps getting pushed back and pushed back. There are still too many unanswered questions, software issues, and people who are supposed to be preparing for this who don’t even seem to have clear answers yet. I do agree that if it eventually forces the industry away from the fast and cheap model and puts more value on quality appraisal work, that would be a good thing. But right now it definitely feels like they’re trying to roll this out before the industry is actually ready for it.