Who Controls Access in UAD 3.6

Today’s Tom Sawyer, he gets high on you,
and the space he invades, he gets by on you.

Those words feel strangely appropriate as the appraisal profession moves into UAD 3.6.

The new appraisal environment is not simply a revised form. It is a data-rich, data-driven system built around large amounts of property information being routed directly into appraisal software.

Matrix MLS systems already exchange structured data through API-based pathways using standards such as RESO, OData and JSON. The infrastructure for moving structured real estate data between systems already exists, which raises an obvious question: why can the appraiser’s existing MLS not feed directly into the 3.6 reporting environment in the same way other data sources do?

Instead, the appraiser is expected to work through a separate vendor data feed, even though professional MLS access is already being purchased and maintained as an essential part of appraisal practice.

MLS access is not optional overhead. It is the working marketplace where appraisers research sales and listings, review photographs and property histories, study market exposure, track competing inventory, and identify the agents directly involved in transactions.

On active and recently listed properties, the MLS may also provide showing instructions, appointment scheduling, agent contact information, and access through electronic lockbox systems. In many markets, the listing agent may not even be located near the property. MLS and electronic access systems therefore serve not only as research tools, but as part of the practical infrastructure that allows inspections and assignments to move forward efficiently.

The retrospective depth of the MLS may be even more valuable. In some markets, the historical record reaches back decades and can include prior listings, earlier sales, old photographs, price changes, status changes, days on market and long-term market statistics. That gives the appraiser a historical view of how properties were exposed, marketed, changed, withdrawn, relisted, and ultimately sold over time.

That depth of market context is difficult for a newly assembled third-party data system to duplicate. Comparable selection is not simply a matter of choosing properties from a data list. It requires understanding how those properties actually competed, how they were exposed to the market, and why they ultimately sold as they did.

What you say about his company
is what you say about society.

Catch the witness, catch the wit,
catch the spirit, catch the spit.

In today’s appraisal practice, MLS access is not a luxury that can simply be dropped because a software vendor offers its own data package. The MLS is the appraiser’s established professional workspace, built around years of accumulated market intelligence and day-to-day use by the people actually participating in the market. Its value is not simply the number of records it contains, but the continuity, depth, and context those records develop over time.

A separate “big data” layer does not replace that working environment. It sits on top of it. The appraiser already has access to the underlying market data through the MLS, then pays again for a vendor to repackage and route that information into appraisal software. The aggregate data we tested included sales from 2024, non-MLS properties, and obscure listings that could not be verified as having received proper market exposure.

The added cost is difficult to ignore. In my case, the west coast coverage area requires membership in two overlapping MLS systems. Neither can simply be dropped because the markets they serve overlap rather than divide neatly at a geographic boundary. Maintaining complete coverage therefore requires paying for both systems, along with electronic property access. Together, those recurring costs total $2,030.88 per year before appraisal software is even considered. When combined with the $2,988 annual cost of the top-tier software package, the total reaches $5,018.88 per year.

An appraisal software package that cost $648 in 2025 now costs $249 per month, or $2,988 per year, with vendor-provided data. That represents a 361% increase in annual software cost, not for an entirely new professional tool, but for access to a 3.6 workflow that places a separately priced data layer on top of information the appraiser already pays to access through the MLS. At that rate, the profession becomes increasingly dependent on systems and data channels appraisers had little role in designing but are nevertheless expected to finance and use.

The important point is not simply that software has become more expensive. Software changes, development costs rise, and new standards require new work. The question is what the appraiser is being asked to pay for. In this example, the combined annual cost of MLS access, data, and appraisal software reaches $5,018.88. That burden lands on a profession already operating under significant fee pressure, while other participants in the real estate transaction receive substantially greater compensation from a single closing.

Appraisers are expected to absorb major changes without having a meaningful role in shaping them. New reporting standards, software requirements, data systems, portals, and delivery platforms are often introduced as finished products. By the time the appraiser encounters them, many of the most important structural decisions have already been made.

That pattern is particularly difficult in a prolonged elevated interest rate environment. Assignment volume has fallen, margins have narrowed, and nearly every business providing a necessary service to the appraiser has increased its cost. Software costs more. Data costs more. MLS access costs more. Delivery costs more. The appraiser is expected to absorb each increase while working in a market producing fewer assignments.

What has not kept pace is the appraisal fee itself. The cost of an appraisal today can remain remarkably close to what consumers paid decades ago, despite enormous increases in housing prices, operating expenses, technology requirements, regulatory demands, and the amount of information expected in the finished report. Rather than allowing professional fees to respond naturally to those increased demands, appraisal procurement has increasingly become a commodity bidding process in which price and turnaround time can overshadow experience, competency, and professional judgment.

Modernization should not mean imposing additional costs, systems, and obligations on the professionals responsible for making the process work. If the new environment depends on required data structures, required software, required delivery systems, and additional layers of expense, while the appraiser has little meaningful role in shaping any of them, then modernization begins to resemble compliance rather than collaboration.

No, his mind is not for rent
to any god or government.
Always hopeful, yet discontent,
he knows changes aren’t permanent,
but change is.

The cost and control questions lead to another issue that deserves closer attention: who actually retains custody of the completed appraisal report?

For decades, appraisers have maintained their own report archives, often preserving complete reports for many years on computers, servers, and hard drives under their own control. Under the emerging 3.6 workflow, that will change. The appraiser may retain a ZIP package or exported data file while practical access to the completed report remains tied to the vendor’s platform and a continuing software subscription.

That distinction matters because the appraiser remains the professional responsible for the analysis, certification, and conclusions contained in the report. Electronic record law recognizes that required records must remain accurate, accessible, and capable of being reproduced for later reference, and appraisal recordkeeping requirements reinforce the same principle. USPAP establishes a five-year retention framework, and many states, including Washington, incorporate similar requirements. If the appraiser remains responsible for preserving and producing the record years after delivery, practical access to the completed appraisal should not depend on maintaining an ongoing paid relationship with a software vendor.

The practical problem becomes even clearer at retirement. Appraisers may continue to face professional liability exposure after they stop accepting assignments, which is one reason extended E&O protection is commonly maintained for a period after retirement. Yet if access to completed reports also requires continued payment to a software vendor, the retired appraiser may have to preserve a commercial software relationship simply to maintain practical access to prior work. At the top-tier rate of $249 per month, five years of continued access would cost $14,940.

That raises a fundamental question about professional recordkeeping in the new environment. The appraiser may remain responsible for the report years after delivery, but practical custody of the finished record may rest with a third-party software provider. Modernization should not create a system in which professional responsibility remains with the appraiser while access to the professional record depends on continuing payments to someone else.

HARBOR approaches modernization from a more informed perspective. The goal is not to reject UAD 3.6, but to build the reporting environment around the way appraisers actually work. Rather than forcing the appraiser to rely on a generalized vendor data feed, HARBOR would connect the appraiser’s existing MLS directly into the 3.6 reporting environment and allow the appraiser to work from the market resource already being paid for, understood, verified, and relied upon.

That distinction matters because appraisers do not simply pull sales from a database and begin adjusting them. Comparable selection requires understanding market exposure, listing history, photographs, condition, prior sales, competing inventory, agent participation, and the circumstances surrounding the transaction. The aggregate data we tested included 2024 sales, non-MLS properties, and obscure listings where proper market exposure could not be verified.

Being asked to select comparables from a generalized data list is not a realistic substitute for that process. A property may appear suitable based on raw characteristics and still prove to be a poor market substitute once the underlying transaction and market context are examined.

HARBOR will place the appraiser’s existing MLS, professional judgment, and control of the finished work product at the center of the 3.6 environment. Technology should improve the appraiser’s access to information, not replace market context with volume or force the profession into a workflow designed without meaningful appraiser involvement.

If appraisers want a meaningful voice in what comes next, quiet agreement is not enough. The profession needs people willing to step forward, examine the model, challenge it where necessary, and help shape a system that reflects the realities of appraisal practice.

The Housing Appraisal & Risk-Based Oversight Registry gives that effort a place to begin. The Pilot Program is where the ideas can be tested in practice. If the direction makes sense to you, come take a serious look and help shape what comes next.

By Joseph Foster (Cactus), Certified Appraiser and HARBOR Director