The appraisal industry’s transition to the Uniform Appraisal Dataset (UAD) 3.6 continues to move forward. With the official November 2, 2026 mandate date fast approaching, market participants — from lenders and appraisal management companies (AMCs) to tech vendors and appraisers — are working to finalize implementation.
To accommodate lenders requiring additional time to finalize their technology integrations and operational processes, Fannie Mae and Freddie Mac (the GSEs), have released a joint policy exception framework.
November 2, 2026 remains the UAD 3.6 mandate date, but sellers with an approved policy exception may temporarily continue submitting UAD 2.6 appraisals.
The GSEs designed this flexibility intentionally to give lenders breathing room and protect borrowers from pipeline disruption, all while holding institutions accountable to a firm transition plan. Here is a breakdown of what the policy exception entails and why remaining on track with UAD 3.6 adoption is critical for your bottom line.
What is the UAD 3.6 policy exception?
The GSEs’ policy exception allows approved sellers to temporarily submit legacy UAD 2.6 appraisal reports beyond the November 2, 2026 deadline, provided they obtain approval for an exception and execute an agreed-upon implementation plan with each applicable GSE.
Key guidelines for the exception include:
- One-time exception: The GSEs have made it clear that this is a one-time exception that will not be extended.
- Target audience: Only direct GSE-approved sellers are required to submit exception requests, which must be submitted separately to each applicable GSE they sell to. TPOs and lenders not selling directly to the GSEs must coordinate directly with their investors.
- Aggregator responsibility: Lenders that buy loans from correspondent partners or third-party originators (TPOs) and sell them to the GSEs must ensure all appraisals being submitted are UAD 3.6 appraisals— otherwise, the aggregator must request the policy exception themselves.
What is the UAD 3.6 policy exception timeline and key deadlines?
Sellers operating under an approved policy exception must navigate a phased sunset of UAD 2.6:
| Phase | Status | Key impacts & restrictions |
| November 2, 2026 – February 28, 2027 | Policy exception period | Sellers with an approved exception may continue submitting UAD 2.6 reports to the Uniform Collateral Data Portal® (UCDP®). The GSEs strongly encourage implementing the use of UAD 3.6 appraisals by the end of this window. |
| March 1, 2027 – May 19, 2027 | Reduced functionality period | UAD 2.6 reports are still accepted, but risk scores will default to “999” in Fannie Mae’s Collateral Underwriter® (CU) and “99” in Freddie Mac’s Loan Collateral Advisor®. Loans will lose eligibility for collateral representation and warranty (R&W) relief for value. |
| May 20, 2027 | Mandatory UAD 3.6 cutoff | Mandatory use of UAD 3.6 goes into effect for all initial appraisal submissions. |
| May 20, 2027 – June 27, 2027 | Pipeline revisions only | UAD 2.6 is only permitted for resubmissions of previously submitted 2.6 appraisal reports. Any new UAD 2.6 submissions in this window will get an unsuccessful status in UDCP with a fatal message in the SSR. |
| June 28, 2027 | Full UAD 2.6 retirement | Complete retirement of UAD 2.6; no legacy reports will be processed. |
What are the operational risks of delaying UAD 3.6 implementation?
While the policy exception provides a fallback plan, delaying implementation introduces friction into workflows:
- Contractual requirements: Requesting an exception requires binding commitments to revised contractual terms and a final implementation plan with each applicable GSE, signed by a representative authorized to enter into a binding contract.
- Loss of representation and warranty relief: Loans secured by UAD 2.6 appraisal reports submitted beginning March 1, 2027 will not be eligible for collateral representation and warranty relief for value.
- Friction in vendor networks: Lenders buying or selling in secondary markets risk pipeline bottlenecks if vendor networks are aligned on different timelines.
How can Clear Capital protect your appraisal pipeline during the UAD 3.6 transition?
Lenders that are ready should keep moving forward with UAD 3.6 appraisal submissions by the November 2 deadline. For those who are taking the exception, use this time to lock in a plan to test systems, confirm AMC and panel readiness, and train your team well before March 1, 2027. Navigating industry-wide technology shifts doesn’t have to strain your operations. Clear Capital is already in active, nationwide UAD 3.6 production.
As of October 23, 2026, Clear Capital has completed 2,900+ UAD 3.6 appraisals across 48 states. Here is what we are seeing:
- Proven scale & network: 99% of our appraiser panel is active for UAD 3.6 orders, with only 3% of UAD 3.6 orders reverted to UAD 2.6.
- Faster turn times: High-volume vendors experience a 28% improvement in turn times.
- Less rework: A 53 percentage point drop in revision requests, backed by built-in QC automation (ClearAVM™ and comp analytics, Restb.ai photo analysis, and direct UCDP and UAD compliance integrations).