Home/Field Notes/Is 3.6 delayed?
Fannie Mae and Freddie Mac announced a temporary policy exception on 30 September 2026. It is being reported as a delay. It is not one — the mandate date is unchanged, and the relief is something an individual lender has to apply for and sign for.
Published 30 September 2026
On 30 September 2026 Fannie Mae published a lender letter, Temporary Policy Exception for Lenders Unable to Meet the UAD 3.6 November Mandate, and Freddie Mac issued a parallel announcement. The headlines that followed within hours described a delay to May 2027.
That is not what the documents do. The mandate date is untouched. On 2 November 2026 the requirement takes effect exactly as published, and a lender that has done nothing is bound by it.
What the GSEs created is an exception a seller applies for. It is not automatic, it is not industry-wide, and it is not granted by default. A seller has to request it from each GSE separately, acknowledge in writing that it cannot meet the mandate, and accept revised contractual terms to get it.
A delay moves a date for everyone. This moves nothing. It lets particular lenders buy time by contract, individually, on terms that get worse the longer they take. Those are not the same thing, and a file does not care which one people are calling it.
| Date | What happens |
|---|---|
| 2 Nov 2026 | Mandate takes effect as scheduled. Without an exception, UAD 3.6 only. |
| 2 Nov 2026 – 28 Feb 2027 | Approved sellers may submit either dataset |
| 1 Mar – 19 May 2027 | “Reduced functionality period.” Approved sellers may still submit 2.6, but Fannie Mae’s Collateral Underwriter returns a risk score of 999 and Freddie Mac’s Loan Collateral Advisor returns 99, and the loan is not eligible for collateral representation-and-warranty relief for value |
| 20 May 2027 | The exception window closes for new UAD 2.6 submissions |
| through 27 Jun 2027 | Resubmissions of previously delivered UAD 2.6 reports continue |
| 28 Jun 2027 | No UAD 2.6 appraisal reports will be processed. New submissions return a failure status and fatal error messages. |
Only sellers with a direct relationship to a GSE request the exception. An aggregator buying loans from third-party originators does not request one on their behalf — it has to ensure its originators either submit UAD 3.6 or obtain exceptions of their own. A requestor has to commit to an implementation timeline, identify what is blocking it, and coordinate its vendors and appraisers before the exception expires. It is an undertaking, not a form.
Read the March window carefully. It is not a grace period. A 999 risk score and the loss of rep-and-warrant relief are a cost applied to every loan delivered that way, which is a fairly direct statement of how long the GSEs expect anyone to need.
The practical consequence is not that anything gets easier. It is that both datasets will be in the field at the same time for roughly seven months, and which one a given assignment needs will vary by client rather than by date.
The order form already tells you, and this is where an appraiser who has not kept current is exposed. Under the redesign there is no 1004. Freddie Mac’s FAQ states it plainly: the data describing the subject property drives the report, not a form type or number. The legacy forms — the 1004 and 70, the condominium reports, the exterior-only reports, the manufactured home report, the small residential income report — are consolidated into one URAR that expands or contracts to fit the property.
So the order stops naming a form and starts naming a scope. UAD 3.6 supports traditional, hybrid, desktop and exterior assignments, and that is the vocabulary the order screens have moved to.
It is the scope language that replaced the form number, and it means a 3.6 assignment. An appraiser who reads it as the old product, accepts it, and works it in legacy software finds out at delivery. An order that still says 1004 is a 2.6 assignment from a client operating under an exception. Both are about to be ordinary, and the difference is a word on the engagement rather than a date on a calendar.
None of which is difficult. It requires reading the order the way you would read a scope-of-work instruction, because that is now what it is.
Nothing about the rule that catches people out. Feedback is delivered on UCDP submission date, not appraisal effective date. An inspection dated in October is not protected by its effective date if the lender delivers in November, and the exception does not change that — it only changes what the portal will accept from that particular seller on that particular day.
For a purchase under contract in Fort Worth, the question worth asking in October is not when the appraisal will be done. It is which dataset the lender intends to deliver in, and whether that lender holds an exception. A seller that applied and a seller that did not are now operating under different rules on the same closing date.
The table above is taken from Fannie Mae’s UAD 3.6 contingency announcement and Lender Letter LL-2026-08, both published 30 September 2026 and both linked below. Freddie Mac issued a parallel announcement. Where early trade coverage and the announcement differ, the announcement governs and I have followed it.
Two points where it is worth reading the announcement rather than a summary. Aggregators do not obtain exceptions covering their originators, which is not how it was first reported. And the run-off after 19 May 2027 is a resubmission window, not a grace period for new work.
Separately, my earlier article on the redesign cites a 3 May 2027 retirement milestone from Freddie Mac’s published timeline. That milestone has moved. I have noted it there rather than quietly deleting it.
If you are making a decision that turns on one of these dates, open the announcement yourself. It is linked below and it is eight pages.
This note covers the exception only. The mechanics of the redesign — what the new URAR is, which forms it replaces, what a fatal UCDP result means, and why the submission-date rule catches people — are in UAD 3.6 and the new URAR, which I have updated to reflect this announcement.
What the transition has done to appraisal fees, and why that is a homeowner’s problem rather than an appraiser’s complaint, is in more fields, same fee.
Dates are taken from Fannie Mae’s UAD 3.6 contingency announcement and Lender Letter LL-2026-08, both published 30 September 2026, and the parallel Freddie Mac announcement. Those documents control. This page is a general summary for appraisers, agents and homeowners, is not legal or compliance advice, and is not an appraisal.
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No. The mandate date of 2 November 2026 is unchanged. Fannie Mae and Freddie Mac created a temporary policy exception that an individual seller can apply for, separately from each GSE, by acknowledging it cannot meet the mandate and accepting revised contractual terms. A lender that does not request and obtain an exception is bound by the original date.
Approved sellers may submit new UAD 2.6 appraisals from 2 November 2026 through 19 May 2027. From 1 March 2027 through 19 May 2027 — the announcement calls it the reduced functionality period — Fannie Mae’s Collateral Underwriter returns a risk score of 999 and Freddie Mac’s Loan Collateral Advisor returns 99, and the loan is not eligible for collateral representation-and-warranty relief for value. Resubmissions of previously delivered reports continue through 27 June 2027. On 28 June 2027 no UAD 2.6 report is processed at all.
Only if that lender requested and obtained it, and only direct GSE sellers can. An aggregator does not obtain an exception covering the originators it buys from — it has to ensure those originators either submit UAD 3.6 or request exceptions themselves. There is no public list of who holds one, so the answer comes from asking the lender.
It is a UAD 3.6 assignment. Under the redesign there is no 1004 — the legacy forms are consolidated into one URAR, and assignments are described by scope rather than form number: traditional, hybrid, desktop or exterior. An order that still names a 1004 is a UAD 2.6 assignment from a client operating under an exception.
Not by its effective date. Feedback is delivered on UCDP submission date, not appraisal effective date. If the lender submits on or after 2 November 2026, the file is evaluated under the rules in force that day — which now depend on whether that lender holds an exception.
No. UAD is the dataset for appraisals delivered to Fannie Mae and Freddie Mac through UCDP. An appraisal developed for an estate, a divorce, an IRS filing, a tax protest or a pre-listing decision is not a UAD submission and is unaffected by the mandate or the exception.
Written fee quote, typically within one business hour. Questions about anything in this article are free, whether or not they turn into an assignment.