Fannie Mae and Freddie Mac Offer Temporary UAD 3.6 Exception as November Deadline Approaches

Written by: Internal Analysis & Opinion Writers

Fannie Mae and Freddie Mac are giving approved sellers additional time to complete their transition to the Uniform Appraisal Dataset 3.6 and redesigned appraisal reports, announcing a temporary policy exception for companies that cannot meet the approaching November 2, 2026 mandate.

The November implementation date itself has not changed. Lenders that are prepared for UAD 3.6 are expected to move forward as planned. However, approved sellers that are unable to complete their transition by the deadline may request an exception allowing them to temporarily continue submitting appraisal reports using the existing UAD 2.6 format.

Under the exception, eligible sellers may submit new UAD 2.6 appraisal reports through the Uniform Collateral Data Portal, or UCDP, from November 2, 2026 through May 19, 2027. Previously submitted UAD 2.6 appraisals may continue to be revised and resubmitted through June 27, 2027.

Fannie Mae and Freddie Mac emphasized that the additional time should not be interpreted as a postponement of the UAD 3.6 mandate.

"The November 2, 2026 mandate is not changing," the government-sponsored enterprises stated in their joint announcement.

Sellers that have successfully implemented UAD 3.6 by November 2 will comply with the applicable Fannie Mae and Freddie Mac requirements. Sellers that have not completed the transition will need an approved exception to remain compliant while temporarily using UAD 2.6.

The exception applies specifically to approved sellers. A lender that originates loans but does not sell directly to Fannie Mae or Freddie Mac does not need to independently request an exception. Instead, that lender should coordinate with its investor regarding implementation requirements.

Aggregators have an additional responsibility. If an aggregator purchases mortgages from third-party originators and then sells those loans to Fannie Mae or Freddie Mac, it must make sure its third-party originators are providing UAD 3.6 appraisals. Otherwise, the aggregator will need to request the appropriate policy exception.

The transition period will occur in several stages.

From November 2, 2026 through February 28, 2027, sellers granted an exception may continue submitting UAD 2.6 appraisal reports to UCDP. Beginning March 1, however, sellers still relying on the older dataset will encounter reduced collateral-review functionality.

Between March 1 and May 19, 2027, UAD 2.6 appraisals may continue to be submitted under an approved exception, but Fannie Mae's Collateral Underwriter will return a collateral risk score of "999." Freddie Mac's Loan Collateral Advisor will return a score of "99."

More importantly, loans secured by those UAD 2.6 appraisal reports will not qualify for collateral representation and warranty relief for value during the reduced-functionality period. That consequence gives sellers a strong operational incentive to complete their transition before March 1 rather than relying on the full length of the exception.

The GSEs said sellers are "strongly encouraged to implement UAD 3.6 prior to March 1, 2027" to avoid potential effects on their businesses and processes.

Beginning May 20, 2027, all initial appraisal submissions to UCDP must use UAD 3.6. From May 20 through June 27, UAD 2.6 will be permitted only when resubmitting an appraisal that had previously been submitted in the older format. Any new UAD 2.6 appraisal submitted during that period will receive an unsuccessful UCDP status and a Fatal feedback message on the Summary Submission Report.

The final cutoff arrives June 28, 2027. At that point, UAD 2.6 will be retired and UCDP will no longer process appraisal reports using the older dataset.

Obtaining the temporary exception also requires a formal commitment from the seller. An authorized representative capable of entering into a binding contract must submit a separate policy exception request to each GSE to which the company sells loans.

The seller must acknowledge that it cannot meet the November mandate, accept the revised contractual terms associated with the exception, and commit to a final implementation plan. The request must also provide information about the company's transition timeline, coordination with vendors and appraisers, obstacles delaying implementation, and areas where assistance from the GSEs could help.

Fannie Mae and Freddie Mac have made one point particularly clear: the exception is temporary. It is intended to provide a limited transition period for sellers facing legitimate implementation challenges, not an alternative to adopting UAD 3.6.

For lenders, appraisal management companies, appraisers, technology vendors, and mortgage operations teams, the announcement provides additional flexibility—but it does not change the industry's ultimate destination. UAD 3.6 remains the required appraisal standard, and organizations that can complete the transition sooner are being encouraged to do so rather than depend on the temporary exception.


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