UAD 3.6’s Deadline Has an Exception. What Should Brokers Confirm?

When an appraisal order is placed in October, one small question can prevent a much larger handoff problem later: which report format is the lender expecting for this loan, and who has confirmed that path?

Fannie Mae and Freddie Mac announced a temporary exception on September 30 for sellers that cannot meet the November 2, 2026 UAD 3.6 mandate. The headline sounds like a deadline extension. It isn’t quite that. The mandate remains; an eligible seller may ask each applicable GSE for a limited exception while it finishes implementation.

For brokers, the practical issue is less about learning a new form and more about avoiding assumptions across lenders, appraisers, and investor channels.

The November date is still the line

UAD is the appraisal data standard sent through the GSEs’ Uniform Collateral Data Portal (UCDP). Starting November 2, new appraisal reports submitted to UCDP for Fannie Mae or Freddie Mac delivery are expected to use UAD 3.6. The redesigned dataset supports a dynamic report instead of the familiar set of numbered appraisal forms.

The recent exception creates a specific path for sellers who need more time. It does not automatically cover every lender or every loan. A Fannie Mae- or Freddie Mac-approved seller that needs the exception must request it from each GSE to which it sells loans. If the lender doesn’t sell directly to a GSE, it still has to align its process with its investor.

That means a broker shouldn’t treat “we have an extension” as a universal answer. The lender’s investor path and its own approved status are what matter to the file.

A grace period is not a blanket approval

For sellers granted an exception, both UAD 2.6 and 3.6 appraisal reports may be submitted through UCDP from November 2, 2026, through February 28, 2027. During that first period, the exception is designed to let an affected seller continue work while its vendors and appraisers transition. The seller remains responsible for carrying out its implementation plan.

There is a second, less forgiving phase. From March 1 through May 19, 2027, an exception holder may still submit UAD 2.6, but the GSEs’ collateral review tools return reduced functionality. Fannie Mae says a 2.6 report receives a CU risk score of 999 and will not be eligible for certain collateral representation-and-warranty relief for value. Freddie Mac’s joint announcement describes a Loan Collateral Advisor score of 99 and the same loss of value-related collateral relief.

That is a lender-level consequence, not a new checklist item for the borrower. But a lender’s chosen path may affect its internal review and what it asks the broker to coordinate. It’s worth knowing which format and submission window the lender is planning around before a property is already on a tight contract schedule.

The later cutoffs are different again

After May 19, the temporary permission to submit new UAD 2.6 reports ends. From May 20 through June 27, a new UCDP submission must use UAD 3.6; UAD 2.6 may be used only to resubmit a report that was previously submitted as 2.6. On June 28, support for UAD 2.6 ends.

In other words, the exception creates several checkpoints, not one new “deadline.” A loan that needs a report correction or resubmission after the new-submission cutoff may be handled differently than an appraisal that has not yet been submitted at all.

The broker’s job is a lender handoff, not a format decision

Brokers generally don’t request a GSE exception and shouldn’t decide which appraisal format an appraiser uses. That instruction comes through the lender’s appraisal channel. Still, the broker can get the right question in front of the lender early—especially when a wholesale lender sells through an aggregator or the file may change investor path.

Before or at order placement, ask the lender:

1. Is this loan expected to go to Fannie Mae, Freddie Mac, or a different investor?

2. Which UAD format should the appraiser deliver for this order?

3. If a GSE exception applies, has the responsible seller obtained it for the relevant investor?

4. What happens if an appraisal needs a correction or resubmission after the date window changes?

The third question is about confirmation, not asking your lender to disclose a confidential implementation plan. If the lender can’t yet answer, ask who owns the follow-up and when the order should be placed. Then give the borrower an accurate update instead of promising that either format will work.

Keep one clean status note with the order

The file note doesn’t need a technical essay. Record the investor path the lender gave you, the format requested, who confirmed it, and when the answer was checked. If the lender changes the investor, transfers the appraisal, or needs a revision, pause long enough to reconfirm the submission path before telling the borrower that timing is unchanged.

That’s the useful update to the earlier UAD transition workflow for brokers: the question is no longer only “Are we ready for November?” It’s also “Does the particular lender on this file have an approved exception, and what phase will the report hit?” The GSEs’ policy exception announcement and updated UAD timeline are the primary references if you need to confirm a date.

Talk through a workflow question

Appraisal handoffs can become harder to track when lender instructions change mid-pipeline. If you want another perspective on organizing the order, update, and borrower communication, talk with EPC about processing support.

If you’re already hearing different answers from different lenders, join the conversation on EPC’s official Facebook page: what’s the one UAD question you’re adding to your appraisal-order handoff?

Educational information only. Investor requirements and lender procedures may differ; confirm the applicable instructions with the lender responsible for the loan.