Fannie Mae and Freddie Mac will let lenders that have not finished rebuilding their appraisal systems keep filing reports in the outgoing format for up to six and a half months past the Nov. 2 deadline β but only if they apply for the exception, commit to a transition plan and accept a penalty on how their loans are reviewed.
The two government-sponsored enterprises set out the terms in a joint announcement dated Sept. 30, titled “Temporary Policy Exception for Sellers Unable to Meet UAD 3.6 Mandate.” The announcement is explicit that the mandate itself is unchanged: “The November 2, 2026 mandate is not changing.”
At issue is the Uniform Appraisal Dataset 3.6 and Forms Redesign, a wholesale replacement of the appraisal reporting forms lenders and appraisers have used for years. It retires the familiar library of GSE appraisal forms β the 1004 for single-family, the 1073 for condominiums and the rest β and replaces them with what Freddie Mac calls “a single flexible and dynamic report” that covers every property type and is aligned to the industry’s MISMO data model. The broad production period opened Jan. 26, and from Nov. 2 every new appraisal on a conventional loan sold to Fannie or Freddie is supposed to arrive in the new format.
What the exception grants
A seller that obtains an exception may keep submitting new UAD 2.6 appraisal reports to the Uniform Collateral Data Portal from Nov. 2 through May 19, 2027, and may resubmit previously filed 2.6 reports through June 27, 2027.
The relief is not free. From March 1 through May 19, 2027 β a window the GSEs label the Reduced Functionality Period β a 2.6 report will come back with a collateral risk score of “99” in Freddie Mac’s Loan Collateral Advisor and “999” in Fannie Mae’s Collateral Underwriter, and the loans those appraisals support “will not be eligible for collateral representation and warranty (R&W) relief for value.” For a lender, losing that relief means keeping repurchase exposure tied to the appraised value that the relief would otherwise remove. Sellers are “strongly encouraged” to implement before March 1 to avoid it, the announcement says.
The hard stops come after. Mandatory use of UAD 3.6 begins May 20, 2027; from then until June 27, new 2.6 submissions will be rejected with an unsuccessful status and a fatal feedback message in the Summary Submission Report. UAD 2.6 is retired entirely on June 28, 2027, after which no report in the old format will be processed.
The GSEs also warn that there is no second bite: the exception “is a one-time policy exception that will not be extended.”
Who has to ask
The obligation falls on sellers β the institutions that sell loans directly to Fannie or Freddie β and each GSE must be asked separately. Lenders that do not sell directly are not required to file anything but, the announcement says, “must align with their investors on their implementation plans.” Aggregators are explicitly on the hook for their correspondents: a seller that buys loans from third-party originators must either ensure every one of those originators is submitting 3.6 appraisals or request the exception itself.
The request is not a form letter. It must be completed online by a representative authorized to enter into a binding contract, and in signing it the seller acknowledges that its business cannot meet the mandate, agrees to revised contractual terms for the duration of the exception, and commits to a final implementation plan coordinated with its software vendors and appraisers. Each GSE also asks for the seller’s transition timing, its “top obstacles preventing implementation” and where the GSE could help.
Sellers that have already converted are considered compliant under Freddie Mac Single-Family Seller/Servicer Guide Bulletin 2025-7 and Fannie Mae’s Selling Guide Supplement on UAD 3.6 policy. Those that have not, and that do not obtain an exception, will be out of compliance with both Guides as of Nov. 2.
Why it matters beyond the back office
Appraisal plumbing rarely comes up at the closing table, but a format change of this size touches everyone in a transaction. Appraisers need software that can produce the new report, appraisal management companies need to route it, and lenders need underwriting systems that can read it. On our reading, the practical risk where any link in that chain is not ready is slower appraisal turn times and, at the extreme, loans that cannot be delivered as planned.
The Uniform Mortgage Data Program under which the change is being made is a joint Fannie-Freddie effort carried out at the direction of the Federal Housing Finance Agency. It is the same channel through which the GSEs have been pushing a steady run of policy changes at lenders this year, from retiring the condo “limited review” option to reworking how credit scores are priced.
Sellers that cannot meet the mandate must file a request with each applicable GSE before Nov. 2, the announcement says β 31 days from Oct. 2.
