Remove or revise the 3.6 UAD appraisal report
The Issue
PETITION TO ELIMINATE THE 3.6 UAD FANNIE MAE/FREDDY MAC APPRAISAL REPORT AND/OR CREATE A REPORT THAT IS MORE APPRAISER FRIENDLY AND PROFESSIONALLY APPLICABLE
CREATE A MINIMUM GSE APPRAISAL FEE
PROHIBIT AMCs FROM AWARDING APPRAISAL ORDERS TO THE LOWEST BIDDER TO ELIMINATE PRICE FIXING. NO APPRAISAL ORDER SHALL BE BID TO THE LOWEST BIDDER.
PROHIBIT AMCs FROM EMPLOYING IN-HOUSE APPRAISERS TO CONTROL INDEPENDENT APPRAISER FEES (ELIMINATE PRICE FIXING)
Fannie Mae and Freddie Mac initiated the UAD 3.6 Appraisal Form in 2026 to streamline the appraisal reporting forms with a methodology meant to create a data-driven, dynamic reporting structure to capture property and market information. It was also created to retire the so-called outdated legacy forms and eliminate the free-form commentary addendum.
https://singlefamily.fanniemae.com/media/23286/display
From the certified residential appraiser’s perspective, the UAD 3.6 appraisal form fulfills a goal of Fannie Mae and Freddy Mac to collect data as the expense of the quality of the appraisal, the diagnostic intent of the appraisal, and the income of the appraiser completing the report. It purportedly is designed to lessen the burden of the lenders and the GSEs (Government-Sponsored Enterprise) reviewing process. It does not take into consideration the effect it has on the residential appraisers completing the appraisal.
From the perspective of the certified residential appraiser (appraiser), the form itself is the antithesis of user friendly. It significantly increases the time needed to complete residential appraisals. Further, it very significantly decreases the ability of the appraiser to complete a comprehensive, lender decision aid. The elimination of the so-called free form addendum in the 2.6 UAD appraisal reports excludes the ability of the appraiser to comprehensively inform the lender of salient information about the property being appraised. It inhibits the ability to apply total analysis for relevant monetary adjustments for all but the most basic of differences between comparable properties used for indications of value and the features of the home being appraised. By and large, most homes are different in some aspect, but the UAD 3.6 appears to be created for the application of monetizing only the most basic adjustments, and it forgoes adequate provision of space to address other issues that affect value.
To utilize only one small example in an arena where literally hundreds of thousands of examples are applicable, let us briefly examine the need to compare a home located in a market area different from the subject and a home design different from the subject as an integral part of the appraisal. This common scenario cannot be addressed with other than minimized statements in a UAD 3.6 format, whereas the inclusion of an addendum in the now-labeled legacy forms provided such a format. Can it be adjusted? Sure. Again, without areas for comprehensive analysis. It is the overall opinion of the appraisers signed below that the architects of the 3.6 UAD report, Ken DeFeo (Senior Director / Senior Manager of Collateral Policy at Fannie Mae) and Sean Murphy (Credit Policy Risk Analytics Manager at Freddie Mac), either are not knowledgeable enough to understand these issues, or perhaps it is their belief that a one size fits all appraisal format is more important than the financial risk taken by the lender(s) or the risks taken by Fannie Mae and Freddy Mac when purchasing the loans and bundling them into mortgage backed securities. (Of course, the GSEs can mitigate their own risk by requiring a lender to buy back a mortgage loan or pay a penalty. When this is taken into consideration, the GSEs have nothing to lose. It is the lender at risk with the utilization of the inadequacy of the new form.) It is the belief of the appraisers that the gentlemen mentioned either ignored or did not comprehend the negative impact the new form would have on appraisers. It is not merely a lack of understanding the form or being properly educated about the form. It is the inadequacy of the form itself. Add to this the multiple choice check box format of the 3.6 UAD appraisal form, with its lack of the ability to fully disclose all elements necessary to create a useful appraisal report, and it can reasonably be argued that a disaster in the making has begun.
From the appraiser perspective, the increased time spent on a 3.6 UAD appraisal is not, by and large, being compensated for. The AMCs are fusing to increase fees to totally compensate for the additional time needed to complete the appraisal. The Appraisal Management Companies (AMCs) have saturated the market in managing the appraisal ordering and review process, with the lenders taking a second look. (On a side note, multiple AMC employees have verified that it is part of their job orders to locate something within an appraisal report to revise, in order to justify their fees to the lenders. But we digress.) The issue with the AMCs managing the appraisal order process is that their main motivation is for profit, at the expense of a professionally prepared and comprehensive appraisal. Rather than seeking out the most competent appraiser, many often send the appraisal out for engagement to the lowest bidder. The old adage “You Get What You Pay For” holds true.
EXPECTING A COMPETENT APPRAISER TO COMPLETE A MORE TIME CONSUMING APPRAISAL REPORT FOR THE SAME FEE AS THAT PAID FOR AN APPRAISAL COMPLETED ON A LEGACY FORM HAS THE FORESEEN RESULT OF EVEN MORE COMPETENT APPRAISERS LEAVING THE PROFESSION THAN HAVE LEFT IN RECENT YEARS. (In the past 10 years, the number of residential appraisers has dropped by 29.4%, or roughly from 92,000 in 2016 to 65,000 in 2025, in the U.S.. A search of an internet AI attributes much of this to the operational policies of AMCs. This includes not only minimal appraisal fees, but the inclusion of the employment of in-house AMC appraiser employees used to price fix the fee of the appraisal. (See Sherman Antitrust Ace (1980), Clayton AntitrustAct (1914), and Federal Trade Commission Act (1914).
The above analysis cannot reasonably be argued with by appraisal professionals, though it can be assumed that many will disagree rather than legitimize the views of appraisers. The facts hold true. For these reasons, which have been kept as brief as possible, the following undersigned appraisers throughout the United States and U.S. Territories petition for the following:
1. Eliminate the 3.6 UAD format. (The appraisers do approve in principle that a more information including appraisal form that protects the interest of the lender more comprehensively and is more appraiser friendly is reasonable. The 3.6 UAD form is simply not reasonable or adequate for lender needs.)
2. If the GSE’s refuse to take into consideration the professional concerns of the residential appraisers listed here below, (We recognize we have no power.) then the GSEs will implement the following:
A. A mandatory minimum fee of $1,000 will be required across the board for all UAD 3.6 Products, with cost of living increases for appraisers in the more expensive to live areas of the county such as California, Chicago, and New York City.
B. No appraisal management company, lender, or other entity shall submit appraisal orders out for bid in competition for the lowest appraisal fee at the expense of the provision of a more qualified appraisal report, in order to eliminate the price fixing. This shall not be confused with implementing a methodology of awarding a fee to a lower bid with the contention that the lowest bidder provides a high quality appraisal. Initiate the fee, period.
3. Appraisal Fees shall increase per GSE requirement at any time there is more than 1% cost of living increase in a 3 year period, with the fee raise to match the increase. (Increase to span all 3 years, and not merely multiple cost of living increases across a 3 year span with less than 1% difference individually.)
4. If at such a time a new appraisal form is implemented, it will be provided to all appraisers at large for commentary and analysis by the professional who actually complete the reports. The appraisers themselves will be the BETA testers.
5. Prohibit appraisal management companies from employing in-house appraisers to compete with residential contract appraisers and to utilize their in-house staff to control and minimize independent appraiser fees. Eliminate the price fixing.
6. No AMC, member of a GSE, member of a lending institution, or any other party shall take any retaliatory action to anyone signing this petition, including, but not limited to, ceasing to award appraisal orders or limiting the number of appraisal orders to an appraiser(s).
129
The Issue
PETITION TO ELIMINATE THE 3.6 UAD FANNIE MAE/FREDDY MAC APPRAISAL REPORT AND/OR CREATE A REPORT THAT IS MORE APPRAISER FRIENDLY AND PROFESSIONALLY APPLICABLE
CREATE A MINIMUM GSE APPRAISAL FEE
PROHIBIT AMCs FROM AWARDING APPRAISAL ORDERS TO THE LOWEST BIDDER TO ELIMINATE PRICE FIXING. NO APPRAISAL ORDER SHALL BE BID TO THE LOWEST BIDDER.
PROHIBIT AMCs FROM EMPLOYING IN-HOUSE APPRAISERS TO CONTROL INDEPENDENT APPRAISER FEES (ELIMINATE PRICE FIXING)
Fannie Mae and Freddie Mac initiated the UAD 3.6 Appraisal Form in 2026 to streamline the appraisal reporting forms with a methodology meant to create a data-driven, dynamic reporting structure to capture property and market information. It was also created to retire the so-called outdated legacy forms and eliminate the free-form commentary addendum.
https://singlefamily.fanniemae.com/media/23286/display
From the certified residential appraiser’s perspective, the UAD 3.6 appraisal form fulfills a goal of Fannie Mae and Freddy Mac to collect data as the expense of the quality of the appraisal, the diagnostic intent of the appraisal, and the income of the appraiser completing the report. It purportedly is designed to lessen the burden of the lenders and the GSEs (Government-Sponsored Enterprise) reviewing process. It does not take into consideration the effect it has on the residential appraisers completing the appraisal.
From the perspective of the certified residential appraiser (appraiser), the form itself is the antithesis of user friendly. It significantly increases the time needed to complete residential appraisals. Further, it very significantly decreases the ability of the appraiser to complete a comprehensive, lender decision aid. The elimination of the so-called free form addendum in the 2.6 UAD appraisal reports excludes the ability of the appraiser to comprehensively inform the lender of salient information about the property being appraised. It inhibits the ability to apply total analysis for relevant monetary adjustments for all but the most basic of differences between comparable properties used for indications of value and the features of the home being appraised. By and large, most homes are different in some aspect, but the UAD 3.6 appears to be created for the application of monetizing only the most basic adjustments, and it forgoes adequate provision of space to address other issues that affect value.
To utilize only one small example in an arena where literally hundreds of thousands of examples are applicable, let us briefly examine the need to compare a home located in a market area different from the subject and a home design different from the subject as an integral part of the appraisal. This common scenario cannot be addressed with other than minimized statements in a UAD 3.6 format, whereas the inclusion of an addendum in the now-labeled legacy forms provided such a format. Can it be adjusted? Sure. Again, without areas for comprehensive analysis. It is the overall opinion of the appraisers signed below that the architects of the 3.6 UAD report, Ken DeFeo (Senior Director / Senior Manager of Collateral Policy at Fannie Mae) and Sean Murphy (Credit Policy Risk Analytics Manager at Freddie Mac), either are not knowledgeable enough to understand these issues, or perhaps it is their belief that a one size fits all appraisal format is more important than the financial risk taken by the lender(s) or the risks taken by Fannie Mae and Freddy Mac when purchasing the loans and bundling them into mortgage backed securities. (Of course, the GSEs can mitigate their own risk by requiring a lender to buy back a mortgage loan or pay a penalty. When this is taken into consideration, the GSEs have nothing to lose. It is the lender at risk with the utilization of the inadequacy of the new form.) It is the belief of the appraisers that the gentlemen mentioned either ignored or did not comprehend the negative impact the new form would have on appraisers. It is not merely a lack of understanding the form or being properly educated about the form. It is the inadequacy of the form itself. Add to this the multiple choice check box format of the 3.6 UAD appraisal form, with its lack of the ability to fully disclose all elements necessary to create a useful appraisal report, and it can reasonably be argued that a disaster in the making has begun.
From the appraiser perspective, the increased time spent on a 3.6 UAD appraisal is not, by and large, being compensated for. The AMCs are fusing to increase fees to totally compensate for the additional time needed to complete the appraisal. The Appraisal Management Companies (AMCs) have saturated the market in managing the appraisal ordering and review process, with the lenders taking a second look. (On a side note, multiple AMC employees have verified that it is part of their job orders to locate something within an appraisal report to revise, in order to justify their fees to the lenders. But we digress.) The issue with the AMCs managing the appraisal order process is that their main motivation is for profit, at the expense of a professionally prepared and comprehensive appraisal. Rather than seeking out the most competent appraiser, many often send the appraisal out for engagement to the lowest bidder. The old adage “You Get What You Pay For” holds true.
EXPECTING A COMPETENT APPRAISER TO COMPLETE A MORE TIME CONSUMING APPRAISAL REPORT FOR THE SAME FEE AS THAT PAID FOR AN APPRAISAL COMPLETED ON A LEGACY FORM HAS THE FORESEEN RESULT OF EVEN MORE COMPETENT APPRAISERS LEAVING THE PROFESSION THAN HAVE LEFT IN RECENT YEARS. (In the past 10 years, the number of residential appraisers has dropped by 29.4%, or roughly from 92,000 in 2016 to 65,000 in 2025, in the U.S.. A search of an internet AI attributes much of this to the operational policies of AMCs. This includes not only minimal appraisal fees, but the inclusion of the employment of in-house AMC appraiser employees used to price fix the fee of the appraisal. (See Sherman Antitrust Ace (1980), Clayton AntitrustAct (1914), and Federal Trade Commission Act (1914).
The above analysis cannot reasonably be argued with by appraisal professionals, though it can be assumed that many will disagree rather than legitimize the views of appraisers. The facts hold true. For these reasons, which have been kept as brief as possible, the following undersigned appraisers throughout the United States and U.S. Territories petition for the following:
1. Eliminate the 3.6 UAD format. (The appraisers do approve in principle that a more information including appraisal form that protects the interest of the lender more comprehensively and is more appraiser friendly is reasonable. The 3.6 UAD form is simply not reasonable or adequate for lender needs.)
2. If the GSE’s refuse to take into consideration the professional concerns of the residential appraisers listed here below, (We recognize we have no power.) then the GSEs will implement the following:
A. A mandatory minimum fee of $1,000 will be required across the board for all UAD 3.6 Products, with cost of living increases for appraisers in the more expensive to live areas of the county such as California, Chicago, and New York City.
B. No appraisal management company, lender, or other entity shall submit appraisal orders out for bid in competition for the lowest appraisal fee at the expense of the provision of a more qualified appraisal report, in order to eliminate the price fixing. This shall not be confused with implementing a methodology of awarding a fee to a lower bid with the contention that the lowest bidder provides a high quality appraisal. Initiate the fee, period.
3. Appraisal Fees shall increase per GSE requirement at any time there is more than 1% cost of living increase in a 3 year period, with the fee raise to match the increase. (Increase to span all 3 years, and not merely multiple cost of living increases across a 3 year span with less than 1% difference individually.)
4. If at such a time a new appraisal form is implemented, it will be provided to all appraisers at large for commentary and analysis by the professional who actually complete the reports. The appraisers themselves will be the BETA testers.
5. Prohibit appraisal management companies from employing in-house appraisers to compete with residential contract appraisers and to utilize their in-house staff to control and minimize independent appraiser fees. Eliminate the price fixing.
6. No AMC, member of a GSE, member of a lending institution, or any other party shall take any retaliatory action to anyone signing this petition, including, but not limited to, ceasing to award appraisal orders or limiting the number of appraisal orders to an appraiser(s).
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Petition created on October 15, 2026