The UAD 3.6 policy exception gives mortgage sellers a way to request more implementation time while leaving the November 2, 2026, mandate in place. Each applicable GSE must approve the seller’s request before it can rely on the exception, according to the September 30 joint announcement.

Who must obtain the exception?

The applicant is the approved seller delivering mortgages to a GSE. An aggregator must ensure its third-party originators use UAD 3.6 or obtain an exception itself. A lender selling only to investors need not apply directly, but must coordinate with those investors. Approval from one GSE does not establish approval from the other, as the joint policy announcement explains.

Readiness checks therefore need to cover both the seller’s own production and its purchased-loan pipeline. A correspondent should confirm which purchasing investor will accept its appraisal format and under what conditions. For lender operations teams, each approval record should identify the GSE, seller entity and agreed transition plan. A vendor’s implementation schedule cannot establish the seller’s approval status.

The September 30 announcement requires a representative authorized to bind the seller to complete each request. The seller must accept revised contractual terms and commit to a final implementation plan, including coordination with vendors and appraisers, to transition before the exception expires. Requested information includes transition timing, implementation obstacles and opportunities for GSE assistance. The announcement says the exception will not be extended.

Submit early enough to obtain approval before the mandate, allowing legal or compliance staff to review the contractual terms before the authorized representative files the request.

Separate the mandate from the submission deadlines

The November mandate turns on the report’s initial submission to the Uniform Collateral Data Portal (UCDP), rather than the loan application or appraisal effective date. Freddie Mac’s September 30 FAQ update makes that distinction explicit.

The September 30 joint announcement and Fannie Mae’s lender letter, LL-2026-08, establish the following timeline:

June 27 does not extend the window for an initial UAD 2.6 submission. Consider two hypothetical files for a seller with the applicable exception. File A’s UAD 2.6 appraisal was submitted successfully on May 18, 2027; a May 25 correction can use the resubmission window. File B’s first submission is May 25: it must use UAD 3.6, even if the appraisal was ordered earlier. These examples apply the submission-history distinction in the joint announcement.

Preserve the initial submission evidence, leave time to clear errors and assign an owner to each unresolved file before the cutoff.

What changes on March 1

From March 1 through May 19, 2027, Fannie Mae’s Collateral Underwriter returns 999 for UAD 2.6 submissions. Under LL-2026-08, mortgages delivered with UAD 2.6 appraisals during that phase are also excluded from specified enforcement relief concerning appraisal and property value.

For UAD 2.6 submissions during the same period, Freddie Mac’s Loan Collateral Advisor returns 99. Affected loans are ineligible for collateral representation and warranty relief for value, according to the September 30 joint announcement.

The additional implementation time therefore comes with a loss of normal risk scoring and specified relief. Secondary-marketing and appraisal-review teams should agree how to evaluate affected loans before committing to a later conversion.

Confirm the full lender-vendor handoff

Freddie Mac’s September 2026 implementation checklist calls for testing ordering, receipt, review and submission, alongside coordination with investors and technology providers. Use that framework to request evidence from each participant:

• Appraisers, appraisal management companies and ordering platforms: Confirm which format the engagement requires, who checks the returned report and who resolves a format mismatch.
• Loan origination and submission vendors: Demonstrate a complete UAD 3.6 transaction through the lender’s actual interfaces. A release date alone does not demonstrate that the lender’s configuration works.
• Review and delivery teams: Identify who clears submission findings, preserves the final report and reconciles the appraisal identifier with the delivery file.
• Correspondent investors: Obtain their acceptance criteria and submission-summary requirements before committing to an appraisal format.

The UCDP Overview, updated September 2025, supplies concrete acceptance checks: UAD 3.6 uses a ZIP package containing XML, the report PDF and images. The appraisal must receive a successful Submission Summary Report (SSR) before loan delivery, and its Document File Identifier must accompany delivery.

Test revisions as well. UCDP does not accept mixed UAD versions under one Document File Identifier, according to Freddie Mac’s UAD FAQ. Ask the vendor to demonstrate how it preserves the original version and submission history when a correction arrives.

Set a common implementation date for ordering, review and delivery as part of the mortgage technology transition. Keep format readiness separate from the different purposes of UAD appraisal reports.

Keep FHA implementation on its own schedule, too. Freddie Mac’s agency-scope guidance directs lenders to the government agencies for their implementation plans; this GSE exception does not establish FHA transition dates.

Check loan delivery separately

Permission to submit an appraisal does not guarantee loan eligibility or protections. The UAD 3.6 SSR guide treats collateral indicators as an early view subject to loan assessment.

Retirement of UAD 2.6 is also distinct from loan-sale timing. Freddie Mac’s UAD FAQ says retirement does not itself prevent subsequent sale of a loan supported by that appraisal; standard appraisal-expiration requirements still apply. Before scheduling delivery, confirm submission status, appraisal age and remaining conditions separately.