UAD 3.6: Modernizing Appraisal? is a Guest Post from John Fariss, MNAA, CAA. All opinions expressed are those of the author, John Fariss, MNAA, CAA, and not necessarily those of George Dell, or his staff.

Over the past year, the appraisal world has been swirling with discussion — and plenty of hype — around the rollout of UAD 3.6, the most significant revision to residential appraisal reporting standards since the original Uniform Appraisal Dataset was introduced in 2011. Fannie Mae calls it “a modern, flexible, and dynamic appraisal reporting structure that reflects the way appraisers think and analyze property data.” Freddie Mac touts its “standardized, consistent, and dynamic approach to appraisal reporting that will modernize the industry for the future.”

AMCs, software vendors, and trade publications have echoed the same: UAD 3.6 will modernize appraisal.

But let’s be blunt.

As someone who has spent over twenty years in this profession, actively integrating data science, statistical modeling, AI-assisted tools, and evidence-based valuation methods into my daily practice, I would suggest we pause before adopting the narrative that UAD 3.6 truly modernizes appraisal. What it modernizes is something entirely different — and far narrower.

UAD 3.6 modernizes how appraisal data is formatted, transmitted, and consumed by the GSEs. It does not modernize appraisal practice itself.

New Slices, Same Recipe

Imagine your local bakery announces it has modernized its entire bread-making operation. You walk in expecting to see new ovens, innovative recipes, or revolutionary baking techniques. Instead, you discover that the flour, yeast, salt, and water are the same. The kneading, proofing, and baking remain unchanged.

The only difference? A new automated slicer cuts the bread into perfectly even slices, wraps it, and applies a label that makes it easier for distributors to store, track, and ship.

That is precisely what UAD 3.6 represents! The ingredients of valuation — market data, comparables, adjustments, and expert judgment — remain unchanged. The analysis that produces credible opinions of value is still performed by the appraiser. What has changed is how the final product is sliced, packaged, labeled, and shipped to the GSEs for their internal processing.

What Actually Changes

UAD 3.6 makes significant changes in how appraisal data is formatted, transmitted, and consumed by Fannie Mae, Freddie Mac, and their automated review systems. The new Uniform Residential Appraisal Report (URAR) replaces a wide range of static forms with a single dynamic format that adapts based on property type, occupancy, and assignment scope. It adheres to the MISMO 3.6 XML standard, enabling much cleaner and more consistent data ingestion.

The structure allows for far more granular data capture. Items such as site influences, view categorizations, condition elements, construction materials, and room counts are broken into smaller, highly standardized data fields. Exhibits, maps, and photographs are now directly tied to specific sections of the report, streamlining their alignment within the report structure.

From the perspective of the GSEs, this overhaul is critically important. Structured data allows their automated systems to analyze appraisal reports more efficiently, identify inconsistencies, feed risk scoring engines, and expand automation across the loan origination process. It also improves their capacity to drive automated underwriting decisions, hybrid models, and expanded waiver programs — all of which reduce the need for full appraisal assignments in many lending scenarios.

What Doesn’t Change

Despite its scope on the reporting side, UAD 3.6 does not represent a modernization of valuation practice. The core appraisal methods — the sales comparison approach, cost approach, and income approach — remain unchanged. The appraiser still carries the responsibility for selecting comparables, performing market segmentation, identifying meaningful adjustments, and reconciling the final opinion of value.

The new reporting structure does not assist the appraiser in developing time adjustments, creating price indexes, or applying statistical methods. It does not encourage the use of regression modeling, grouped analysis, or other forms of evidence-based valuation techniques that some of us are increasingly using to improve transparency, replicability, and credibility.

UAD 3.6 simply reshapes how the final conclusions are packaged and delivered — it does not contribute to how they are developed.

Appraisers remain solely responsible for identifying appropriate market segments, defining competing market areas, and establishing proper data groupings. While the GSEs benefit from improved data aggregation for their internal models, the practicing appraiser sees little benefit from UAD 3.6 in terms of enhanced valuation practice or tools.

Real Modernization

If true modernization of appraisal practice is occurring, it is happening independently of UAD 3.6. It is occurring among those appraisers who are embracing more advanced forms of market analysis, moving beyond traditional pairings and subjective adjustments into data-driven valuation supported by statistical reasoning. Exactly what we at the CAA have been teaching, sharing and implementing.

Evidence-Based Valuation (EBV^©), which I have integrated into my own practice, reflects this evolution. By constructing assignment data frames, carefully segmenting markets, and applying transparent adjustment logic rooted in observable market behavior, EBV allows for stronger, more defensible conclusions. Data science tools, such as RStudio and Quarto, enable appraisers to build dynamic models, apply time-series adjustments, and visualize market trends that clarify pricing behavior across time and property characteristics.

Artificial intelligence and machine learning also have potential roles — not to replace appraisers, but to support exploratory analysis, identify patterns, and refine trend detection. These tools, properly applied, represent true modernization of appraisal practice because they improve how valuation is developed, not just how it is reported.

Why This Distinction Matters

For many legal, estate, tax, and litigation assignments, UAD 3.6 offers no benefit whatsoever. Attorneys, courts, fiduciaries, and clients do not require data formatted for automated ingestion by the GSEs. They require carefully reasoned, clearly explained, well-documented valuations that can withstand scrutiny and cross-examination.

For appraisers who wish to thrive in the years ahead, this distinction becomes pivotal. The rise of UAD 3.6 will accelerate automation in lender work, compressing fees and turn times as hybrid models and waivers expand. But complex assignments, those requiring thoughtful segmentation, empirical adjustments, and defensible narratives, will continue to require genuine expertise.

Those who build that expertise through evidence-based valuation, litigation support, market consulting, or advanced modeling will continue to provide essential services that cannot be replicated by form-fillers or automated scoring engines.

A Closing Thought

The real risk in UAD 3.6 is not the change itself. The real risk lies in believing that this represents the modernization of our profession. It does not.

UAD 3.6 modernizes reporting. It reorganizes data for the benefit of automated review systems. But it does not change how we analyze markets, derive adjustments, segment data, or defend value conclusions. It modernizes how we slice the bread — but it does not change how we bake it.

For those of us committed to modernizing appraisal itself — through evidence, data science, transparency, and advanced reasoning — UAD 3.6 is simply a new delivery package. The real work remains what it has always been: understanding markets, interpreting data, and producing credible opinions of value rooted in observable reality.