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Commission hears industry warning on incoming UAD 3.6 reporting standard

October 20, 2025 | Commerce & Insurance, Deparments in Office of the Governor, Organizations, Executive, Tennessee


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Commission hears industry warning on incoming UAD 3.6 reporting standard
At its Oct. 20 meeting, the Tennessee Real Estate Appraiser Commission heard a detailed briefing from Commissioner Sandra Tuck on changes regulators and lenders expect as the appraisal industry moves to UAD 3.6.

The new Uniform Appraisal Dataset, UAD 3.6, will replace UAD 2.6 and is planned for phased deployment. Limited production had been scheduled to begin Sept. 8, 2025, with broader production and GSE acceptance steps continuing through late 2026, Tuck said. Lenders and the government-sponsored enterprises will require UAD 3.6 submissions after the transition period, and software vendors must update their products and obtain GSE approval to accept the new structured reports.

Why it matters: Commissioners were told the new dataset is a structural change from a fillable form to a dynamic report with defined data elements that may increase the amount of information appraisers must collect at inspection. Tuck said the change is expected to increase the number of discrete data elements gathered on a typical inspection from roughly 500 to about 1,500, and that the report will present 29 possible sections, 18 always present and 11 conditional by property type. The change is intended to standardize reporting and improve reviewability, the commission was told.

Tuck said software providers were still completing development in mid-October and were expected to roll out updates in the months ahead. She said appraisers should expect that the UAD 3.6 reports will be more structured, reduce opportunities for separate addenda, and replace some narrative with fixed fields and embedded comment areas.

“It's going to change. It's not a static form,” Tuck said, describing how apps will present conditional fields for condos or multifamily properties when the appraiser selects the property type.

Conference takeaways and industry context: Tuck summarized additional conference items the commission discussed: an Appraiser Qualifications Board (AQB) reassessment of education, examination and experience requirements (with an exposure draft expected before 2025 ends); continued adoption of the PAREA pathway by states; and the Appraisal Foundation’s Harmonization Task Force work to align state licensing with AQB criteria.

Tuck cited data presented at the conference: about 4,400 inquiries into the PAREA pathway, 183 active participants and 53 graduates, of which about 32 had received credentials; and national licensing counts that show a long-term decline in residential appraisers. Conference presenters estimated 15%–20% of current residential appraisers may not transition to the new UAD reporting process, she said, because of changes in workflow, increased data collection and, in some cases, lenders’ increased use of valuation waivers.

Questions from commissioners focused on timing, software readiness and potential workforce impacts. Commissioners also noted continuing-education providers were already listing courses on UAD 3.6 topics and the commission had approved several courses that should help Tennessee appraisers prepare.

Tuck recommended the commission monitor the UAD rollout closely and encourage courses that prepare regulators and practitioners to use and review the new report format.

Ending: Commissioners were not asked to take immediate regulatory action but were told to expect additional conversations as software vendors complete development and GSE requirements firm up. The commission will continue to track AQB and Appraisal Foundation work and the practical impacts on Tennessee licensees.

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Scribe from Workplace AI
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