UAD 3.6, the New URAR, and the Reality Nobody Wants to Say Out Loud

There’s a growing gap between official rollout timelines and what many of us are actually seeing in the field. After reviewing the latest industry chatter — and especially the recent Copilot analysis circulating — I’ll say this plainly:

The concerns are not exaggerated.

From the vantage point of someone who works daily as both an appraiser and a Realtor, the biggest issue isn’t whether UAD 3.6 is “coming.” It’s whether the ecosystem is behaving like a system that is anywhere near mandatory adoption.

Right now, it simply isn’t.

The Readiness Problem No One Can Ignore

On paper, Broad Production is technically live. In practice, the market feels very different.

Most appraisers are still producing reports on legacy forms. Many lenders are not fully operational on the new dataset. Vendors continue working through implementation wrinkles. AMCs are largely communicating preparation rather than execution.

That’s not criticism — that’s observation.

Large-scale transitions require three things to align simultaneously:

• Software stability
• Lender workflow stability
• Appraiser competency + comfort

Historically, the slowest of those three dictates the real timeline.

And today, all three still show friction.

The New URAR: Conceptually Strong, Operationally Heavy

The redesigned URAR is intellectually sound. The structure is more logical. The data model is more granular. From a valuation theory standpoint, the modernization makes sense.

But production reality matters.

More structured data fields, expanded property descriptions, and conditional logic increase cognitive load and completion time. That’s unavoidable. Even highly proficient appraisers will see longer report cycles during the adjustment period.

That creates downstream consequences many stakeholders underestimate.

Turn times stretch. Revision cycles increase. Lender expectations collide with production math.

The Production Equation Most People Miss

Appraisal capacity is not infinitely elastic.

If reports take longer to complete, one of three things must happen:

1. Appraisers produce fewer reports
2. Fees increase to offset time
3. Quality compresses under volume pressure

Option three is clearly unacceptable. Which leaves volume compression and fee pressure as the natural economic responses.

Early adoption phases almost always reduce output before efficiency gains appear. Anyone expecting immediate productivity parity is ignoring decades of workflow transition history.

Why Delays Would Not Be Surprising

Industry veterans have seen this movie before.

Major systemic changes rarely move at policy speed. They move at infrastructure speed. When readiness is uneven across vendors, lenders, and practitioners, timelines drift — not because of resistance, but because operational risk rises.

Mandatory enforcement without ecosystem stability creates failure points nobody wants.

Seen through that lens, a revised mandate window in late ’27 or ’28 is not a radical prediction. It is a structurally conservative one.

The Fee Conversation That’s Coming

Here’s the uncomfortable but economically rational truth:

If UAD 3.6 + the new URAR materially increase report complexity and production time, fees cannot remain anchored to legacy-era assumptions.

You cannot simultaneously demand:

• More data
• More analysis structure
• Same turn times
• Same fees

Markets eventually correct those contradictions.

The only uncertainty is timing.

The Bigger Industry Impact

None of this suggests UAD 3.6 is flawed. The direction is logical. Standardization and data modernization are necessary.

But transition costs are real.

Short-term effects are likely to include:

• Reduced appraiser output
• Longer turn times during adjustment cycles
• Increased training dependency
• Gradual upward fee pressure
• Temporary lender workflow friction

Long-term effects may indeed produce efficiency and better data integrity — but the bridge between here and there matters.

The takeaway isn’t pessimism.

It’s realism.

Technology transitions succeed when timelines respect production physics. Ignoring field-level constraints never accelerates adoption — it only amplifies disruption.

As always, those of us actually producing reports will adapt. We always do. But the industry should remain honest about what large-scale change truly looks like in motion rather than in slide decks.

Because the market eventually tells the truth — regardless of the timeline.