Newz: UAD 3.6 Fees, Fun Appraiser Game, Who Can Get Your Appraisal Data?
October 16, 2026
ARTICLE LIST – In order, Scroll down the page to read
- LIA AD: Problem with An Affidavit
- UAD 3.6 and the Appraisal Fee Chain: Who Actually Sets the Fee?, By Doug Smith, SRA
- Lots Under Water
- Certification 25: The 20-Year Fight Over Who Gets to Use Your Data, By Isaac Peck, WorkingRE, Publisher
- Appraiser Game – Something FUN, By Dustin Harris
- MY AD: 2026 E&O Update – Claims, Payment Options, Lawsuits, Etc
- Inspectors Blocked the Door, Appraisers handed over the Keys By Desiree Mehbod
- MBA STATS: Mortgage applications decreased 2.7 percent from one week earlier
Thanks to our Sponsor!!!
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UAD 3.6 and the Appraisal Fee Chain: Who Actually Sets the Fee?
By Doug Smith, SRA
“…the higgling and bargaining of the market…”
— Adam Smith, The Wealth of Nations, 1776
There has been considerable discussion about appraisal fees as UAD 3.6 is implemented. Much of the criticism over resistance to fee increases has been directed at Appraisal Management Companies.
But before deciding where responsibility lies, perhaps we need to follow what might be called the appraisal fee chain.
It begins with the borrower
A consumer seeking to purchase or refinance a residence provides information to a lender. The familiar conventional mortgage application is the Uniform Residential Loan Application (URLA), also known as Freddie Mac Form 65/Fannie Mae Form 1003.
For federal mortgage disclosure purposes, an application is considered received once the lender has six pieces of information: the consumer’s name, income, Social Security number, property address, estimated property value, and desired loan amount.
Once those items have been received, the lender generally must provide a Loan Estimate within three business days.
That Loan Estimate includes estimated loan and closing costs, including the anticipated cost of an appraisal when one is required.
This is where the appraisal fee chain gets interesting.
Federal disclosure rules limit how much certain estimated charges can increase between the Loan Estimate and closing. Depending on the circumstances, some required third-party service charges may be subject to a 10% cumulative tolerance, while others are subject to different rules. A valid changed circumstance may also permit a revised Loan Estimate.
So here is the first question:
Does the appraisal amount initially disclosed to the borrower influence the fee that can later be offered to the appraiser?
Once the borrower indicates an intent to proceed, the appraisal ordering process moves forward. Depending on the lender’s business model, the appraisal may be ordered directly from an appraiser or through an AMC.
Eventually, an assignment reaches an appraiser with a proposed fee.
But where in the appraisal fee chain was that number actually established?
Was it established by the lender when estimating the cost of the loan?
Was it established through an existing agreement or fee schedule between the lender and AMC?
Does the AMC determine the fee it offers the appraiser?
For lenders ordering directly, are they expecting UAD 3.6 assignments to be completed for the same fees previously paid for UAD 2.6 assignments?
And when an appraiser responds that the proposed fee is inadequate, how far back up the appraisal fee chain does that information travel?
These questions matter because UAD 3.6 changes the appraisal product and, for many appraisers, the process required to produce it. Appraisers are investing in training, software and equipment. Inspection procedures and data collection are changing. During the transition, the time required to complete an assignment may change as well.
Yet much of the current discussion seems to begin with the assumption that the appraisal fee should remain where it was.
Perhaps the question should not simply be, “Why won’t AMCs increase appraisal fees?”
The better question may be:
Where in the appraisal fee chain is the price of a UAD 3.6 appraisal actually being established—and is there still room for the market to establish a different price?
Nearly 250 years ago, Adam Smith described part of that price-setting process as the “higgling and bargaining of the market.”
Appraisers are participants in that market too.
A proposed fee is a proposal, not necessarily the market price.
Perhaps it is time for a little more higgling and bargaining.
My comments: I had never known about this before. Thanks to Doug Smith for the info!
