On November 2, 2026 the appraisal behind every conventional mortgage changes form. The appraisal in the divorce file does not, and nobody has written about what happens in between.
OneThe Finding: Two Standards, One File
The mandate does not change divorce appraisal practice by a single line. It changes everything the divorce appraisal is measured against.
On November 2, 2026 the Uniform Residential Appraisal Report is replaced. Thirteen legacy forms retire, including the 1004 that every family law practitioner in the country has seen. In their place is a single dynamic report built on a new data standard, UAD 3.6, running eighteen to thirty pages on legal-size paper where the 1004 ran six.
None of that reaches a divorce appraisal. UAD 3.6 governs appraisals submitted to the Uniform Collateral Data Portal on conventional loans sold to Fannie Mae or Freddie Mac. A divorce appraisal is not ordered by a lender, is not submitted to that portal, is frequently retrospective to a date of separation or filing, is written for different intended users, and often applies a different definition of value. The mandate has nothing to say about it.
Which is precisely the problem, and it is not the one the industry is discussing.
Divorce cases routinely carry two appraisals: one that values the marital estate and one that a lender orders later for the refinance or the assumption that the settlement depends on. Those two documents have always differed in purpose. From November 2 they will differ in form, in vocabulary, and in what they report at all. Fields that counsel has cross-examined on for twenty years no longer exist in the lender version. Fields that never existed before, including a photographed defect list with estimated repair costs on page one, now do.
The divergence is not temporary. Fannie Mae and Freddie Mac have a date. The Federal Housing Administration does not, and has said so in writing. The Department of Veterans Affairs and the Department of Agriculture have published nothing we can verify. So from November a single divorce file can hold a conventional appraisal on the new standard, a government-backed appraisal on the retired forms, and a marital estate appraisal on a general purpose form that answers to neither.
This report sets out the dates, what the mandate binds, what actually changes inside the document, and the nine places that lands in a divorce file. It does not tell appraisers how to practice. It tells the people who read appraisals what they are about to be reading.
TwoThe Dates, and the One That Catches People
The schedule has never moved. The rule that decides which format applies is not the one most people assume.
| Phase | Dates | What may be submitted |
|---|---|---|
| Limited Production | September 8, 2025 to January 25, 2026 | UAD 3.6 by invited lenders only |
| Broad Production | January 26, 2026 to November 1, 2026 | UAD 2.6 or UAD 3.6, at the lender’s election |
| Mandate | November 2, 2026 | UAD 3.6 only |
| Retirement | May 3, 2027 | UAD 2.6 pipeline cleared; revisions to earlier submissions stop |
These dates were published in a joint announcement on October 28, 2024 and have not been changed since. We traced the full announcement log. Nothing in it extends, delays or alters any milestone, and the enterprises have said they have no plans to adjust.
The rule that decides which format a given appraisal must use is easy to state and easy to get wrong.
The November 2, 2026 mandate is based on the initial UCDP Submission Date of each report.
Not the effective date of the appraisal. Not the loan application date. Not the date the appraiser was engaged. The date the report is submitted to the portal.
Enforcement is already visible. Since August 6, 2026 the portal has returned a warning message on every UAD 2.6 submission. From November 2 it returns a fatal error and a status of Not Successful, and the report has to be converted, which in practice means produced again in the new format.
An appraisal ordered in October on a legacy form, delivered in October, and submitted to the portal on or after November 2 is rejected. It does not matter that the inspection, the effective date and the engagement all fell inside the old window. A divorce refinance or assumption sitting in that gap has to be appraised again, and a court deadline does not move because a portal did. Anyone with divorce files closing in the first half of November should be asking now which format the appraisal will be delivered on.
ThreeWhat the Mandate Binds, and What It Does Not
Conventional loans sold to the two enterprises. That is the entire scope, and the trade coverage has this wrong.
UAD 3.6 binds appraisals on loans sold to Fannie Mae or Freddie Mac. The enterprises worked with the federal agencies to build agency requirements into the dataset, and both enterprises then say plainly that agency timing is the agencies’ own business. Fannie Mae’s FAQ instructs readers to contact each agency for its implementation plans.
That is a statement that the data fields were designed to accommodate agency needs. It is not a statement that the agencies adopt the standard on November 2, and the difference is where most of the published commentary goes wrong.
FHA will establish and announce a mandatory transition at a future date.
The same bulletin says an optional transition start date will be announced following successful beta testing, and that it will begin before the enterprises’ mandatory date. As of August 28, 2026 neither date exists. FHA appraisals continue on the legacy forms past November 2 until FHA says otherwise.
Several vendor and trade articles carry headlines announcing that FHA has adopted UAD 3.6. Against HUD’s own bulletin that framing is misleading. HUD is the primary source on FHA timing, and it has published a deferral rather than a date.
For the Department of Veterans Affairs and the Department of Agriculture we could locate no circular, handbook change or published page stating an adoption date. We report that as unverified rather than as a finding.
The thirteen forms that retire
The redesigned report is a single dynamic document that expands and contracts by property type and scope of work, replacing a family of thirteen: the 1004 and its desktop and hybrid variants, the 1073 and its desktop and hybrid variants, the 1075, the 2055, the 1004C, the 2090, the 2095, the 1025, and the 1004D.
One survivor is worth naming because the older readiness materials get it wrong. The 1007 comparable rent schedule is not retired. It is folded into the new report and survives in a narrowed role for the limited circumstance where rent estimation happens after the appraisal. A practitioner working from the April 2025 lender readiness kit will be told the 1007 is gone. The current enterprise FAQs say otherwise and they are the later document.
FourWhat Actually Changes in the Appraisal
Not a redesign of the same content. A different set of things reported, in a different way, with much of the old narrative converted into structured data.
Condition and quality are no longer one rating
The C1 to C6 and Q1 to Q6 scales survive with rewritten definitions, but a report no longer carries one of each. Ratings split into exterior, interior and overall, and they repeat for every dwelling, every unit and every accessory dwelling unit. A high-rise condominium carries no exterior rating at all.
Below that, condition is reported per room and per component. Every kitchen and every bathroom in every unit carries three required fields: an update status of fully, partially or not updated; a time frame; and a condition status of new or like new, typical wear and tear, damaged and functional, or damaged and nonfunctional. The same four-point scale repeats for each flooring type and for walls and ceilings. Photographs of each kitchen and bathroom are required.
A defect list, with costs, on page one
The single narrative question on the 1004 asking whether there are physical deficiencies or adverse conditions is gone. In its place are six structured tables covering the site, the dwelling exterior, the unit interior, outbuildings, vehicle storage and amenities. Each entry records the feature, its location, a description, whether it affects soundness or structural integrity, and a recommended action of completion, inspection, repair or none. Photographs of physical defects are required.
Everything requiring action then reappears in the summary on page one, with an estimated cost to repair where applicable, prefaced with a statement that the items represent the as-is condition as of the effective date. Where nothing requires action, the report prints an affirmative negative saying so.
The report says who inspected the property, and how
A required field records the property valuation method as traditional, hybrid, desktop or exterior, with an instruction that it represents what was actually completed rather than what was ordered. Two further fields record the exterior and interior inspection as physical, virtual or no inspection, with the inspection date.
Where a property data report was used, the person who collected the data is named, with their company, their address and an occupation drawn from an enumerated list that includes appraiser, appraiser trainee, home inspector, insurance inspector and real estate agent.
Familiar fields that no longer exist
Several things a reader has been trained to look for are simply absent from the new report.
- Gross living area, as a term, does not appear. Six ANSI-based area buckets replace it per unit, including a nonstandard finished area category for space with ceilings under seven feet, plus a required field naming the source of the measurement.
- Gross adjustment totals and percentages do not appear. Only a net adjustment total survives. The net and gross percentage test that counsel has used to attack comparables for two decades has no field to attack.
- The neighborhood section is dissolved. Built-up percentage, growth, property values, present land use, one-unit housing trends and the urban, suburban or rural classification are all gone.
- The 1004MC market conditions addendum is gone, replaced by roughly twenty discrete market fields including a required description of the market area boundaries and of the search criteria used, an appraiser-chosen lookback period, and graphs. The increasing, stable or declining checkbox does not survive.
- Effective age and remaining economic life display only on FHA, USDA and VA appraisals. A conventional report carries no effective age.
New structure where narrative used to be
- Comparable weight, recorded as most, less or no weight for every comparable, with a reconciliation that must explain how the weighting was determined.
- A zero versus blank convention. A zero in an adjustment line now means the appraiser considered the difference and found no market support for an adjustment. A blank means the feature is the same. The distinction is machine-readable.
- Time adjustments anchored to contract date in preference to settlement date.
- Transfer terms as an enumerated field, including estate sale, sale between related parties and court ordered non-foreclosure sale.
- Reconsideration of value as a structured record: type, date, result of no value change or value change, and commentary.
- Exposure time as a required numeric field rather than a narrative remark.
Several data points are transmitted in the underlying file and drive what the report displays while being expressly marked as not appearing on the report. Other rows print only where the appraiser judges them relevant. The printed report is a curated rendering of a larger dataset, and the enterprises’ own guidance cautions that the summary is not a substitute for reading the entire appraisal. A lender parsing the data file sees more than the party who receives the PDF.
FiveWhere This Lands in a Divorce File
Nine consequences, in the order we would raise them with counsel.
- The October pipeline. A legacy-form appraisal submitted to the portal on or after November 2 is rejected and must be produced again. Divorce files closing in early November are the exposure, and the question to ask is which format the appraisal will be delivered on, not when it was ordered.
- Two standards in one file. From November a conventional refinance and an FHA or VA assumption on the same marital home produce appraisals built to different specifications. They are not comparable line by line, and neither is comparable to the general purpose report the marital estate was valued on.
- A photographed, dated defect list with repair costs. Deferred maintenance is contested in a large share of buyouts. It is now structured evidence with a soundness flag and a recommended action, surfaced on page one. It will help whichever party it helps, and it will be produced in discovery either way.
- The report records who inspected, and whether anyone did. A field reading no inspection, or a collector occupation of real estate agent, is available to opposing counsel in structured form for the first time.
- Two condition ratings, and possibly two values. Covered in the next section. A settlement reciting the appraised value is now ambiguous in a way it was not before.
- Cross-examination lore goes stale. Attacking a conventional appraisal on gross adjustment percentage, on the neighborhood trend checkbox or on the 1004MC means attacking fields that no longer exist. The habits are twenty years old and they retire on November 2.
- Market analysis is no longer standardized in scope. The lookback period is chosen by the appraiser. Two appraisals of the same property can rest on different market windows, and reconciling them requires reading a field that did not exist before.
- A reconsideration of value is now permanently recorded. Where one party pushes for a revision, the fact of the request, its date and its result are structured data in the report rather than correspondence in a file.
- The discovery question nobody has raised. The printed report is not the complete dataset. Whether the underlying data file is discoverable in a contested valuation is an open question, and we can find no published discussion of it.
SixTwo Conditions, and Possibly Two Values
The same conflation problem as assumption and release, in a different document.
The overall condition rating on the redesigned report is hypothetical. It reflects the condition of the property as if any required repairs, inspections or completions had been satisfactorily completed. A separate as-is overall condition rating carries the current state where the appraisal is made subject to something.
So a single report can carry two condition ratings that describe the same house differently, one of them describing a house that does not yet exist.
Alongside that sits a structured provision for client-requested conditions and alternate opinions of value, which allows one report to state more than one value: as-is and subject-to, and in some engagements a quick-sale or liquidation figure as well.
A settlement provision reciting the appraised value has always assumed there is one. On a report that carries an as-is value and a subject-to-repairs value, that phrase does not identify a number. It is the same defect as an agreement that says a spouse will assume the mortgage without saying who is released from it: a term that reads as settled and is not. The fix is the same in kind, which is to name which value, as of which effective date, from which report.
SevenThe Divorce Appraisal Is a Different Assignment
This part predates UAD 3.6 entirely, and the mandate makes it harder to ignore.
A divorce appraisal and a lender appraisal are different assignments with different clients, different intended users and, frequently, different definitions of value. Three consequences follow, none of them new, all of them about to be more visible.
The definition of value differs. The market value definition preprinted on the lender forms derives from federal financial institutions regulation and was drafted for mortgage collateral. Family law generally speaks in terms of fair market value, and the governing definition is whatever the relevant jurisdiction’s law supplies. An appraiser cannot alter preprinted certification language on a lender form. This, rather than layout or familiarity, is the substantive reason non-lending assignments are generally written on general purpose forms.
The clearest statement of that is printed on the lender form itself, which is the part most people have never read.
The intended use of this appraisal report is for the lender/client to evaluate the property that is the subject of this appraisal for a mortgage finance transaction. The intended user of this appraisal report is the lender/client.
The form states its own purpose and its own audience, and neither one is a divorcing spouse, an attorney, a mediator or a court.
The borrower, another lender at the request of the borrower, the mortgagee or its successors and assigns, mortgage insurers, government sponsored enterprises, and other secondary market participants may rely on this appraisal report as part of any mortgage finance transaction that involves any one or more of these parties.
That is the complete list of parties permitted to rely on the report, and every one of them is a party to a mortgage transaction. Item 21 goes further, requiring the appraiser’s consent before the report is disclosed or distributed to anyone outside that list. A lender appraisal handed to opposing counsel is being used by a party the document does not authorize, for a purpose it does not name.
The redesigned report does not change this. Fannie Mae states that the purpose of the URAR has not changed and that its opinions, conclusions and certifications are for the intended user to evaluate the property for a mortgage finance transaction or related activities. The new form is a better document in many respects. It is no more a divorce document than the old one was.
A lender appraisal cannot properly be repurposed for a divorce. The Appraisal Institute is direct that changing the name of the client and forwarding a readdressed report does not change the original appraiser-client relationship, and that a new client means a new assignment requiring a new report. The reverse also holds: a lender must order its own appraisal and cannot rely on the one obtained for the settlement. In practice a buyout produces two appraisals, and always did.
The effective date is frequently in the past. Valuation dates in dissolution are set by state law and vary widely, by separation, by filing, by trial or by dissolution, and in several states by judicial discretion. That makes many divorce assignments retrospective, and some require two effective dates in one engagement. None of that is a UAD question. All of it is a reason the divorce appraisal was never going to follow the lender form.
We are a lending organization, not an appraisal one. Nothing here instructs an appraiser on form selection, on scope of work or on compliance with the Uniform Standards of Professional Appraisal Practice, and nothing here should be read as legal advice on valuation date or standard of value in any jurisdiction. What we can say is what the lender’s appraisal will and will not contain from November, and what that means for a buyout number and for the language of a settlement.
EightWhat Nobody Can Answer Yet
Three open questions, and we have put the first of them to the companies that can settle it.
Whether the legacy and general purpose forms survive in the software. This is the question that decides what a divorce appraiser can actually produce on November 3, and it has no published answer. One vendor, SFREP, has stated that non-lender work will continue to require general purpose report types after the mandate date. That commits to the general purpose series. It does not commit to the numbered legacy forms.
Practitioner expectation runs the same way. TJ McCarthy, SRA, ASA, IFA, a founder of United Valuation with more than forty years in valuation, a past president of the Chicago Chapter of the Appraisal Institute and of the Illinois Coalition of Appraisal Professionals, a former chair of the Illinois Real Estate Appraisal Licensing Board and a member of the Appraisal Foundation’s State Regulatory Advisory Board, told us he expects the lender form family to retire fully from enterprise use on November 2, and the general purpose report to carry non-lending work from that point. The General Purpose Appraisal Report, the GPAR family published by Bradford Technologies, is the product most often named in that role, and other vendors maintain their own general purpose series alongside it.
That is informed expectation from an authoritative source, and we report it as such. It is not the same thing as a written commitment from the companies that maintain the software, which is what would actually settle it. a la mode, ACI and Bradford Technologies have published nothing either way. We have written to all three and will publish their answers, or the fact of their silence, in the next edition.
The risk is not that anyone prohibits the old forms, since no enterprise rule reaches non-lending work. The risk is product-line attrition: forms libraries that stop being maintained, and platforms whose forward development is entirely shaped by the new standard while the older product is quietly migrated away from.
Whether the underlying data file is discoverable. The printed report is a curated view. In a contested valuation, whether a party can compel production of the full dataset is a question we can find nobody addressing.
What the enterprises require at the margins. Minimum comparable counts and the minimum market lookback period are set in enterprise policy supplements rather than in the joint specification. We were unable to retrieve the full Fannie Mae supplement, and we would rather say so than infer.
We searched the appraisal trade press, the Appraisal Institute’s education materials on the redesigned report, the vendor guidance and both enterprises’ own FAQs. The total published material connecting this mandate to non-lending work amounts to two sentences, both of them reassurance rather than analysis. On the redesigned report as a court exhibit, on its interaction with expert testimony, and on divorce specifically, we found nothing at all.
NineAdoption Status, Program by Program
Where each loan program stands as of August 28, 2026.
| Program | Status | Authority and detail |
|---|---|---|
| Fannie Mae | Dated | Mandatory November 2, 2026, keyed to initial UCDP submission date. Warnings since August 6, 2026, fatal errors from the mandate. |
| Freddie Mac | Dated | Same schedule, same submission-date rule. Legacy pipeline clears May 3, 2027. |
| FHA | No date announced | FHA INFO 2026-15, June 25, 2026. Beta testing underway; an optional start date to be announced after testing; mandatory transition “at a future date.” Legacy forms continue past November 2. |
| VA | Nothing published | No circular or handbook change located. Named in the enterprise FAQs as a requirements contributor, which is not adoption. |
| USDA | Nothing published | Same position as VA. No published adoption date located. |
| Non-lending appraisals |
Out of scope | Divorce, estate, litigation and tax appeal work is not reached by the mandate. Land-only appraisals are expressly out of scope. General purpose report types are the vendor-documented product for this work. |
Statuses reflect published positions located as of August 28, 2026. Where a program has published nothing, this table says so rather than inferring a position from silence.
TenMethod, Sources, Corrections
How this was verified, and what we could not verify.
Dates, scope and enforcement mechanics were taken from the joint enterprise timeline and announcement log, Fannie Mae’s UAD 3.6 FAQ in its August 2026 version, Freddie Mac’s UAD and forms redesign FAQ, and the enterprises’ portal messaging announcements. Field-level detail was taken from the joint UAD specification, principally the URAR reference guide and the report style guide, which are the normative documents and are enforced by compliance rules at submission.
FHA status was taken from HUD’s own FHA INFO bulletin and preparedness materials rather than from trade coverage, which conflicts with them. Appraisal practice points on assignment, readdressing and reporting options were taken from the Appraisal Institute and the Appraisal Foundation. Intended use, intended user and reliance language was read from the published Form 1004 itself. Practitioner expectation on form availability after the mandate was given to us in conversation by TJ McCarthy, SRA, ASA, IFA, and is identified as such where it appears.
Not verified, and reported as such: any VA or USDA adoption date; the minimum comparable count and minimum market lookback period, which sit in enterprise policy supplements we could not retrieve in full; and whether the legacy and general purpose forms remain in the major software libraries after the mandate, which is the subject of written questions now outstanding.
This report will be reissued as the agencies act and as the software companies answer. Corrections are listed here in every edition, including our own. Edition One carries none. If you find an error in this document, tell us and it will appear in the next one under its own heading, with the date.
About the Divorce Lending Association
The Divorce Lending Association has been advancing divorce mortgage planning as a professional discipline since 2011. It creates and governs the Certified Divorce Lending Professional (CDLP®) designation and the Real Estate Mediation Specialist (REM-S™) certification, publishes practice standards and a code of ethics, and maintains a public national directory that any referring professional can check. It is an approved continuing legal education provider, an approved continuing judicial education provider, and an approved continuing education provider with CFP Board and the Institute for Divorce Financial Analysts.
About the author
Jody Bruns, CDLP® · President and Founder
Jody Bruns founded the Divorce Lending Association to give mortgage and real estate professionals education, resources and certification in divorce lending, and created both the CDLP® and REM-S™ certifications. She brings more than 35 years in mortgage and finance and continues to practice as an active divorce mortgage planner.
She is a certified mediator and mediator trainer, a licensed real estate continuing education instructor, and an approved continuing legal and judicial education provider. She has coached and trained more than 12,000 professionals across divorce mortgage and real estate, and is the author of A House Divided: The Clash Between Divorce, Real Estate & Mortgage Financing and Anchored in Faith: A 40-Day Devotional Journey Through Divorce.
Citation. The Divorce Appraisal Report, Edition One. Divorce Lending Association, August 28, 2026. Free to quote and reproduce unaltered with attribution.
© 2026 Divorce Lending Association, LLC. All rights reserved. CDLP® and REM-S™ are marks of the Divorce Lending Association. Reproduction is permitted only in unaltered form and with the attribution above.
This is not legal advice, and it is not appraisal guidance. It is a lending analysis prepared for family law professionals. It describes what enterprise and agency requirements ask of lenders and appraisers. It does not instruct appraisers on scope of work, form selection or professional standards, it does not advise on valuation date or standard of value in any jurisdiction, and nothing in it should be substituted for the judgment of counsel or of a qualified appraiser licensed in the relevant jurisdiction.
Primary sources. Joint UAD and forms redesign timeline and announcement log · Fannie Mae UAD 3.6 FAQ (August 2026) and UAD 3.6 Policy · Freddie Mac UAD and forms redesign FAQ and lender readiness kit · Joint UAD specification, URAR reference guide and report style guide · UAD condition and quality rating definitions · ANSI reporting requirements job aid · Fannie Mae Selling Guide B4-1.1-06 · HUD FHA INFO 2026-15 (June 25, 2026) and FHA UAD 3.6 preparedness materials · HUD Electronic Appraisal Delivery portal · Fannie Mae Form 1004 and Freddie Mac Form 70, intended use, intended user and appraiser’s certification · Appraisal Institute guidance on readdressing and reassignment · The Appraisal Foundation, USPAP 2024 edition.