UAD 3.6 appraisal fees are up about $65. Is yours?

Early data says fees on the new report (UAD 3.6) are up about $65 per report. Whether yours went up is a different question, and the answer is in your own numbers. In Field Report No. 02, Josh Stalk, Licensed Residential Appraiser (NV), walks through what the data says, what federal law says about how lenders pay fee appraisers, and how to build your own number before the next order comes in.

What does the early data say?

On October 7, 2026, Clear Capital shared numbers from more than 2,100 reports on the new format, as reported by National Mortgage Professional.

Fees: up about $65 per report, in the markets with enough volume to compare the two formats. It varies by market.
Turn times: up a little at first.
Speed: appraisers got about 28 percent faster on the new report as they got used to it. That compares new reports with new reports, not with the old format.

Then a survey. Working RE reported a Corporate Settlement Solutions survey in which 66.7 percent of 831 appraisers expect to raise their fees. Among the 214 who had already done a new report, it was 82.2 percent.

Not every client agrees. One management company emailed its appraisers: "we do not currently have sufficient support of a fee increase above the standard for this assignment."

What does federal law say about appraisal fees?

Here's the part a lot of appraisers have never read. Regulation Z, the Truth in Lending rules, section 1026.42, paragraph (f).

On a covered transaction, a consumer loan secured by the borrower's principal dwelling, the lender and its agents (like a management company working for it) must pay a fee appraiser "at a rate that is customary and reasonable for comparable appraisal services performed in the geographic market of the property being appraised."

The rule also spells out how a lender can show it complied. It starts from recent rates paid for comparable work in that market, then reviews six factors and makes any adjustments needed:

The type of property
The scope of work
The time in which the work is required to be performed
The appraiser's qualifications
The appraiser's experience and professional record
The appraiser's work quality

And the lender and its agents must not engage in anticompetitive acts, like price fixing, that affect what fee appraisers are paid.

Josh's point: scope of work is on the list, and the new report asks for more on every file.

How do I build my own number?

Not his number, not the forum's. Yours. Three pieces:

Your hours. Time your next three new reports, from the order to the export. Don't guess.
Your rate. What an hour of your licensed work is worth to you.
Your costs. Software, data, insurance, everything that comes off the top of every file.

Hours times rate, plus costs. That's your floor. Anything under it, you're paying to do the work.

What do I send when a client says there's no support for a higher fee?

Your scope, your time per file, and your fee. What the new report asks for, how long your files actually take, and what you charge. Then they decide, and so do you.

Two answers that don't work: saying nothing and taking the order at the old fee, which tells them the old fee covers the new work, and quoting a fee you saw another appraiser post online, which isn't your scope, your time or your costs. Agreeing on fees with other appraisers can be price fixing. Your fee is yours.

What should I do this week?

Time your next three new reports, from the order to the export.
Write your floor: hours times your rate, plus your costs.
Put the scope in your quote. It's the new report, and it asks for more on every file.
Get faster. Appraisers in Clear Capital's data got about 28 percent faster with practice. Your time is the one number you control.

The Field Notes have the six factors, the floor worksheet, and a reply you can send.

Education, not legal or financial advice. Your fee is your decision.

Questions appraisers ask

How much have UAD 3.6 appraisal fees gone up?

In early data Clear Capital shared on October 7, 2026, from more than 2,100 new reports, fees were up about $65 per report in the markets where the two formats could be compared. It varies by market.

Does federal law say what a lender has to pay an appraiser?

Regulation Z, 12 CFR 1026.42(f), says the lender and its agents must pay a fee appraiser a rate that is customary and reasonable for comparable work in the property's market, on consumer loans secured by the borrower's principal dwelling. It does not set a dollar amount.

Is scope of work one of the factors in the rule?

Yes. To show it pays a customary and reasonable rate, a lender starts from recent rates in the market and reviews six factors, adjusting as needed. Scope of work is one of them, with the type of property, the time in which the work is required, and the appraiser's qualifications, experience and professional record, and work quality.