AppraisalPilot

Field Report No. 03

Comp photos gone from the MLS? What UAD 3.6 requires

Reviewed by J. Marshall Hunt, on October 24, 2026

By J. Marshall Hunt, Founder, AppraisalPilot

Updated October 24, 2026

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The new report (UAD 3.6) still requires a photo of every comparable, typically the front, and a missing one is a Fatal message. What's disappearing is the interior photos that used to support each comp's quality and condition ratings. In Field Report No. 03, Josh Stalk, Licensed Residential Appraiser (NV), walks through what's changing, what the rules require, and how to support a comp when the photos are gone.

What's happening to listing photos?

On October 23, 2026, HousingWire reported that many MLSs have created ways to restrict the interior photos of sold listings that go out to the real estate portals, while keeping those images in an internal database for agents and appraisers. It named CRMLS, Canopy MLS and Flexmls among the MLSs with photo privacy controls for sold properties.

The backdrop, as HousingWire described it: consumers more worried about the privacy of their data as AI advances, and some agents steering sellers to private listings to avoid piling up days on market or a record of price cuts.

CRMLS spelled out its own policy on February 23, 2026. For closed listings (and leased, expired and canceled ones), it removes every photo except the primary photo from IDX syndication, the feeds that put listings on public websites. The photos stay in the MLS. They just aren't public. CRMLS's stated reason is consumer safety and privacy.

The Council of MLSs told HousingWire: "Consumer privacy and the needs of appraisers don't necessarily have to be competing priorities." It is working on best practices guidance.

What does the new report require for comp photos?

Three primary sources, in the GSEs' own words:

  • The photo and image job aid (Fannie Mae and Freddie Mac, v1.0, June 23, 2026) lists the required photos by section. For the Sales Comparison Approach, the required photo is "Property Photo (Subject and Comparables)."
  • The URAR Reference Guide (Appendix F-1 v1.4, page 221) describes it as "Photo of the property, typically the front."
  • The UAD compliance rules (Appendix H-1 v1.5) make a missing comp photo a Fatal message, rule UAD1275: "Provide a photo of each sales comparable used in the valuation." Fatal, not a warning.

Interior photos of comparables are not on the job aid's required list.

Do I still have to drive by my comps?

The old format's scope of work had you inspect each comparable sale from at least the street. For the new report, Fannie Mae says it has retired that requirement: "for appraisal reports in UAD 3.6 we have retired the requirement to inspect the comparable sales from the street," and appraisers "will be at liberty to source the required comparable photos at their own discretion."

That is Fannie Mae's policy, from its Appraiser Update (Q3 2025). Josh's point: you can still drive by, you just don't have to. A client's scope of work can still call for one.

What still needs support when the interior photos are gone?

The ratings. Every comp on the new grid still gets an overall quality rating (Q1 to Q6) and an overall condition rating (C1 to C6), plus an interior condition rating. Those are the ratings the interior photos used to support.

The grid also asks where your comp data came from. Data Source is required for every comparable, and you can pick more than one: MLS, assessor record, real estate agent, exterior inspection, previous appraisal file, property owner and more. If the source is MLS, the MLS number is required. More on the grid: comps from your MLS and the new URAR sales grid, and on the ratings: interior and exterior condition and quality on the new URAR.

Where do the photos still live?

Josh names three places.

  1. Inside your MLS. CRMLS says closed listing photos stay in the MLS, and HousingWire reports many MLSs keep them in an internal database for agents and appraisers. Check what your login can see.
  2. A second source. Cotality's chief valuation officer, Shawn Telford, told HousingWire that appraisers should verify property information with at least a couple of sources. Josh's suggestions: the assessor record, a previous appraisal file, and the listing agent. Ask the agent what was updated, when, and the condition of the kitchen and baths. The Field Notes have an email you can send.
  3. Your workfile. USPAP's Record Keeping Rule says the workfile must contain "all other data, information, and documentation necessary to support the appraiser's opinions and conclusions and to show compliance with USPAP, or references to the location(s) of such other data, information, and documentation." Josh's read: if a photo supports your condition rating, save it the day you pull the comp. It may not be public next month.

What if the comp sold as a private listing?

Verify it from other sources, get the photo yourself or from a reliable source, and report every data source you used. The new report's own scope of work, which Fannie Mae quotes, asks the appraiser to "research, verify, and analyze adequate and reliable data for the subject market area including data for each comparable property reported."

Two answers that don't work: dropping the comp because it never hit the MLS (the report's data source list has room for assessor records, agents, property owners and your own exterior inspection), and leaving the comp photo blank with a comment (a missing comp photo is a Fatal).

What should I do this week?

  1. Look up your MLS's photo policy for sold listings, and what your login can see.
  2. Save every comp's MLS sheet and photos to your workfile the day you pull them.
  3. Put a second source behind every comp's condition and quality.
  4. Fill in Data Source with every source you used, and the MLS number when it's MLS.

Items 2 and 3 are good practice, not a GSE rule. The Field Notes have the rules with their sources, a comp photo checklist, and an email you can send a listing agent.

Education, not legal or compliance advice. Check your client's and each GSE's current requirements.

Questions appraisers ask

Does the new report (UAD 3.6) require a photo of every comparable?

Yes. The GSEs' photo and image job aid lists the Property Photo for the subject and comparables as required in the Sales Comparison Approach, and the URAR Reference Guide describes it as a photo of the property, typically the front. A missing comp photo is a Fatal message in the UAD compliance rules (UAD1275).

Do I still have to drive by my comparables?

For UAD 3.6 reports, Fannie Mae has retired its requirement to inspect the comparable sales from the street, and says appraisers will be at liberty to source the required comparable photos at their own discretion. A client's scope of work can still call for a drive-by.

Are interior photos of comparables required?

No. Interior comp photos are not on the job aid's required list. But every comp on the new grid still gets an overall quality rating, an overall condition rating and an interior condition rating, and those ratings still need support.

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