Appraisal Reports Face New Data Privacy Concerns
Homeowners with conventional mortgages should know that UAD 3.6 appraisal reports can be stored and shared downstream.
Updated on Nov. 2, 2026 in Residential
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Appraisers are raising data privacy concerns about Certification 25 of the Uniform Appraisal Dataset (UAD) 3.6, the form standard that governs how appraisal reports are used for mortgage finance. Some appraisers have stopped doing work for Fannie Mae and Freddie Mac over the certification's data-access terms as UAD 3.6 begins to take effect.
Why it matters
Certification 25 states that appraisers bear no liability for use of their reports outside the mortgage transaction and must certify that downstream entities can permanently store, analyze, distribute and harvest report data. Appraisers say this conflicts with the broader push for consumer data privacy in real estate, and that it could create animosity and lawsuits from borrowers.
Certification 25 follows Certification 21, which contains similar data-access terms. Fannie Mae and Freddie Mac maintain a proprietary database covering every dwelling that has had a loan, and appraisal reports now include interior photos and copyrighted MLS images.
The players
Fannie Mae and Freddie Mac
The government-sponsored enterprises that buy mortgages and set appraisal standards, and that maintain a proprietary database on every dwelling that has had a loan.
Desiree Mehbod
An appraiser who has stopped doing appraisal work for the GSEs over Certification 25.
The details
Appraisers include interior photos of properties in their reports, and Certification 25 requires them to sign off on downstream data use. Under the certification, the appraiser is aware that some parties may use report data without their permission, yet the appraiser carries no liability for that outside use. Appraisers argue that once a report is stored, analyzed and distributed by downstream entities, the homeowner's property data travels well beyond the original lending decision.
Timeline
Certification 21 set the predecessor data-access terms that Certification 25 resembles.
Fannie and Freddie forms with downstream data access were introduced in the early 2000s.
UAD 3.6 is just beginning to go into effect.
An article on Certification 25 data privacy concerns was published on November 2, 2026.
The Home Front
The data-access terms trace back to Fannie and Freddie forms introduced in the early 2000s, which already granted downstream data access. Certification 25 continues that pattern as UAD 3.6 takes effect, placing appraisal data handling squarely within the mortgage finance system.
If you are buying or refinancing with a conventional loan, ask your lender whether your appraisal will use the UAD 3.6 form and what data-use terms apply to your report. Keep a copy of your appraisal report and any consent or disclosure forms you sign, since they document how your property data may be used later.
The takeaway
The appraisal report that supports your mortgage can carry your home's interior photos and property data well beyond your loan. Before you sign, ask your lender or appraiser how your report will be stored and shared, and keep a copy of your appraisal for your records.
Further reading
For more on how home-sale rules and mortgage standards shape buying and owning, browse the Residential real estate section.
Source note: This article includes information reported by HousingWire.
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