Quick Answer: Few loans close exactly on schedule. Contracts get extended, builders run late and repairs take longer than planned. When that happens, the appraisal may age past agency limits, or the value may depend on work that is not finished yet. Fannie Mae Form 1004D, the Appraisal Update and/or Completion Report, is the tool lenders have used to handle both situations.
This guide explains what the 1004D does, when Fannie Mae requires an update, how completion reports work, how FHA differs, and what replaces the 1004D under UAD 3.6.
What Is Form 1004D?
Form 1004D is Fannie Mae's Appraisal Update and/or Completion Report. Freddie Mac uses the same form under the number 442. It has two separate uses, and the appraiser completes the section that matches the assignment:
- Summary Appraisal Update: confirms whether the property's value has declined since the original appraisal date.
- Certification of Completion: confirms that the conditions in a subject-to appraisal, such as repairs or construction, have been met.
The form's instructions say that, at a minimum, the appraiser completing an update must concur with the original appraisal, inspect the exterior of the property from at least the street and research current market data. A 1004D does not replace the original report. It is tied to it.
Fannie Mae Appraisal Age Rules
Fannie Mae's age limits are set out in Selling Guide section B4-1.2-04. The main rules are:
- The property must be appraised within the 12 months before the date of the note and mortgage.
- If the appraisal is more than four months old on the note date, the appraiser must complete an update that includes an exterior inspection.
- The update must be completed within the four months before the note date.
- If the update shows the value has declined, the lender must obtain a new appraisal.
- An appraisal more than 12 months old needs a new appraisal, even with an update.
- A desktop appraisal more than four months old needs a new appraisal rather than an update.
Fannie Mae says the original appraiser should complete the update, but lenders may use a substitute appraiser. The substitute must review the original report and state whether its value was reasonable as of the original date, and the lender must document why the original appraiser was not used.
How Completion Reports Work
When an appraisal is made subject to completion or repairs, the lender must confirm the work was done. Under Fannie Mae section B4-1.2-05, the Completion Report can rely on an on-site inspection, and virtual inspections, digital photos and site videos are also allowed. Photos and other exhibits must be unaltered and able to be authenticated with metadata and the property's geocode.
Fannie Mae separates minor items from major ones. Minor items may be handled as-is, and the lender is not required to make sure they are repaired before sale. Items that affect safety, soundness or structural integrity require a subject-to appraisal and verified completion before the loan is sold. For new construction, a letter signed by both the builder and the borrower, with interior and exterior photos, can be used in place of a 1004D. Postponed improvements on new construction must be finished within 180 days of the note date and cost no more than 10% of the as-completed value, with the lender holding back 120% of the estimated cost.
How FHA Handles Updates and Completion
FHA adopted Form 1004D through Mortgagee Letter 2009-51. Under that letter, the completion section may be done by the original appraiser or another FHA roster appraiser in good standing, while the update section is limited to the original appraiser. FHA did not allow the 1004D to replace Form HUD-92051, the Compliance Inspection Report, for new construction and manufactured housing.
FHA's age rules also differ from Fannie Mae's. Under Mortgagee Letter 2022-11, an FHA appraisal is valid for 180 days from its effective date, and an updated appraisal is valid for one year from the original effective date. Lenders should confirm the current requirements in HUD Handbook 4000.1, since FHA guidance is consolidated there and can change.
What Replaces the 1004D Under UAD 3.6?
Form 1004D is one of the legacy forms Fannie Mae and Freddie Mac are retiring under the redesigned Uniform Appraisal Dataset, UAD 3.6. In its place, the GSEs use two separate reports: the Restricted Appraisal Update Report and the Completion Report. Each is submitted to the Uniform Collateral Data Portal and tied to an existing UAD 3.6 appraisal. The GSEs' reference guide notes that the Completion Report does not provide an opinion of value.
For appraisals still on the legacy UAD 2.6 format, the 1004D process is unchanged. The key dates are:
- Broad production of UAD 3.6 began January 26, 2026.
- UAD 3.6 becomes mandatory for new GSE appraisal submissions on November 2, 2026.
- Lenders approved for Fannie Mae's temporary exception under Lender Letter LL-2026-08 may keep submitting new UAD 2.6 reports through May 19, 2027, but from March 1, 2027 those reports lose collateral risk scoring and value-related rep and warranty relief.
- UAD 2.6 is fully retired on June 28, 2027.
Our article on UAD 3.6 compliance for lenders covers what lenders should have in place for the transition.
Tips for Ordering Updates and Completion Reports
Most delays with updates and completion reports come from timing and communication rather than the work itself. A few habits help:
- Track appraisal age from the effective date, and order updates before the four-month mark rather than at the closing table.
- Order the completion report as soon as the borrower or builder confirms the work is done.
- Ask for the original appraiser first, since Fannie Mae prefers it and FHA's 2009 guidance limited updates to the original appraiser.
- Tell the appraiser which report format the original appraisal used, so the follow-up report matches it.
- Keep photos and documentation in the file, since they support the loan's eligibility later.
Our guide to the appraisal order lifecycle shows where these follow-up orders tend to stall.
How R3 AMC Handles Follow-Up Orders
Updates and completion reports are routine follow-up orders for R3 AMC, which places residential appraisals across the country for conventional, FHA, jumbo, non-QM, USDA and portfolio loans. Before a report goes to the lender, it passes ValueTest.ai research, USPAP and agency guideline checks, and a human reviewer. The company reports more than 500 active appraisers and an average five-business-day turnaround, and it was a preferred beta tester for UAD 3.6.
Frequently Asked Questions
What is a 1004D used for?
Form 1004D is used to update an aging appraisal or to certify that repairs or construction in a subject-to appraisal were completed. Freddie Mac uses the same form as Form 442.
How old can an appraisal be for a Fannie Mae loan?
The appraisal must be dated within the 12 months before the note date. If it is more than four months old, an update is required, and the update must be completed within the four months before the note date.
Can a different appraiser complete the 1004D update?
Fannie Mae prefers the original appraiser but allows a substitute who reviews the original report, with the lender documenting why. Under FHA Mortgagee Letter 2009-51, only the original appraiser may complete the update section.
Is the 1004D going away?
Yes, for UAD 3.6 appraisals. It is replaced by a separate Restricted Appraisal Update Report and Completion Report, while legacy UAD 2.6 appraisals keep using the 1004D until that format is retired on June 28, 2027.
Does a completion report give a new value?
No. A completion certification confirms that the conditions in the original appraisal were met. The UAD 3.6 Completion Report also does not provide an opinion of value.
Need an appraisal partner? Call R3 AMC at (702) 658-1191 or contact the R3 AMC team.
Key Takeaways
- Form 1004D handles two jobs: appraisal updates and completion certifications.
- Fannie Mae requires an update when an appraisal is more than four months old on the note date, and a new appraisal after 12 months.
- A decline in value on the update means a new appraisal is required.
- FHA appraisals follow their own validity periods and update rules.
- Under UAD 3.6, the 1004D splits into a Restricted Appraisal Update Report and a Completion Report.
- R3 AMC manages residential appraisal orders nationwide. Contact R3 AMC to place an order.
