Subject is a 3 level split, built 1970 No bedrooms above grade Basement has two bedrooms Basement bedroom window sills exceed FHA basement bedroom classification requirement for "Below grade valuation" ("Windowsill may not be greater than 44") (3-3 4150.2) ATTACHED Then there is a disclaimer to use reasonable judgement. Sale. FHA. Basement bedroom windows are daylight, large and meet the other two requirements defined by FHA Secondary info:Subject market time is typical for market Last sale in 2003 market time was typical for market I've determined adjustment for the basement bedrooms based on two measurements Looked at the sale in 2003 to determine the market reaction at that time Looked at the very few similar sales with only below grade bedrooms, outside the subject's market (with appropriate adjustments). Both of these indicate a similar adjustment Help me work this out. Do I state this as a 0-Bedroom Above grade property with 2-bedrooms below grade, and clearly note that the basement bedroom window sills do not meet the FHA critera spelled out in 4150.2 section 3-3. Note that the market appears to accept this property as a 2-bedroom below grade property. Note the cost to cure? Or am I missing something here? Off base? I will be out of the office for the next 2 hours, but appreaciate all comments/feedback.