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  #1  
Old 05-14-2010, 04:48 PM
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Default Final inspection, fannie form 1004D vs HUD form 92051

Several months ago, HUD issued a mortgage letter stating that Fannie form 1004D is an acceptable form for final inspections. Is there ever a situation where you should use the HUD compliance inspection report for a final inspection in lieu of the 1004D? Can the lender come back and request a change from the 1004D to the HUD compliance inspection report?
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Old 05-14-2010, 04:50 PM
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CIR for new construction and manufactured housing.
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Old 05-14-2010, 04:53 PM
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CIR for new construction and manufactured housing.
Sorry, I meant to exclude them! My wording should have been "for an existing SFR"
  #4  
Old 05-14-2010, 08:12 PM
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Just contacted the Santa Ana HOC about that. Following is the response that I received:

"That’s why AMC’s have to be clear when they request a “Completion of Repairs”, they should state what form they would like it on. They could want the CIR because the Underwriter must also sign it, that’s not the case with the 1004D. Either form is acceptable for us, except in the case of New Construction and Manufactured Homes."

And another comment from the HOC: "We are willing to accept either form at this time for repair items. Might want to inform the AMC the Mortgagee Letters are “Regulatory” and if they fail to adhere to them, the lender they represent can be sanctioned by HUD.

If they have issues with that, have them call the FHA Resource Center at 1-800-225-5342"

So I guess it is whatever the client orders. I am still going to have a statement on the CIR for repairs or conditions on an existing house that the CIR was completed at client's request and may or may not be in compliance with Mortgagee Letter 2009-51. Put all the responsibility on the AMC or client that orders the CIR.

Last edited by Jo Ann Meyer Stratton : 05-15-2010 at 09:38 AM.
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Old 05-14-2010, 08:18 PM
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Another example of SOW and Reporting issues that should be discussed at engagement and prior to report submission. Otherwise, don't get too bent out of shape if the lender zigs when you zag. It's their money, you are just a reporter, and they may desire certain report forms to meet their needs.
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Old 05-14-2010, 08:52 PM
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There is more to the story than I have revealed. Back in early February, I accepted an assignment from a MB for a FHA loan on a duplex. This was prior to FHA appraisals having to go the HVCC route. There were some repair issues that I had to made and the report was ...subject to repair. Early April, get an order to do the final. Submit final on the Fannie 1004D form since the mortgage letter had come out few months prior. Receive following stip via MB ..."
  1. I need the appraiser to provide a formal “Compliance Inspection” – I can’t use the FNMA completion report is needs to be on the HUD form
I reply back to MB.." After I read the stip I figured it must be the stagecoach folks! They should not be allowed to do FHA! Back a few months ago, HUD came out with one of their mortgage letters stating that final inspections can be done on 1004D form. Please reply that to Wells! (I figured it had to be Wells since I had had similar encounters with them on other FHA matters) Next day I receive a response via MB per follows:

I guess our stagecoach is broken down…. I purposely asked if I could take the FNMA form before I asked for it from you. Your appraiser is correct – I am ok with what he sent & I’ll clear the condition

Please tell the appraiser we aren’t all a bunch of morons around here

So, you would think that was the end of the story. Nope, received a call this afternoon from one of those idoits on the stagecoach again wanting the final on the CIR form. (The loan has long been closed) She explained that she was calling for her supervisor and had had discussions on this over the last 2 days. I explained the happenings previously and finally told her...NO.


  #7  
Old 05-14-2010, 09:26 PM
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Quote:
Originally Posted by David Sawyer View Post
So, you would think that was the end of the story. Nope, received a call this afternoon from one of those idoits on the stagecoach again wanting the final on the CIR form. (The loan has long been closed) She explained that she was calling for her supervisor and had had discussions on this over the last 2 days. I explained the happenings previously and finally told her...NO.
Mortgagee Letter 2009-51 did not go into effect until February 15, 2010 and applies only to case number assignments on or after that date. In other words, if the case number was assigned prior to 2/15/10 then a CIR has to be used for the final inspection. It doesn't matter when the final inspection was ordered.
  #8  
Old 05-14-2010, 09:45 PM
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Originally Posted by james stephens View Post
Mortgagee Letter 2009-51 did not go into effect until February 15, 2010 and applies only to case number assignments on or after that date. In other words, if the case number was assigned prior to 2/15/10 then a CIR has to be used for the final inspection. It doesn't matter when the final inspection was ordered.
MORTGAGEE LETTER 2009-51
TO: ALL APPROVED MORTGAGEES
ALL FHA ROSTER APPRAISERS
SUBJECT: Adoption of the Appraisal Update and/or Completion Report (Fannie Mae Form 1004D/Freddie Mac Form 442/March 2005)
The Federal Housing Administration (FHA) is adopting the Appraisal Update and/or Completion Report, Fannie Mae Form 1004D/Freddie Mac Form 442/March 2005. This is a dual-purpose form. Part A, Summary Appraisal Update Report, provides for updates of existing appraisals when the appraiser concurs with the original appraisal report and updates the appraisal by incorporating the original appraisal report. Part B, Certification of Completion, provides for compliance repair and completion inspections for existing and new construction dwellings. This mortgagee letter is effective for all case number assignments on or after January 1, 2010.

James, please read effective date in red above!


  #9  
Old 05-14-2010, 09:57 PM
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Quote:
Originally Posted by David Sawyer View Post
This mortgagee letter is effective for all case number assignments on or after January 1, 2010.

James, please read effective date in red above!
David, please read below...


FHA Appraisal Process Delayed Until Feb 15

HUD Mortgagee Letter, FHA Mortgagee Letters, HUD FHA Realestateloans.com — Posted by jerroldmayer @ 05:09

Delayed Implementation Date for New Requirements in ML 2009-28

Enactment of ML 2009-28, Appraiser Independence, will be delayed until February 15, 2010. ML09-28 (originally planned for a January 1, 2010 implementation) has two parts: a) prohibition of mortgage brokers and commission-based lender staff from the appraisal process, and b) appraiser selection in FHA Connection. The effective date for both sections of this guidance will now take effect for all case numbers assigned on or after February 15, 2010. This extension will provide FHA and lenders additional time to adjust systems to accommodate the changes.

Detailed instructions on changes to FHA Connection will be issued in a new mortgagee letter. However, lenders should be aware that the requirement for inputting the appraiser ID and the appraisal assignment date in the FHA Connection case number assignment screen will be removed. Instead, lenders will be required to enter all appraisal data, including the appraiser ID, in the Appraisal Update Screen once the completed appraisal is received by the lender and prior to closing the loan.

Delayed Implementation Date for ML 2009-51

ML 2009-51, Adoption of the Appraisal Update and/or Completion Report, states an effective date of January 1, 2010. The effective date is being extended and will now apply to all case numbers assigned on or after February 15, 2010. This extension will provide additional time needed by FHA and lenders to adjust their systems to accommodate use of the form.
  #10  
Old 05-14-2010, 11:02 PM
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I've talked to FHA about using the CIR. He said that we MUST use the 1040D unless it is for new construction or manufactured housing. The lender can not tell us to use the CIR.

What is irritating is that they want us to add comments to the form. ie Subject mets HUD/FHA minimum property requirements in handbook 098765432456789-4.34567890

The only place to add these is the space that you write in IF you check the box "NO"
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