FHA Attic Access

[Scott R Marshall]

What bothers me about CB4 is the "subject to the following required inspection". I wish they hadn't included that because that is still calling for an inspection, regardless of the lender coming back with "don't worry about it"

How do you get around that?

I guess the way I have reconciled that quandry is by placing the ball in the lenders court. Just because it say "required" inspection, the lender and underwriter still have the option to waive the inspection. My opinion of market value is still viable as I am assuming there are no issues which would require repair if the inspection is performed. If an inspection is performed which shows issues than my opinion of market value may be impacted based on this "new" information. If the lender requires it then so be it.

Sometimes, in cases like this, the inspection report itself is sufficient for me to issue a 1004D form. In cases like this I attach the form to the original assignment, attach the inspection report and send the entirety of the report back to the client, typically at no additional charge as the additional work in most instances is nominal. In addition, I disclose within the 1004D form itself that no re-inspection of the subject was deemed necessary as the inspection report "required" indicated that the issue noted within the original report did not require repair, meaning my extraordinary assumption was correct. If I need to go back out and re-inspect and/or take additional photos, I will charge for that.

 

[residentialguy]

Sounds like a good plan, Scott.

One could argue that since it is required, CB3 should be checked for access alterations...or as RSW stated, stopped at mid-stream (which I don't like). They really need a CB5, for cases like this.

 

[Delta85]

Hey Everyone
Got an attic access question.....I am appraising a dwelling that is 6 years old. The property owner told me that the previous owner or builder sealed the scuttle access to the attic. The scuttle was supposedly located in the walk-in closet area. At the time of inspection, there was no access to the attic. Where the scuttle was looks like the remainder of the ceiling area within the closet, drywall, taped and painted.

I stated this in the report, that the scuttle has been sealed and the appraiser was unable to inspect.

This report got kicked back and they indicated they want the subject made - 'Subject to Attic Inspection'. I made the report 'As-Is' and mentioned the above.

Are they seriously going to make a homeowner cut out the ceiling so an appraiser can inspect the attic area? Has anyone ever encountered this?

We have to have access to the attic. It's not our problem how those arrangements are made. If it's unsafe perhaps call for a home inspector or licensed contractor to take over where your due diligence ends.

 

[RSW]

RSW,


I agree with you in principal but I have run into instances where for whatever reason it could not be done (whether attic or crawlspace). In those instances I have always CB4'd them. In an instance where perhaps it was possible to easily re-inspect once an easy repair was made, maybe I would work with the owner on attempting to reshedule a time when I can re-inspect. However, I have run into instances where a crawlspace has been sealed up. In some cases, especially with reverse mortgages, the owner has no idea where it is as maybe it is under the carpet or buried under a bunch of stuff in a closet. In my experience it has been easier to simply CB4 it and explain the situation. A bit different in the case of attics/scuttles although I have also run into 1 instance where the panel to the scuttle was sealed. In that instance, the subject was less than a 10 minute drive from my home and re-inspection was easy. If it were a 45 minute drive maybe my reaction would have been slightly different. As harsh as this sounds, time is money and I am not making a second trip for free when it is no fault of my own.

I am sure we have all run into this and have all handled it differently dependant on the situation. I'm just saying I have run into cases where "making it right" was going to be either a big issue for the borrower, myself or both. I guess my only other alternative is to refuse to complete the assignment until such a time when the issue is remedied.

So, it is a matter of conenience for you if you are going to complete the appraisal report per HUD/FHA protocol? Now I am starting to question your ethics completely. I don't think there is a grey area as far as I am concerned. Either complete the appraisal report according to HUD/FHA protocol or don't do them. Simple as that!

 

[RSW]

What bothers me about CB4 is the "subject to the following required inspection". I wish they hadn't included that because that is still calling for an inspection, regardless of the lender coming back with "don't worry about it"

How do you get around that?

You can't get around it. You are still on the hook as the appraiser. How can you make a statement that the subject meets HUD/FHA's MPRs when you have not fully inspected the subject property. I am not going to do it.

I believe we are both on the same page with this topic.

 

[residentialguy]

You can't get around it. You are still on the hook as the appraiser. How can you make a statement that the subject meets HUD/FHA's MPRs when you have not fully inspected the subject property. I am not going to do it.

I believe we are both on the same page with this topic.

I don't state that they meet MPRs if they don't or I can't verify, I state that they don't meet them or that I do not have the ability to check, ie snow, sealed attic, etc. Do you stop the appraisal mid-stream when you find anything that doesn't meet MPRs? It's one thing to find a cess pool of toxic waste in the back yard, but sealed attic is an easy fix.

 

[RSW]

I don't state that they meet MPRs if they don't or I can't verify, I state that they don't meet them or that I do not have the ability to check, ie snow, sealed attic, etc. Do you stop the appraisal mid-stream when you find anything that doesn't meet MPRs? It's one thing to find a cess pool of toxic waste in the back yard, but sealed attic is an easy fix.

It is a requirement to state that they meet or will meet MPRs if repairs are necessary.

 

[Mr Rex]

The most recent protocol is from the revised Appendix D. It says:

If unable to visually evaluate the improvements in their entirety, contact the lender and reschedule a time when a complete visual inspection can be performed. This includes access to the crawl space and attic. The appraiser is not required to disturb insulation, move personal items, furniture, equipment, plant life, soil, snow, ice or debris that obstructs access or visibility.​

 

[RSW]

The most recent protocol is from the revised Appendix D. It says:

If unable to visually evaluate the improvements in their entirety, contact the lender and reschedule a time when a complete visual inspection can be performed. This includes access to the crawl space and attic. The appraiser is not required to disturb insulation, move personal items, furniture, equipment, plant life, soil, snow, ice or debris that obstructs access or visibility.​

Exactly! Nowhere does it say to complete the report "Subject To" an inspection of the attic.

 

[residentialguy]

It is a requirement to state that they meet or will meet MPRs if repairs are necessary.

I do state that they meet or will meet MPRs if repairs are necessary.

If unable to visually evaluate the improvements in their entirety, contact the lender and reschedule a time when a complete visual inspection can be performed. This includes access to the crawl space and attic

Exactly! Nowhere does it say to complete the report "Subject To" an inspection of the attic.

These are guidelines. They don't say that you can't do it the other way. The end result is the same, so I don't think we have to worry about the HUD guideline police coming to take us to prison cell block FHA. It is much less confusing by doing the appraisal subject to and doing a re-inspection. They don't have to cancel an order and re-order with a higher fee for re-inspection. It takes much longer to complete the assignment by stopping mid-stream and then completing the appraisal after it has been opened up. I can have the appraisal completed and gone through UW while waiting for the final and when it's done, I can have it wrapped up in 5 minutes after re-inspection.