Walked away mid-inspection/vent

[CANative]

absolutely, note in the report, just as when there is no safe access.

The same is not true for attics and crawl spaces.

 

[MRB]

The same is not true for attics and crawl spaces.

then HUD's directive is contradictory considering a ghost instruction to condition the report.

 

[CANative]

I don't think so. HUDs rules and regulations are codified in government style handbooks and communications (note mortgagee letters... very similar to how the military does things.)

The requirement is for the appraiser to complete a head and shoulders (at a minimum) observation of the attic and crawl space. This is specific. It goes on to say that if access is not possible to note this in the report. It does not say that this means to just make assumptions or to move on without condition. The requirement is still there.

In this case, it's what is NOT stated that is important.

 

[MRB]

I don't think so. HUDs rules and regulations are codified in government style handbooks and communications (note mortgagee letters... very similar to how the military does things.)

The requirement is for the appraiser to complete a head and shoulders (at a minimum) observation of the attic and crawl space. This is specific. It goes on to say that if access is not possible to note this in the report. It does not say that this means to just make assumptions or to move on without condition. The requirement is still there.

In this case, it's what is NOT stated that is important.

consider recent revisions, however I will not belabor. Maybe I'll just carry a saber saw on inspections and if the borrower becomes a bit unruly, suggest expediting the process and start cutting.

 

[CANative]

What's the big deal? The appraiser just states that there was no access to the attic or crawl space and condition the appraisal on inspection under the EA that there is nothing wrong.

The DEU has the authority to waive the condition or can inform their borrower that they have to do what it takes to allow appraiser access. If the second option is the way they want to do it then the appraiser just goes back out and reinspects and issues a 1004D.

 

[MRB]

I don't think so. HUDs rules and regulations are codified in government style handbooks and communications (note mortgagee letters... very similar to how the military does things.)

The requirement is for the appraiser to complete a head and shoulders (at a minimum) observation of the attic and crawl space. This is specific. It goes on to say that if access is not possible to note this in the report. It does not say that this means to just make assumptions or to move on without condition. The requirement is still there.

In this case, it's what is NOT stated that is important.

What's the big deal? The appraiser just states that there was no access to the attic or crawl space and condition the appraisal on inspection under the EA that there is nothing wrong.

The DEU has the authority to waive the condition or can inform their borrower that they have to do what it takes to allow appraiser access. If the second option is the way they want to do it then the appraiser just goes back out and reinspects and issues a 1004D.

I completed finals for a client who removed two separate appraisers from their roster who completed the appraisal report. One was for carbon monoxide detectors outside all bedrooms. The other was for door knobs on two interior doors and a handrail in a stairway leading to the unfinshed attic.

 

[residentialguy]

The requirement is for the appraiser to complete a head and shoulders (at a minimum) observation of the attic and crawl space. This is specific. It goes on to say that if access is not possible to note this in the report. It does not say that this means to just make assumptions or to move on without condition. The requirement is still there.

In this case, it's what is NOT stated that is important.

What's the big deal? The appraiser just states that there was no access to the attic or crawl space and condition the appraisal on inspection under the EA that there is nothing wrong.

The DEU has the authority to waive the condition or can inform their borrower that they have to do what it takes to allow appraiser access. If the second option is the way they want to do it then the appraiser just goes back out and reinspects and issues a 1004D.

Absolutely correct.


MRB, are you now saying something different? I just stated to subject it and let the DEU decide and you agreed. I'm getting a bit confused.

 

[MRB]

Absolutely correct.


MRB, are you now saying something different? I just stated to subject it and let the DEU decide and you agreed. I'm getting a bit confused.

I acknowledged, point well taken. Believe or not I try to be as least confrontational as possible.

 

[timd354]

nowhere does it say if there is no safe access, the appraiser is to condition the report, subject to running a drywall knife through a finely plastered ceiling to appease and overzealous appraiser.

I never said that the appraiser should condition the report to running a knife through drywall of a plastered ceiling - you read much more into my post than what I actually stated. In my opinion, appraisers who encounter the situation where there is no access to an attic or a crawl space for a FHA appraisal inspection should simply condition the report on a final inspection of the attic or crawl space (they should not condition for the property to be modified - as that is not the appraiser's problem...it is up to the lender and property owner to figure out how to provide access) However, since the condition for the inspection of the attic or crawl space cannot possibly be met in such cases unless access is provided, it is clear that the FHA in essence requires the structure to be modified in order to provide access to the appraiser (again, not the appraiser's problem or issue). Otherwise the appraisal eventually submitted by the lender to FHA will not meet the FHA valuation protocol.

The DEU could waive the requirement I suppose, but in my experience I have never seen this requirement waived by a DEU and suspect that a DEU that did make it a habit of waving this requirement would eventually no longer be a DEU.

 

[timd354]

What's the big deal? The appraiser just states that there was no access to the attic or crawl space and condition the appraisal on inspection under the EA that there is nothing wrong.

The DEU has the authority to waive the condition or can inform their borrower that they have to do what it takes to allow appraiser access. If the second option is the way they want to do it then the appraiser just goes back out and reinspects and issues a 1004D.

Or the appraiser goes back out for the reinspection and has a major hissy fit because of some reasonable request from the borrower and stomps off without ever completing the reinspection.