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Does HUD have specific regulations on bedroom size?

jlc84690

Freshman Member
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Apr 16, 2024
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Certified Residential Appraiser
State
Missouri
I have been searching for the answer and have not been able to locate it in the HUD 4000.1 handbook. I have a lender pushing back on a room that I labeled and considered an office stating it is a bedroom and they want it changed to such. This is a very rural area with no building codes. Bedroom counts don't really matter once there are at least 2. This room was small in my opinion and I considered it an office and not a 3rd bedroom. It does have a window. They even asked for a ROV with the number of bedrooms being the reason. I stated in the report that the number of bedrooms in this market is not as important to a buyer as GLA and that the room has been given an adjustment in the GLA section of the gridline. Any idea on where to find the info?
 
I've never seen any 'official' HUD statement of minimum size for a bedroom. IRC says 70 square feet. Some local jurisdications may require more.... I think NY requires 80 square feet.
 
I have been searching for the answer and have not been able to locate it in the HUD 4000.1 handbook. I have a lender pushing back on a room that I labeled and considered an office stating it is a bedroom and they want it changed to such. This is a very rural area with no building codes. Bedroom counts don't really matter once there are at least 2. This room was small in my opinion and I considered it an office and not a 3rd bedroom. It does have a window. They even asked for a ROV with the number of bedrooms being the reason. I stated in the report that the number of bedrooms in this market is not as important to a buyer as GLA and that the room has been given an adjustment in the GLA section of the gridline. Any idea on where to find the info?
When you say it is very small...can a bed fit in it?
Imo, if the room can fit a bed, and one has enough room to move around after the bed is in? it has a window, and there is no building code, then functionally it could be a bedroom.

There are times to fight clients (if they push to change a value, or to ignore a safety or health condition ), but the label on a room might not be one of them...just saying.
 
I have been searching for the answer and have not been able to locate it in the HUD 4000.1 handbook. I have a lender pushing back on a room that I labeled and considered an office stating it is a bedroom and they want it changed to such. This is a very rural area with no building codes. Bedroom counts don't really matter once there are at least 2. This room was small in my opinion and I considered it an office and not a 3rd bedroom. It does have a window. They even asked for a ROV with the number of bedrooms being the reason. I stated in the report that the number of bedrooms in this market is not as important to a buyer as GLA and that the room has been given an adjustment in the GLA section of the gridline. Any idea on where to find the info?
I've never heard of any minimum size for FHA. It's not a hill that I personally would want to die on. If the utility of the room is diminished due to the size you could hit it for functional utility if the market recognizes a difference there. If not, I would tend to call it a bedroom, comment on the size and it's effect from a market standpoint, and move on.
 
Besides the label of the room, it could come down to comp choice or value as an issue - if the OP reported a 2-bedroom, did they use only 2-bedroom comps or did they also use some 3-bedroom comps ?

If they adjusted for sf and not bedroom count ( as it seems )- that is not an issue, however, did their judgment call about the room affect their comp choices and value? (since the lender sent an ROV)
It is easy to change a label on the room, but what else would that mean for the appraisal?
 
Mortgage lenders require bedrooms to meet the local building code standards (like the International Residential Code (IRC)). The baseline size to legally qualify as a bedroom is 70 square feet. Additionally, no wall-to-wall horizontal dimension can be less than 7 feet. [1, 2, 3]
Meeting the minimum footprint is just the first step. To count as a valid bedroom for a loan appraisal, the room must also include: [1]
  • Emergency Egress: A window or door that opens directly to the outside for fire safety. The window must meet specific size requirements (usually at least 5.7 square feet of total opening space).
  • Ceiling Height: At least half of the ceiling must be a minimum of 7 feet tall.
  • Accessibility: The room cannot serve as the only pathway to another bedroom (it must have its own entrance).
  • Heating/Cooling: Permanent heating and cooling elements (like HVAC vents or baseboard heaters) must be present. [1, 2, 3, 4, 5]
If a room is under 70 square feet or lacks these essential safety features, an appraiser cannot classify it as a legal bedroom. This may limit the bedroom count on your appraisal, directly impacting the property's overall valuation and the amount a lender is willing to finance. [1]

My comment: FHA may not have a separate requirement for bedroom size. However, FHA loans are also mortgage loans and reported on a UAD, so the lender requirement for a bedroom to be 70 sf minimum, imo, would apply. That makes it objective - either this room is a minimum of 70 sf or it is not. Even if it is a rural area that ignores building codes or has no buidling codes, the lenders still have their own minimums that apply. My reasoning on this - not an official citation.
 
I've never seen any 'official' HUD statement of minimum size for a bedroom. IRC says 70 square feet. Some local jurisdications may require more.... I think NY requires 80 square feet.
NY does not require an minimum square footage for a bedroom. The market determines whether a room can be considered a bedroom.
 
NY does not require an minimum square footage for a bedroom. The market determines whether a room can be considered a bedroom.
Lenders have a minimum requirement for a bedroom that is particular to them, rather than state-specific.

The market might determine if a room is valued as much as a bedroom in price; however, the market does not change building codes or lender minimum requirements.
 
I read somewhere that it had to have sufficient room for a bed and clothes storage. Or needed to have enough room to function as a bedroom.
 
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