FHA Attic Access

[Couch Potato]

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



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.

No! FHA has requirements, not guidelines.

 

[residentialguy]

No! FHA has requirements, not guidelines.

And that is not a requirement, it is a guideline...and it is a guideline that does not specify when you have to contact your lender or how to handle it.

 

[residentialguy]

" 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.​

An inspection done in accordance with these guidelines is visual and is not technically exhaustive."

 

[Scott R Marshall]

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!

So now my ethics come into question. :Eyecrazy: Look, do what you think is appropriate. I am doing what I think is appropriate. Whether you want to hold up the appraisal, complete it "subject to" that inspection or complete it "subject to" repair so you can perform the inspection, that is your call. At the end of the day, I have not withheld anything in submitting the report, I have only stated what could not be inspected for whatever reason and as FHA/HUD says its a requirement, I am leaving it in their capable hands by calling for the inspection if they are so inclined. My decision to not spend or to spend additional time without additional compensation is my own business decision.

For the record this has happened to me 3 times. The first time I already mentioned and as it was close by a quick re-inspection was no big deal and the report was held up. The other time was an instance where the crawlspace had been sealed over and the only way anyone was going to see it was do either cut a hole in the floor or blast a hole in the exterior wall. That one was not close by. I let the client know and was told to proceed in completing the report. So they got a CB4 appraisal (my judgement as to how to best complete the assignment given the request to complete it) and I never was called back to go back out a re-inspect. The third time was for a reverse mortgage and there was an elderly lady who met me at the inspection. She had no idea where the interior panel for the crawlspace was and the panel for the scuttle was in a closet loaded with stuff. I called the client and was told to re-inspect at a later date before turning in the assignment and received an additional fee.

All I was attempting to imply in my post is that the "solution" may very well be a case by case basis dependant on how difficult it will be for the appraiser to re-inspect and/or how difficult it will be for the borrower to comply with the request and/or the clients response once told the issue on whether to proceed or hold up the report and/or the compensation which is agreed upon if re-inspection is necessary. Or it can be, as you said, only black and white and the report will always be held up no matter what.

 

[RSW]

I have spoken with the HOC several times on this issue and have been informed that the appraisal is not to be completed until the attic is inspected. It is very intersting how many appraisers can decide to not follow protocol in the name of holding up the closing. There is only one instance that I am aware of where the appraisal can be made subject to an inspection and the DEU can wave that inspection to keep from holding up the closing and that is when snow covers the roof and will not melt in a few days. That is not the appraiser's decission: It is the DEU's decission. FHA appraisal protocol does not change.

 

[residentialguy]

Show me where is says to stop in mid stream. I do contact the lender and reschedule a time when a complete visual inspection can be performed...but I finish the rest of the appraisal report and send it in with the report saying exactly that.

 

[residentialguy]

It is very intersting how many appraisers can decide to not follow protocol in the name of holding up the closing.

It's very interesting to see an appraiser who likes to pizz off their good clients when they're so far and few. Tells me that they're doing a lot of AMC work or no work and living in the past.

 

[Scott R Marshall]

RSW,


In my examples the closing will still be held up if the client or underwriter so desires. If you look at the OP's first post, the client is asking him to complete the report in a manner consistent with how I have completed them in the past. As stated, the number of appraisals I have completed in this manner has been a very small percentage of my overall FHA work as most homes have access to attics and crawlspaces or the issue can be remedied in a way which is mutually agreeable to both the borrower, the client and myself.

There is only one instance that I am aware of where the appraisal can be made subject to an inspection and the DEU can wave that inspection to keep from holding up the closing and that is when snow covers the roof and will not melt in a few days.

And no where in the handbook does it say this is acceptable as well but FHA/HUD has made a decision based on the unique nature of the situation to waive the requirement. And I say if there is one scenario where they may there may be more as FHA/HUD does not see there own requirements in black and white in this instance. By making the report CB4 I am allowing the DEU to decide if this is such a case.

The issue the OP may be facing is the non-communication to the client about the scenario. I look at the non-inspection of these areas for FHA/HUD in the same manner I would handle a home where I was not able to inspect a room. Ask the borrower if there is an expedient way in which access can be granted. Call the client and advise of the situation. Wait for the client to direct whether to complete "subject to" that inspection or wait until access is available. If a re-inspection is required negotiate with the client additional fees which will be incurred because of this. Disclose within the report what steps were taken in attempting to gain access if none can be provided and a "subject to" appraisal is completed.

 

[RSW]

Show me where is says to stop in mid stream. I do contact the lender and reschedule a time when a complete visual inspection can be performed...but I finish the rest of the appraisal report and send it in with the report saying exactly that.

Revised appendix D, page D-3:

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.

Show me where it says to complete the appraisal report subject to. You can't.

 

[residentialguy]

Revised appendix D, page D-3:

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.

Show me where it says to complete the appraisal report subject to. You can't.

Just as you can't show me that you can't complete the appraisal report subject to. Show me where it says to stop and go no further. You can't. It says nowhere in the red that you have to stop your inspection/report. It says to contact them an reschedule a time when it can be performed. That's what a final does. Therefore, you can do it your way and I can do it my way (should be a song) Either way is fine and the end result is the same...except my subject closes on time.