FHA Attic Access

[Scott R Marshall]

Therefore, you can do it your way and I can do it my way (should be a song)

"There ain't no good guys, there ain't no bad guys. There's just you and me and we both disagree. Woohoohoohoo Oohohh Ohhhooooh."

 

[RSW]

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.

I've had the HOC inform me that the attic has to be inspected before the appraisal is finished. That, along with the revised appendix d is good enough for me.

Scott:

As to ******$$$$$ off my clients? I really don't care as long as I am doing the appraisal report according to FHA appraisal protocol. I have ******$$$ed off more clients in the 26+ years I have been appraising than most appraisers have as clients.

 

[Peter LeQuire]

There's no question that the current environment is permissive, and, beyond that, all of the decision making is pushed downhill to the appraiser. RSW is correct - the FHA protocol is to not complete the appraisal until access to the attic (and/or the crawl space) is provided and the appraiser can complete the inspection. "Inspection" means more that shoving one's head and shoulders through whatever scuttle is available and taking a picture: the appraiser is to look at the components and for the conditions specified in Appendix D - at that point, if the appraiser notes a condition that should be reported, s/he reports it and may call for either inspection by a qualified expert in the appropriate field (ex. electricical systems or roofs or mold or rotted wood) and then call for inspection (or repair if appropriate). Some parts of the 4150.2 and Appendix D may be ambiguous: the requirement to not complete the appraisal if access to attic and crawl is not ambiguous.

The fact that lenders push appraisers to not disrupt the process of moving a loan to closing is immaterial. The fact that a lender's DE underwriter isn't knowledgable of FHA requirements or is caught up in the production imperative is immaterial. FHA requires what it requires, and the fact that an appraiser hasn't been brought up short for not complying with those requirements doesn't matter a hill of expired listings: at some point s/he will, and I believe it is much more prudent to be on the manual side of a dispute about property conditions or following FHA requirements than not.

 

[Scott R Marshall]

RSW,


I never said I do this to not upset my clients. And I agree with you that as much as possible the appraiser should exhaust every necessary step in an attempt to comply with this requirement, even if it means a delay in delivery of the report. My issue arises when it appears that it can not or will not be done.

I will make a deal with everyone here. The next time I come across a property where inspection of either the attic or crawlspace is just not possible I will make the phone call to the mothership. I will explain to them the exact scenario and see what they say. It may be awhile as this is a very infrequent occurence. If at that time they say the report cannot be completed under any condition and that inspection must take place, I will let you know (and eat crow as well). If they say to proceed I wil let you know as well.

I am not meaning to sound argumentative or that I am a know-it-all. I, like many here, are seeking clarification from whatever powers that be once unique circumstances present themself.

 

[RSW]

RSW,


I never said I do this to not upset my clients. And I agree with you that as much as possible the appraiser should exhaust every necessary step in an attempt to comply with this requirement, even if it means a delay in delivery of the report. My issue arises when it appears that it can not or will not be done. I will make a deal with everyone here. The next time I come across a property where inspection of either the attic or crawlspace is just not possible I will make the phone call to the mothership. I will explain to them the exact scenario and see what they say. It may be awhile as this is a very infrequent occurence. If at that time they say the report cannot be completed under any condition and that inspection must take place, I will let you know (and eat crow as well). If they say to proceed I wil let you know as well.

I am not meaning to sound argumentative or that I am a know-it-all. I, like many here, are seeking clarification from whatever powers that be once unique circumstances present themself.

The subject property would then NOT be eligible for the FHA progam in that case. Again, that is not an appraisal issue but rather an underwriting issue.

 

[residentialguy]

There's no question that the current environment is permissive, and, beyond that, all of the decision making is pushed downhill to the appraiser. RSW is correct - the FHA protocol is to not complete the appraisal until access to the attic (and/or the crawl space) is provided and the appraiser can complete the inspection.

Please give me the link to that. You're twisting this 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.

to read like this: If unable to visually evaluate the improvements in their entirety, STOP RIGHT THERE and contact the lender and reschedule a time when a complete visual inspection can be performed.

It doesn't read like that. You could do it like that, just as I could read it like: If unable to visually evaluate the improvements in their entirety, FINISH THE REPORT and contact the lender and reschedule a time when a complete visual inspection can be performed.

Let me ask you something. Once I arrive and measure the home, it is a full fee charge at that point. What difference would it make to FHA if I finish the report and go back to re-inspect it...or to finish the report later, after re-inspection? ...other than possibly FHA losing the deal by going past closing, which I'm sure that's what they are hoping for.

I've had the HOC inform me that the attic has to be inspected before the appraisal is finished. That, along with the revised appendix d is good enough for me.

I've had them inform me that the market value is not the REO market, no matter how predominant the REO market is.

 

[RSW]

Please give me the link to that. You're twisting this 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.

to read like this: If unable to visually evaluate the improvements in their entirety, STOP RIGHT THERE and contact the lender and reschedule a time when a complete visual inspection can be performed.

It doesn't read like that. You could do it like that, just as I could read it like: If unable to visually evaluate the improvements in their entirety, FINISH THE REPORT and contact the lender and reschedule a time when a complete visual inspection can be performed.

Let me ask you something. Once I arrive and measure the home, it is a full fee charge at that point. What difference would it make to FHA if I finish the report and go back to re-inspect it...or to finish the report later, after re-inspection? ...other than possibly FHA losing the deal by going past closing, which I'm sure that's what they are hoping for.





I've had them inform me that the market value is not the REO market, no matter how predominant the REO market is.

And what does that have to do with the topic we are discussing?

 

[residentialguy]

Last I remember, we were talking about you reading it as "stop" and I am saying that "stop" is 1 option.

So what chu talking about, Willis?

 

[Couch Potato]

Last I remember, we were talking about you reading it as "stop" and I am saying that "stop" is 1 option.

So what chu talking about, Willis?

So you you think it is fine to do an FHA appraisal subject to you inspecting the improvements?

 

[Delta85]

For what it's worth and maybe I am doing this wrong but when I have not been able to access the attic I've always completed the inspection and report and made it subject to my getting access to inspect the attic.

To me it makes more common sense to make it subject to rather than completely stop all activity. If the report is subject to then it is invalid without an inspection of the attic so that's basically stopping right there. But halting the process entirely means having to do go back, pick up where you left off, finish the entire inspection, get your comps and photos, etc. Why create that much delay in the process?

If FHA really wants me to halt I suppose I will change the way I handle these situations. Sometimes by the time I realize I can't access the attic I've already measured and completed most of the inspection anyways so I am charging full fee at that point. It just makes more common sense to make it subject to.