FHA Crawl Space Requirements

[Jen Quinn]

Hi all, I did an FHA inspection today and the crawl space is not 18" minimum required height. There is also insulation falling down all over the place. I have included some photos that I took from the entrance (which was outside, and about 2' wide by 1.5' tall). What I am wondering is this: How do I call this out? Do I make the report subject-to the crawl space being dug-out to minimum height and the insulation being re-tacked? The house was built in 1965, and there is a vapor barrier under there (though it is not whole) This is the first time I have encountered a non-compliant crawl space, and I don't want to cause problems if they're not necessary. At the same time, I don't want to overlook or ignore something that should be called-out.
Interestingly (to me at least), the home was purchased in 2018 with an FHA loan. I am not sure how it passed an FHA inspection, not only because of the crawlspace, but also due to the fact that there is one smoke detector and one CO detector downstairs, outside of one bedroom, but 20' from the second bedroom. In the finished attic, which has 2 bedrooms, there are no smoke detectors and no CO detectors. Also, the water heater is not double-strapped. All of these things are state requirements for sale.
Thanks for any help you can give!

 

[Tim The Enchanter]

I suspect that does not meet MPR.
Someone else will have better info.

 

[Terrel L. Shields]

Point it out. I don't know you have to do anything more than call the issues. You are not required to recommend a fix or require repairs I think, That would be up to the underwriter and mortgagee to fix. The DEU probably can waive such repairs. Ground cover is not required unless excessive moisture exists then they would need it.

• If the crawl space contains any system components, the minimum required vertical clearance is 18 inches between grade and the bottom of the floor joists.
• The crawl space must be properly vented unless the area is mechanically conditioned.
• The crawl space must be free of trash, debris, and vermin.
• The crawl space must not be excessively damp and must not have any water pooling. If moisture problems are evident, a vapor barrier and/or prevention of water infiltration must be required.
The Appraiser must report any evidence that may indicate issues with structural support, dampness, damage, or vermin that may affect the safety, soundness and security of the Property.

 

[Jen Quinn]

Point it out. I don't know you have to do anything more than call the issues. You are not required to recommend a fix or require repairs I think, That would be up to the underwriter and mortgagee to fix. The DEU probably can waive such repairs. Ground cover is not required unless excessive moisture exists then they would need it.

• If the crawl space contains any system components, the minimum required vertical clearance is 18 inches between grade and the bottom of the floor joists.
• The crawl space must be properly vented unless the area is mechanically conditioned.
• The crawl space must be free of trash, debris, and vermin.
• The crawl space must not be excessively damp and must not have any water pooling. If moisture problems are evident, a vapor barrier and/or prevention of water infiltration must be required.
The Appraiser must report any evidence that may indicate issues with structural support, dampness, damage, or vermin that may affect the safety, soundness and security of the Property.

Thanks for the response. So you don't think I need to make the report subject-to anything to do with the crawl space?

 

[Terrel L. Shields]

So you don't think I need to make the report subject-to anything to do with the crawl space?

Perhaps subject to inspection by a licensed contractor and remediation as recommended. Structurally, it isn't an issue. I don't know insulation is even required and a vapor barrier isn't required unless "excessive' dampness. I don't know how to define "excessive" unless it is ponding water beneath the floor.

 

[CANative]

The requirements regarding crawl space clearance changed a long time ago.

4150.2

(3-6) o There must be adequate access to the crawl space; the appraiser must be able to access the crawl space for inspection. Access is defined as ability to visually examine all areas the crawl space. Specifically, the minimum distance is 18 inches.

o The floor joists must be sufficiently above ground level to provide access for maintaining and repairing ductwork and plumbing.

o The crawl space must be clear of all debris and trash and must be properly vented.

o The crawl space must not be excessively damp and must not have any water ponding.

> If these requirements are not met, mark 'YES" in VC-8 and prepare the appraisal "as-repaired" subject to repair of the deficiency.

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4000.1

m. Crawl Space Observation Requirements

The Appraiser must visually observe areas of the crawl space and notify the Mortgagee of the deficiency of MPR and MPS when the crawl space does not satisfy any of the following criteria:

• The floor joists must be sufficiently above ground level to provide access for maintaining and repairing ductwork and plumbing.

• If the crawl space contains any system components, the minimum required vertical clearance is 18 inches between grade and the bottom of the floor joists.

• The crawl space must be properly vented unless the area is mechanically conditioned.

• The crawl space must be free of trash, debris, and vermin.

• The crawl space must not be excessively damp and must not have any water pooling. If moisture problems are evident, a vapor barrier and/or prevention of water infiltration must be required.

The Appraiser must report any evidence that may indicate issues with structural support, dampness, damage, or vermin that may affect the safety, soundness and security of the Property.

In cases where access through a scuttle is limited, and the Appraiser cannot fully enter the crawl space, the insertion of at least the head and shoulders of the Appraiser will suffice. If there is no access to the crawl space but there is evidence of a deficient condition (such as water-stained subflooring or smell of mold), the Appraiser must report this condition and the Mortgagee must have a qualified third party perform an inspection.

 

[Jen Quinn]

The requirements regarding crawl space clearance changed a long time ago.


4000.1

m. Crawl Space Observation Requirements

The Appraiser must visually observe areas of the crawl space and notify the Mortgagee of the deficiency of MPR and MPS when the crawl space does not satisfy any of the following criteria:

• The floor joists must be sufficiently above ground level to provide access for maintaining and repairing ductwork and plumbing.

• If the crawl space contains any system components, the minimum required vertical clearance is 18 inches between grade and the bottom of the floor joists.

• The crawl space must be properly vented unless the area is mechanically conditioned.

• The crawl space must be free of trash, debris, and vermin.

• The crawl space must not be excessively damp and must not have any water pooling. If moisture problems are evident, a vapor barrier and/or prevention of water infiltration must be required.

The Appraiser must report any evidence that may indicate issues with structural support, dampness, damage, or vermin that may affect the safety, soundness and security of the Property.

In cases where access through a scuttle is limited, and the Appraiser cannot fully enter the crawl space, the insertion of at least the head and shoulders of the Appraiser will suffice. If there is no access to the crawl space but there is evidence of a deficient condition (such as water-stained subflooring or smell of mold), the Appraiser must report this condition and the Mortgagee must have a qualified third party perform an inspection.

Thanks for the response. One of the issues is that I can't tell if there are system components under the house. Getting my actual head and shoulders in there would have required me laying on my stomach and wriggling my way in, which seems above and beyond to me, and I wouldn't have been able to see very far anyway because of the floor joist that ran a foot in from the access point.. Because of the low-hanging joists and falling insulation, I couldn't see the subfloor. I do appreciate the help. I spent a long time this afternoon trying to find any documentation that was close to this particular problem.

 

[CANative]

I don't see any ducts in your photos. What kind of heating system did it have? Wall furnace? I see what appears to be a copper water pipe but I don't see anything that looks like a plumbing system.

Did you look for an interior crawl space hatch - say in a bedroom or hall closet. I find these once in a while. Plumbing is accessible from there.

I am not sure how it passed an FHA inspection, not only because of the crawlspace, but also due to the fact that there is one smoke detector and one CO detector downstairs, outside of one bedroom, but 20' from the second bedroom. In the finished attic, which has 2 bedrooms, there are no smoke detectors and no CO detectors. Also, the water heater is not double-strapped. All of these things are state requirements for sale.

There is no MPR for smoke and CO alarms. Codes and laws pertain to 203(k) assignments and proposed or new constructions (less than 12 months.) MPS (min. prop. standards) apply versus MPR. 4000.1 has no requirement for water heater seismic strapping. It DOES have a requirement for the water heater to have a TPR valve discharge tube. So that must be inspected and, if not present, a repair condition made.

 

[Jen Quinn]

I don't see any ducts in your photos. What kind of heating system did it have? Wall furnace? I see what appears to be a copper water pipe but I don't see anything that looks like a plumbing system.

Did you look for an interior crawl space hatch - say in a bedroom or hall closet. I find these once in a while. Plumbing is accessible from there.



There is no MPR for smoke and CO alarms. Codes and laws pertain to 203(k) assignments and proposed or new constructions (less than 12 months.) MPS (min. prop. standards) apply versus MPR. 4000.1 has no requirement for water heater seismic strapping. It DOES have a requirement for the water heater to have a TPR valve discharge tube. So that must be inspected and, if not present, a repair condition made.

It's a FA system with a heat pump outside. There was no interior hatch. The vents are in the floor with an air return in the wall of the hallway.
I guess I should have been more specific. It should not have made it through any appraisal without these conditions being called out. In Oregon, seismic-strapping and Smoke detectors installed to code are required for all sales, and CO detectors are required for all sales or tenant-occupancy if there is a CO source, and now for all homes constructed after 2011. Those conditions should have been called out on the last appraisal sale 02/18).

 

[Addie]

I don't see any ducts in your photos. What kind of heating system did it have? Wall furnace? I see what appears to be a copper water pipe but I don't see anything that looks like a plumbing system.

Did you look for an interior crawl space hatch - say in a bedroom or hall closet. I find these once in a while. Plumbing is accessible from there.



There is no MPR for smoke and CO alarms. Codes and laws pertain to 203(k) assignments and proposed or new constructions (less than 12 months.) MPS (min. prop. standards) apply versus MPR. 4000.1 has no requirement for water heater seismic strapping. It DOES have a requirement for the water heater to have a TPR valve discharge tube. So that must be inspected and, if not present, a repair condition made.

Embarrassed for you. You need to take some classes on FHA requirements. I would love to review an FHA appraisal of yours. with a pool, no CO sector, water heater straps. Does it have 1 of the 7 safety features allowed in CA for a pool? Is that crawl space access door locked? Is there a doggy door on the firewall door? Ohh, you didn't subject to those things that aren't up to state, local law?

Same goes for FNMA selling guide. I can call you out from the selling guide on those too if you would like.

Out of the handbook you forgot to read;

"(c) Pools, Hot Tubs and Spas
(i) In-GroundPools,HotTubsandSpas
Mortgagees must secure all in-ground swimming pools, hot tubs, and spas as required by local laws, codes and ordinances. The Mortgagee must:

• secure the pool, hot tub, and/or spa with a removable safety cover anchored to the pool deck or, if a cover cannot be anchored to the pool deck, board or otherwise secure the pool, hot tub, and/or spa; and
• secure and repair any fences around the pool, hot tub, and/or spa to restrict access."

"
i. Compliance with Law
The Appraiser’s performance must comply with all applicable federal, state, and local laws. The Appraiser must adhere to all state and local laws relating to appraisal, licensing and certification requirements."

"
"ii. Repairs Necessary to Comply with Mortgage Lender or State, Tribal, or Local Law Requirements"

"(ii) Exterior Doors
The Mortgagee must secure all exterior doors. For exterior sliding glass doors, the Mortgagee must latch these doors and install or provide slider locks, anti-lift blocks, security bars, or another secondary security mechanism.
The Mortgagee must not brace, nail shut, or otherwise block or damage the door. If no other locking mechanism exists, the Mortgagee must board/secure access doors, pet doors, and other panels providing access to basements and crawl spaces, where permitted by state or local law."