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FHA - Crawlspace Compliant?

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TruJa

Junior Member
Joined
Feb 5, 2019
Professional Status
Certified Residential Appraiser
State
Idaho
I was reading through the threads because I just inspected a property and am going back and forth over whether to require a crawlspace to be cleaned up, and saw some older comments that made me think some appraiser's may not understand some items, so I thought I would stick my neck out and opine a little and ask a question. As background I am a former remodeling contractor.

The obvious:
If a crawlspace has obvious moisture problems (mold, pooling water), obvious infestation issues, hacked up, broken, or missing structural members, obvious settling/cracking, then it needs to be repaired to meet minimum requirements.

The less obvious:
If there is cracking which may or may not be structural (i.e. more than hairline cracks from drying), call for an inspection.
If there are system components then 18" clearance is required. What is a system component? If you have venting, plumbing, or electrical then you have a system component. How do you know if you have venting or plumbing? Ideally you should see vents or pipes since you are certifying that you can visually inspect all areas of the crawlspace, but lets be realistic... I've yet to meet an appraiser who really looks at every area of a crawlspace. If there are registers coming up through the floor then there are vents below. If there are plumbing drains on the 1st floor (and likely upper floors too) that go down, then 99.9% chance you have plumbing components below. This might be a problem with older homes. If there are plumbing components, does the entire crawlspace need to meet the 18" requirement, or just a sufficient area to service the system components? According to the HOC rep I spoke with the entire thing needs to meet the requirement. (Granted they don't want to opine specifically, but just quote the handbook at you)

Fuzzy grey areas:
This is the question I'm struggling with most recently: What is debris? According to "approved" educational videos I've seen by the "experts", storing a few boards in the crawlspace is debris. I've called for cleanup once in my career when someone had it full of clothes and books and trash, and I couldn't even get into the crawlspace. But what about left over construction "debris"? What about loose insulation that has fallen down? What if there is cardboard & caulking tubes & abandoned pieces of ducting? Is it a question of safety, soundness or security? I don't think so. Is it debris? Yes.

Trying to figure out where the line is on "debris" for a crawlspace.
Thank you.
 
This has been my ‘beef’ for many years and why I quit performing FHA inspections. Most ppraisers do only the minimum head and shoulders inspection of the crawl yet certify they inspected all areas.

I also blame the FHA for this ridiculous protocol stipulation when they know it’s not being completed.
 
I was reading through the threads because I just inspected a property and am going back and forth over whether to require a crawlspace to be cleaned up, and saw some older comments that made me think some appraiser's may not understand some items, so I thought I would stick my neck out and opine a little and ask a question. As background I am a former remodeling contractor.

The obvious:
If a crawlspace has obvious moisture problems (mold, pooling water), obvious infestation issues, hacked up, broken, or missing structural members, obvious settling/cracking, then it needs to be repaired to meet minimum requirements.

The less obvious:
If there is cracking which may or may not be structural (i.e. more than hairline cracks from drying), call for an inspection.
If there are system components then 18" clearance is required. What is a system component? If you have venting, plumbing, or electrical then you have a system component. How do you know if you have venting or plumbing? Ideally you should see vents or pipes since you are certifying that you can visually inspect all areas of the crawlspace, but lets be realistic... I've yet to meet an appraiser who really looks at every area of a crawlspace. If there are registers coming up through the floor then there are vents below. If there are plumbing drains on the 1st floor (and likely upper floors too) that go down, then 99.9% chance you have plumbing components below. This might be a problem with older homes. If there are plumbing components, does the entire crawlspace need to meet the 18" requirement, or just a sufficient area to service the system components? According to the HOC rep I spoke with the entire thing needs to meet the requirement. (Granted they don't want to opine specifically, but just quote the handbook at you)

Fuzzy grey areas:
This is the question I'm struggling with most recently: What is debris? According to "approved" educational videos I've seen by the "experts", storing a few boards in the crawlspace is debris. I've called for cleanup once in my career when someone had it full of clothes and books and trash, and I couldn't even get into the crawlspace. But what about left over construction "debris"? What about loose insulation that has fallen down? What if there is cardboard & caulking tubes & abandoned pieces of ducting? Is it a question of safety, soundness or security? I don't think so. Is it debris? Yes.

Trying to figure out where the line is on "debris" for a crawlspace.
Thank you.
Your Confusing a Home Inspection by a Licensed Home Inspector or a Licensed Contractor with what a Real Property Appraiser does when they view the Observable Physical Condition of the Subject Property.

I know FHA seems to want us to cross that line. We could do all you say. The Cost of the Appraisal/Inspection would run over $1,000 and possibly more.

In North Carolina Appraisers have to be very careful because we have Licensed Home Inspectors. They are Governed by the Department of Insurance. Real Estate Appraisers are governed and regulated by the NC State Appraisal Board. We are specifically mentioned in the NC Home Inspectors Rules and Regulations. Its in the form of a you might say a Caution/Warning of possible sanction if we cross that line.

So I get your Point(s). They are good ones.
 
obvious infestation issues
here we are liable to find a cripple support that has wood touching the ground and termites will get to it...so, that is our biggest issue...
 
This has been my ‘beef’ for many years and why I quit performing FHA inspections. Most ppraisers do only the minimum head and shoulders inspection of the crawl yet certify they inspected all areas.

I also blame the FHA for this ridiculous protocol stipulation when they know it’s not being completed.

Why stop accepting FHA assignments because of how other appraisers performed their inspections?
 
Your Confusing a Home Inspection by a Licensed Home Inspector or a Licensed Contractor with what a Real Property Appraiser does when they view the Observable Physical Condition of the Subject Property.

I know FHA seems to want us to cross that line. We could do all you say. The Cost of the Appraisal/Inspection would run over $1,000 and possibly more.

In North Carolina Appraisers have to be very careful because we have Licensed Home Inspectors. They are Governed by the Department of Insurance. Real Estate Appraisers are governed and regulated by the NC State Appraisal Board. We are specifically mentioned in the NC Home Inspectors Rules and Regulations. Its in the form of a you might say a Caution/Warning of possible sanction if we cross that line.

So I get your Point(s). They are good ones.
I see what you are saying, but I'm really not confusing them. I have multiple warnings in multiple places that I am not a home inspector, that I recommend all interested parties obtain a home inspection, and that my "inspection" is very limited in scope and purpose. Honestly, I almost always only do head & shoulder inspections and disclose this in my reports, (but I really do stick my head in and look around). Maybe 2-3x per year I see something I had better look at closer, so I do.
 
Yes, Predominately display in multiple places that your report IS NOT a Home Inspection. That's all you can do.

Whats interesting in My AO Charlotte MSA....Buyers are Indeed paying for a Home Inspection. Lots of them are doing it even on relatively new houses. Thats a small amount of money for the Assurance it gives the buyer.
 
So does anyone want to give their opinion for what would constitute disqualifying "debris" in a crawlspace for minimum property requirements, and what wouldn't?
 
So does anyone want to give their opinion for what would constitute disqualifying "debris" in a crawlspace for minimum property requirements, and what wouldn't?
No, it would not be up to mau', the appraiser.
IF it's S-S-S then STOP & get the client involved - by informing them with photos, descriptions, etc. (and an Invoice)
And where you decide it's S-S-S bad-enough then you would call for "bids" of repair, STOP until you know more.
You described more than debris. But, your observations would be described as debris, right?
 
I recently had a Reverse Mortgage house where junk (clothes, boxes) was piled from the floor to the ceiling in every bedroom. I said, "At lender discretion, have borrower remove material in bedrooms so upon re-inspection, appraiser can observe the actual condition of floors and walls." That's how I handle "fuzzy."
 
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