FHA 'inspection Requirements' Vs State Law

[CANative]

I was mentored and still attempt to take comps photos at an angle. Often that is not possible so I guess we will need to add an additional boilerplate comment on the feasibility of taking such photos. Got to love it!

Maybe. But I would say that the photo itself would make it obvious why side angle photos couldn't be done.

 

[bnmappraisal]

FHA has, for years, required subject photos that captured each side - extending the requirement to comp photos isn't really as surprise.

No, but to add to that logic, USPAP has required for years that Subject sale/transfer history be analyzed for the past 3 yrs ... now FHA is requiring that for comps too!
Guess we shouldn't be really surprised about that either! (definitely not a knock at you at all Peter, just making a general statement)

 

[Mr Rex]

The requirement about the ongoing life of the mechanicals etc is interesting. Home Inspectors are not required to comment on the life expectancy of any component, although I often do make comments that a component that is working at the time of the inspection appears to be nearing the end of its useful life, and recommend budgeting for replacement.

 

[Peter LeQuire]

No, but to add to that logic, USPAP has required for years that Subject sale/transfer history be analyzed for the past 3 yrs ... now FHA is requiring that for comps too!
Guess we shouldn't be really surprised about that either! (definitely not a knock at you at all Peter, just making a general statement)

The tendency has been and will continue to be for the various requirements of agencies and regulators to bleed into each other. It's easy to notice when an underwriter imposes a HUD requirement on an appraisal intended for a conventional loan, for example. (In my lending past, some of the discussions between underwriting and marketing folks, on the one hand, and experienced production people, not wanting to be at a competitive disadvantage because of more stringent underwriting than their competitors, on the other, could get very heated. Commissioned/incentive-driven loan people knew the agency requirements better than underwriters, loan marketing people and, in some cases, senior management.) It takes years to train underwriters to a reasonable level of discernment across all loan types, agency requirements and lender peculiarities.

There's also the tendency of government to expand its reach and the depth of its involvement in whatever they touch, but that's a discussion for the Do Drop Inn after 5:00 this afternoon.

 

[Eli]

FHA has been a major market force relative to fees and report requirements since I can remember, which is when some of you were in diapers. FHA dropped the fee influence a little a little while back, where VA picked up where they left off on the fee side.

 

[valuequestor]

Wow, just finished reading this entire thread. I tend to agree with CANative, sounds like more work for me as well. I just finished an FHA Update Course offered by a very knowledgeable instructor. He's on the phone with the Santa Ana HOC most every day. He stressed in class that we should stop using "inspected" and move to observed or viewed when describing what we do when we are in the property. It will mean changing a few comments for some. The comp pics are just common sense in my opinion. I always felt like it was an attempt to hide something when taking a straight on front shot. Why do that? Change is inevitable, embrace it or move out of the way.

 

[normando]

Bureacrats make these rules. When we take photos there are times when there are people in front of subject. I quickly find an angle and take photo without human there. We don't have the luxury of taking our time in capturing the perfect photo: All my years, comp photos can be taking whatever angle and should have no problem. Stupid bean counters think they know better.

 

[TX ladybug]

This is what I have, on my report, I just revised it, have I covered all of my *** and is anything outdated?


"As per HUD Handbook 4150.2 Appendix D, page D-7: FHA appraisals are no guarantee that the property is free from defects. The appraisal only establishes the value of the property for mortgage insurance purposes. Buyers need to secure their own home inspections through the services of a qualified inspector and satisfy themselves about the condition of the property. The appraiser is not an expert in any other field, except estimating market value. The intended user of this appraisal report is the lender/client and HUD/FHA. The subject property meets FHA guidelines. The subject property meets the current requirements of HUD handbooks 4000.1. The intended use of the appraisal is solely to assist FHA in assessing the risk of the Property securing the FHA-insured Mortgage.

The appraisers are not experts in the identification of hazardous substances or detrimental environmental conditions. The appraiser's routine inspection of the subject property did not develop any information that indicated any apparent significant hazardous substances or detrimental environmental conditions. The subject was not inspected for mold as the appraisers are not experts in this area. The appraiser suggests a home inspection should client require certification outside the scope of the appraiser. The FHA Appraiser does not guarantee that the Property is free from defects. The appraisal establishes the value of the Property for mortgage insurance purposes only.

As per the Scope of Work, this appraisal is "As is". No hypothetical conditions or extraordinary assumptions were used to prepare this report. The appraiser is not an expert in home inspection or any other field outside of forming an opinion of value, therefore defers to the experts should client require certification outside the scope of the appraiser."