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FHA Lead Based Requirements For 'historic' Properties

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Parham93

Freshman Member
Joined
Nov 19, 2008
Professional Status
Certified Residential Appraiser
State
Maryland
I had a quick question for you all regarding FHA requirements and ‘Historic’ properties (subject is 145 years old). I have a revision request that I am 99.9% sure I have already addressed with this lender but they are requesting additional information in the form of the FHA guideline that governs the issue.


The Issue: FHA Appraisal on a 145 year old End Unit Townhouse in a local historic district. The subject is on the Local Historic Society's list for architecture but does not have any restrictions that effect the appraisal. The problem is like many old townhomes in those types of areas the subject has chipping/peeling paint on the exterior brick (typical 100+ year old painted brick patina).


As required of FHA appraisals I have indicated the peeling/chipping paint on the exterior in the condition section and made the report Subject-to lead based paint inspection/certification/remediation.


The Request:

1st Request – “can you please list all repairs that need to be completed, also this being an historical building would the paint on the exterior need to be fixed please advise”

1st Reply : Repairs listed in the condition section, per FHA Guidelines all properties built prior to 1978 require lead paint inspection/certification/remediation.


2nd Request – “can you specify what the FHA guidelines are for a historical building the lender is reaching out”

2nd Reply : Copy and pasted the actual text from the HUD/FHA website regarding Lead Based Paint requirements... on or before 1978… included Links to the HUD/FHA site that detailed the guidelines and the 4000.1 SFH Handbook.


3rd Request – “That doesn’t address the FHA guidelines for the historic buildings. From what we have read that just addresses the FHA guidelines for building we need something that addresses historic buildings.”


Before I address this in my 3rd Reply regarding the Lead Based Paint Requirements of FHA I did an internet search to make sure they don’t have special exemptions for ‘Historic’ properties and have been unable to find anything. Now like I said at the beginning I am 99.9% sure they don’t have special exemptions for ‘Historic’ properties but before I get too aggravated and tell them to call HUD/FHA to verify it for themselves I wanted to get your opinions.

Thanks.

Paul
 

AMF13

Elite Member
Joined
Jan 24, 2002
Professional Status
Certified Residential Appraiser
State
California
I believe the requirement covers ALL homes 1978 or prior.
 

JTip

Elite Member
Joined
Oct 12, 2004
Professional Status
Certified Residential Appraiser
State
Pennsylvania
FHA Appraisal on a 145 year old End Unit Townhouse in a local historic district.

Pass...sorry, booked for 6 weeks.

This is not an FHA candidate; they need a conventional product.
 

Alpine

Junior Member
Joined
Mar 21, 2010
Professional Status
Licensed Appraiser
State
Oregon
Let me guess: They want each request and reply included in revised versions of the report, as if an appraisal must necessarily digress into an extended email exchange over redundant issues that were addressed in the original report?

Based on them being as thick as a brick with peeling paint in response to your repeated clarifications, I would call your regional HUD homeownership center personally. Granted, they don't always give you specific directive, but it will empower you to put it to rest, whatever the determination.
 

glenn walker

Elite Member
Joined
Oct 11, 2006
Professional Status
Certified Residential Appraiser
State
California
Has nothing to do with Historical - Anything Pre-1978 that has chipping-peeling paint or unsealed wood has to be mitigated and FHA/HUD has always stated health & safety issues are never grandfathered or waived for any reason.
 

Digger88

Elite Member
Joined
May 11, 2010
Professional Status
Certified Residential Appraiser
State
Virginia
exactly. historic is not a definition in the dictionary one can point to and say anything past 99.9 years is free from all FHA req's. what DA AMC is this?
 

andrew81

Senior Member
Gold Supporting Member
Joined
Dec 5, 2008
Professional Status
Certified Residential Appraiser
State
Illinois
i am not aware of any requirements "addresses historic buildings" but they do have an out

FHA 24 CFR § 200.810(c) said:
Federal Housing Administration (24 CFR 200 to 299)
SUBCHAPTER A: GENERAL
PART 200: INTRODUCTION TO FHA PROGRAMS (12/16/16)
Part 200, Subpart O: Lead-Based Paint Poisoning Prevention (05/01/01)
§200.810: Single Family Insurance and Coinsurance (04/01/05)

Treatment of a defective paint surface is not required if such a surface is found to not be a lead-based paint surface by a lead-based paint inspector certified pursuant to procedures of the U.S. Environmental Protection Agency at 40 CFR part 745.
 

Parham93

Freshman Member
Joined
Nov 19, 2008
Professional Status
Certified Residential Appraiser
State
Maryland
LMAO ok .. so update on this issue:

Per the local FHA Instructor and the President of the local Association of Appraisers, we are all correct in that anything "built on or before 1978" requires an inspection/certification and/or remediation of lead based paint.

4th Request (received this morning) - "Due to the building being an historic building there is no reason the exterior would or should ever get mentioned in the report or have to be repainted.
Can you please add some kind of comment to the report stating such this is going to be closing on Wednesday. "

So there it is... Can you change the report to ignore a HUD/FHA guideline so we can get the loan to closing.

Umm .... NO.

That could/would cost me my FHA Roster status (if the report was reviewed), most of my current business (due to being removed from the FHA Roster and/or having disciplinary action from HUD/FHA), open to a lawsuit for USPAP violations, disciplinary actions by the State Appraisal Board and loss of my Appraisal License.

Looks like I wont have to worry about much future work from this client LOL...


Paul
 

AMF13

Elite Member
Joined
Jan 24, 2002
Professional Status
Certified Residential Appraiser
State
California
If that's how they roll, you won't be losing much. :shrug:
 
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