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Need help to rebut Reviewer's comment that dwelling does not meet ANSI Z765-2021

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If the main level is below grade - meaning any part or corner of the main level is below the surrounding dirt level (eg. it is built into a hill in back) it is an Ansi exception- GXX 001... State it and explain it in the comments and count it as GLA.
Street level has nothing to do with it, however.
in the ansi beginning i did a big house where the garage was at street level. the rest of the 2 story house was below st level just like yours. the side of the house was touching the side of the gully it was in with the other 3 sides being mostly above ground. nobody in their right mind would say this house was all basement. and i never saw this before. no similar sales. so some of you ansi nuts would call it all basement. i used the ansi exemption and there was no problem. of course it all depends on the analism of the underwriter who sent it to the reviewers.
unfortunately, somewhere there are explanations of the ansi exemptions, but the market can determine that this house as all GLA, and not basement sq footage.
doing it the ansi nuts way will make that appraisal grid so convoluted that you will leave yourself open to mistakes and misunderstandings from buyer and seller and agents. and go figure the ansi GLA of the comps. if nobody else did that on their reports, then you have to explain why your GLA is different from everyone else. with appraisers & reviewers sometimes their stupidity can't be cured, but i would try my best to re educate them. ps, i actually reallly really love you ansi nuts.
 
Stop trying to fit every square peg into a round hole. Not every improvement is going to technically comply with ANSI standards. What you're call below grade (I can't get the pictures to open) is highly common in my market especially for lakefront properties. You've already stated you have similar comps supporting this type of construction / design is market acceptable. If they contend the home is not ANSI compliant and is all basement, that's their call to not make the loan.
 
i think they can be considered as Q5, but no appraisers classify these properties as Q5 because they are all $1.5M+ properties. Classify them as Q5 would only raise red flags for the Lenders.
You can have a Q5 if most of the value is in the land. Shouldn't be my problem if doing the appraisal correctly raises red flags. I don't want to do a poor job to try to ward off red flags. You will twist yourself in a pretzel if you start doing appraisals to look neat and tidy over accuracy.
 
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in the ansi beginning i did a big house where the garage was at street level. the rest of the 2 story house was below st level just like yours. the side of the house was touching the side of the gully it was in with the other 3 sides being mostly above ground. nobody in their right mind would say this house was all basement. and i never saw this before. no similar sales. so some of you ansi nuts would call it all basement. i used the ansi exemption and there was no problem. of course it all depends on the analism of the underwriter who sent it to the reviewers.
unfortunately, somewhere there are explanations of the ansi exemptions, but the market can determine that this house as all GLA, and not basement sq footage.
doing it the ansi nuts way will make that appraisal grid so convoluted that you will leave yourself open to mistakes and misunderstandings from buyer and seller and agents. and go figure the ansi GLA of the comps. if nobody else did that on their reports, then you have to explain why your GLA is different from everyone else. with appraisers & reviewers sometimes their stupidity can't be cured, but i would try my best to re educate them. ps, i actually reallly really love you ansi nuts.
Yea I did one that was a split foyer, you walked up a lot of steps to get to the front entrance. IT was partially below grade on one side of the lower floor, this side had the garage and laundry/utility area behind it. It lived like a 2 story with no basement, main living areas on the first floor, and 2nd floor was bedrooms/baths.
 
in the ansi beginning i did a big house where the garage was at street level. the rest of the 2 story house was below st level just like yours. the side of the house was touching the side of the gully it was in with the other 3 sides being mostly above ground. nobody in their right mind would say this house was all basement. and i never saw this before. no similar sales. so some of you ansi nuts would call it all basement. i used the ansi exemption and there was no problem. of course it all depends on the analism of the underwriter who sent it to the reviewers.
unfortunately, somewhere there are explanations of the ansi exemptions, but the market can determine that this house as all GLA, and not basement sq footage.
doing it the ansi nuts way will make that appraisal grid so convoluted that you will leave yourself open to mistakes and misunderstandings from buyer and seller and agents. and go figure the ansi GLA of the comps. if nobody else did that on their reports, then you have to explain why your GLA is different from everyone else. with appraisers & reviewers sometimes their stupidity can't be cured, but i would try my best to re educate them. ps, i actually reallly really love you ansi nuts.
If you invoke the exception. That does not make the area a "basement". It just means it cannot be measured by ANSI standards. It is still living area and it would be shown on the grid as living area. Not as a basement.
 
When can ANSI Z765-2021 not be applicable for SFR?

See attached photos. Subject is a detached SFR with a detached carport improved at street level, but the entire dwelling is improved approx. 4 feet below street level, with 3 sides of the dwelling having open access, and one side of the dwelling butting against the carport foundation; these types of dwellings are common in the neighborhood with ample similar comps. The Reviewer says the sketch does not conform to ANSI Z765-2021 because the house is below grade and should be classified as a basement. I have provided comps that are entirely above grade, partially below grade as subject, and comps that are entirely below grade and not visible from the street. The comps show little value difference between dwellings at street level vs dwellings partially below street level and dwelling completely below street level. Should the subject property, and comps that are partially or fully below grade, all be classified as walk-out basements?

Previously had appraised another similar property (Subject-2 photos) in the neighborhood for a different Lender. The front photo clearly shows that level-1 is partially below grade, but the rear photo shows level-1 is completely above grade. The reviewer on this property made no qualms that level-1 was included in the GLA measurement. Although ANSI is a now a requirement, it appears it can be a subjective judgment call by the appraiser or the reviewer.

i have attached the first few pages of the ANSI fact sheet. Where can i get more detailed ANSi requirements to rebut the reviewer and support my case?
The photos aren't loading. Is this a 2 story house with the bedrooms on the upper level above the kitchen/dining/living room? Or is this a ranch with a lower level family room underneath the main dining and kitchen area?
 
in the ansi beginning i did a big house where the garage was at street level. the rest of the 2 story house was below st level just like yours. the side of the house was touching the side of the gully it was in with the other 3 sides being mostly above ground. nobody in their right mind would say this house was all basement. and i never saw this before. no similar sales. so some of you ansi nuts would call it all basement. i used the ansi exemption and there was no problem. of course it all depends on the analism of the underwriter who sent it to the reviewers.
unfortunately, somewhere there are explanations of the ansi exemptions, but the market can determine that this house as all GLA, and not basement sq footage.
doing it the ansi nuts way will make that appraisal grid so convoluted that you will leave yourself open to mistakes and misunderstandings from buyer and seller and agents. and go figure the ansi GLA of the comps. if nobody else did that on their reports, then you have to explain why your GLA is different from everyone else. with appraisers & reviewers sometimes their stupidity can't be cured, but i would try my best to re educate them. ps, i actually reallly really love you ansi nuts.
There are examples of exceptions, but those examples are examples, not limitations. If the grade screws up the typical function, then you don't follow strict Ansi, rather you measure it how the house functions. Like you said, you're house does not function as a basement.
 
Q Rating has nothing to do with ANSI but quality of construction. With that being said lots of in Hill Multi Million Dollar Estate Beach Homes and ones in Hills are built like that in California . So big deal its not ANZI borrower needs to go to a Bank that does portfolio loans and doesnt care about ANZI. I would just throw it in the reviewers lap and tell him take it or leave it and be done. Its a Underwriting decision not an appraisal problem.
 
Worst case scenario. The reviewer won't budge. So you just use gx0001 and move on. From what you have posted. You have similar homes and home that are ANSI compliant for comps. You also stated market demonstrates no difference. Everything on your grid would remain the same. Just change commentary. If you use gx0001. ANSI is out the door and does not apply. Your living area goes on the GLA line in the grid.
 
An even worse case scenario. Four years from now, one of the GSE's gets conflicting information during a subsequent sale/refinance, and decides to turn you into the state.
 
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