Comment Submitted by Donad Martin

My name is Donald J. Martin, SCRP, RAA, GAA, CDEI, AQB Certified USPAP Instructor, Chief Appraiser for the Illinois Department of Transportation and a Board of Trustee Member of The Appraisal Foundation. I have been a practicing appraiser for near 49 years as a Certified General Real Estate Appraiser. I ran my own appraisal firm for near 4 decades. I am not speaking for either IDOT or TAF, but my views given from my many, many years of appraising and observations. I also am a managing Real Estate Broker in IL and have been a Certified General Real Estate Appraiser in six states IL, IN, IA, MI, MN and WI (currently IL, IN and WI). I have trained many appraisers, performed many FHA and VA Appraisals, and licensed, taught and written classes cumulatively for 7 different schools. I also have a background as a loan officer, an underwriter, Marine, father, and AML survivor. FHA has long been the champion of making sure home ownership is safe, secure and sound. Lessening regulations that would ensure current FHA Minimum Property Standards continue to be adhered too, will increase home hazards and resulting injuries, cancers and in some cases death. Many FHA purchasers cannot afford to make much needed repairs. As such, if the repairs are not required prior to close, may repairs will not be completed due to affordability issues. It is imperative to continue to require that home ownership be safe, secure and sound. FHA should be a model to ensure collectively Americans are safe in their homes or rentals that they occupy. Additionally, when mortgages are defaulted on, the repairs will often deter both market value and marketability. Appraisers are licensed and certified through requirements by The Appraisal Foundation and enforced at the respective state regulatory level, as required through FIRREA (Financial Institutions Reform Recovery and Enforcement Act of 1989 AKA the Savings & Loan Bailout Bill), they act to "Preserve the Public Trust." Reducing in any way the required repairs will deter the Public Trust and destabilize the housing market which has led in part to the collapse of many financial institutions. Relaxing requirements has a destabilizing impact and at a time where there is housing shortage, reduction in Single Family Housing Minimum Property Requirements will have a net impact of reducing safe, sound and secure available housing, allowing homes to go into greater disrepair. I urge you not to impede required FHA minimum property standards, the health and welfare of our nations housing stock and more importantly of Americans depends on this.