Comment Submitted by Kathleen Kniffen

Thank you for requesting information re: FHA MPR's. I have been an FHA appraiser for 20+ years. I have read most of the submitted comments and many have made good points. Specifically, Appraiser training is not consistent and Appraisers are performing different levels of inspection depending on when they got on the FHA roster and who trained them. My FHA application had 10 questions and focused on peeling paint, utilities being turned off and appliances being present. The detailed level of inspection from the VC sheets was gone and I find reports requiring repairs I would never call for. Also, I agree with those that feel most of the electrical, plumbing, foundation and roof requirements are beyond the scope and expertise of the Appraiser. Relying on the Appraiser may give inaccurate results because we don't have the tools & training to fully test these systems. For example, a head & shoulders view of the scuttle/attic only sees the few feet in front of us and cannot see all corners of the roof line so what is really being provided? An area of concern may be missed. Additionally, climbing on a ladder is unsafe and an Appraiser died recently doing this. Many Appraisers are no longer taking FHA work due to the inspection requirements. The FHA MPR's may be a benefit for Buyer's/Owners but if FHA continues to want that micro-level of detail about the condition of the home, FHA should require a Home Inspection. Then Lenders/ Underwriters can require repairs based on FHA protocol. To modernize, FHA should modify requirements for Appraisers to be in-line with FNMA / VA and require obvious issues easily seen in the normal course of business. Appraisers are experts at valuing properties. Thank you.