Comment Submitted by Association of Texas Appraisers

Summary: The Association of Texas Appraisers (ATA) supports the FHA's efforts to modernize and streamline Minimum Property Requirements (MPRs) by advocating for a converged, two-layer system with the VA and GSEs. They argue for adopting shared UAD condition ratings and data standards while maintaining a stricter, separate eligibility decision for public programs to ensure safety and consistency across the mortgage market.