Comment Submitted by American Valuation Society

Summary: The American Valuation Society (AVS) supports the modernization of FHA's Minimum Property Requirements (MPRs) by recommending the adoption of a shared FHA–VA existing-home property acceptability standard. They argue for aligning FHA's processes with the VA's model—specifically regarding visual appraisal scope, named review filters, and proportional repair verification—while adopting the GSE's condition and quality rating systems to ensure consistency across all lending channels.