FR-6609-N-01 Request for Information Regarding Single Family Minimum Property Requirements (MPR)

D.R. Horton, Inc., a large homebuilder, supports the Request for Information regarding Minimum Property Requirements (MPRs) to improve home affordability. They argue that HUD should reduce regulatory burdens by either restoring the distinction between MPRs and Minimum Property Standards (MPSs) for new construction, aligning MPRs with GSE standards, or accepting local code compliance as sufficient.

The National Reverse Mortgage Lenders Association (NRMLA) supports the Request for Information but advocates for specific revisions to streamline Minimum Property Requirements (MPRs). They propose transitioning to performance-based standards for shared wells and water purification systems, clarifying swimming pool guidelines, and adopting more flexible, cost-effective verification methods for repairs and collateral risk assessments to better serve senior homeowners.

Leading Builders of America, a trade association representing large homebuilders, supports the review of FHA's Minimum Property Requirements (MPRs) to reduce regulatory burdens and costs. They argue that requiring new construction to meet both Minimum Property Standards (MPSs) and MPRs is duplicative and suggest aligning MPRs with GSE requirements or local building codes to improve affordability.

The Collateral Risk Network (CRN) supports the FHA's effort to modernize and streamline Single Family Minimum Property Requirements (MPRs) to reduce regulatory burdens and improve access to housing. They argue that current MPRs are often outdated, overly rigid, and place unnecessary technical inspection burdens on appraisers, and they recommend focusing on material defects while clarifying communication and appraiser roles.

The Consumer Federation of America supports the FHA's Minimum Property Requirements (MPRs) as essential consumer protections but argues that widespread misunderstandings about them create barriers for first-time homebuyers. They recommend that HUD improve public education, publish a plain-language MPR checklist, provide data on closing timelines, and allow for post-closing repairs on minor deficiencies.

The commenter, a former government regulator now working for a lender, argues that FHA should maintain its distinct Minimum Property Requirements (MPRs) rather than adopting the Fannie Mae and Freddie Mac Property Condition Rating (PCR) framework. They advocate for simplifying and clarifying the existing MPRs—such as defining "habitable" and reducing intrusive inspection requirements—to protect entry-level borrowers while improving operational efficiency for lenders and appraisers.

The National Association of Mortgage Brokers (NAMB) supports modernizing the FHA's Minimum Property Requirements (MPRs) to make FHA loans more competitive with conventional financing. They recommend adopting the GSE property condition rating system, allowing for post-closing repairs on non-critical items, and consolidating fragmented guidance into a single policy document.

The commenter suggests that FHA should expand post-closing repair flexibility by providing specific guidance on escrow limits and timeframes. They also recommend creating a dedicated, easily identifiable section for Minimum Property Requirements (MPRs) in the Handbook to improve clarity for stakeholders.

The International Code Council (ICC) supports HUD's efforts to modernize single-family minimum property requirements (MPRs) and strongly encourages the agency to adopt the International Property Maintenance Code (IPMC) as its baseline standard. They argue that leveraging this existing, privately developed consensus standard would improve safety, standardize compliance across jurisdictions, and fulfill federal mandates to use voluntary consensus standards.