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

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.

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.

A coalition of housing finance trade organizations is urging the FHA to align its Minimum Property Requirements (MPRs) with the standards established by Fannie Mae and Freddie Mac. They argue that the current FHA requirements are overly burdensome, create unnecessary costs for lenders and borrowers, and should be replaced with a standardized condition rating system to improve efficiency and marketability.

United Wholesale Mortgage, a mortgage company, supports the modernization of FHA’s Minimum Property Requirements (MPRs) to reduce unnecessary repair conditions for non-material issues. They argue for a tiered repair taxonomy that distinguishes between mandatory pre-closing repairs, deferred-repair-eligible items, and observation-only conditions to improve efficiency and borrower access.

International Bancshares Corporation, a multi-bank financial holding company, supports the modernization of FHA's Single-Family Minimum Property Requirements (MPRs). They argue that aligning FHA standards with the Fannie Mae and Freddie Mac C1-C6 rating methodology would reduce complexity, provide greater clarity for lenders, and improve transaction certainty for borrowers.

The commenter, representing a business interest in the mortgage industry, provides specific recommendations to improve FHA's Single Family Minimum Property Requirements (MPRs). They argue for greater standardization, the removal of requirements for minor cosmetic repairs, and better alignment with GSE (Fannie Mae and Freddie Mac) standards to increase efficiency and reduce transaction costs.

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.

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.

A certified residential appraiser supports the FHA's effort to modernize Minimum Property Requirements (MPRs) but argues for a clearer, risk-based framework. The commenter advocates for distinguishing between minor technical issues and genuine safety/habitability concerns to reduce the compliance burden on appraisers and lower costs for borrowers.

G7 Service Group, a property preservation and compliance firm, supports HUD's efforts to modernize Minimum Property Requirements (MPR) and property preservation standards. They argue for clearer distinctions between cosmetic and functional defects, updated reimbursement structures to reflect current labor and material costs, and more flexible, technology-driven guidelines to improve housing inventory and operational efficiency.