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

The commenter, likely a mortgage broker or real estate professional, argues that the current FHA Minimum Property Requirements (MPR) put borrowers at a competitive disadvantage compared to conventional financing. They advocate for removing attic and crawl space inspections due to low benefit and safety risks, and suggest modifying requirements for low-value detached buildings to reduce unnecessary repair costs.

An experienced FHA appraiser argues that the current minimum property requirements (MPRs) exceed the scope of an appraiser's expertise and training, potentially leading to inaccurate results. The commenter suggests that FHA should modernize its requirements to align with FNMA/VA standards or require a separate home inspection for detailed condition reports.

The Real Estate Valuation Advocacy Association (REVAA), a trade association for Appraisal Management Companies, supports the FHA's effort to modernize and streamline Minimum Property Requirements (MPR). They argue that the current framework is outdated, creates unnecessary friction for borrowers, and often requires appraisers to perform tasks outside their professional expertise.

An individual appraiser argues that attic inspections should be removed from minimum property requirements because they pose safety hazards and rarely yield significant findings. They also suggest removing HVAC testing requirements, citing potential system damage and increased liability for the appraiser.