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 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.

A veteran Certified General Appraiser argues that appraisers lack the specific training and insurance coverage to certify the condition of home components. The commenter suggests that if condition certification is the goal, a professional inspector should be engaged instead of relying on the appraisal.

Richard Negro, a Certified Residential Appraiser, supports the modernization of FHA's Minimum Property Requirements (MPRs) by advocating for clearer definitions of "Safety" and a distinct separation of responsibilities between appraisers and underwriters. He argues that FHA should provide more objective guidance and training to reduce inconsistent underwriting decisions and improve transparency for borrowers.

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 suggests that FHA should modernize and streamline its Minimum Property Requirements (MPRs) by aligning them with other governmental and non-governmental financing programs. They argue that standardizing these requirements would reduce transaction delays, lower costs for borrowers, and provide greater clarity for lenders and appraisers while still maintaining safety and soundness.