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FHA – Crawl space and attics
Random Internet postings….
Man killed in crawlspace of Oklahoma City home, may have been electrocuted
Posted on facebook, reportedly from FHA employees:
– If you can fit through the crawlspace door you must crawl the crawl space and inspect it all.
– Must inspect all the attic if there is access, even if there is no flooring.
My comment: If you’re fat, don’t have to inspect all of the crawlspace? Lots of stories about snakes, rats, dead animals, etc etc in crawl spaces. Appraisers crawling along ceiling joists and going thru the ceiling. Hmm… maybe FHA appraising is for the young, agile and small ;>
The largest amount of appraisers are over age 55 and as we age our balance on a ladder is not as good, our ability to crawl into the crawl space is more difficult as well. Would guess, FHA will have a hard time finding appraisers willing to put themselves in the position of a house inspector for $500 or even more. There are limits to the body and even bigger limits to the liability that we should be willing to accept. The regs are placing too much responsibility and liability on us and we are not qualified. Pay for a house inspector. And, yes I agree we pay dues to appraisal organizations that only offer newsletters and boring education at high fees….nothing more.
Where are the appraisal organizations and why are they not standing up for us? They seem to tout their involvement, but I have not seen any of their results when it comes to this type of regulations/requirements on appraisers. What would happen if FHA/HUD stated that the real estate agent had to have some kind of responsibility in regards to the property that they were listing (like actually measuring a house to determine the GLA)? I bet the NAR would be on top of it and it would die a very quick death. Look at how the NAR has protected their members and what kind of responsibility or non-responsibility the agents actually have in their real estate transactions. I am a member of our local Real Estate Board and I hear all the time how the NAR was able to defeat a bill or new restrictive regulation/legislation. Where is our oversight and protection? (Yes, I used to be part of a national appraisal organization for almost twenty years, but two years ago I realized that the only time I heard from them was when it was time to pay the dues.)
I do FHA appraisals reluctantly and am always worried about hauling that ladder up the flight of stairs and if I’m alone, falling off and dying slowly in a vacant home where they will someday find my corpse. I hate that FHA requires that we inspect attics and crawl spaces but refusing to do them reduces my business volume. I wish there was a way we could gather as an industry and go on strike so no one will do FHA/HUD appraisals until they back off on the crawl space and attic inspections. The rest does not bother me much and I always write a long disclaimer detailing my lack of expertise concerning mechanical systems and that they should not rely on my inspection for anything except a photo. The physical demands for a 5 foot woman to haul an 8 foot ladder up stairs and try to balance on the top step is a cause for concern. I wish someone could come up with a reasonable solution, such as disbanding FHA/HUD and creating a more intelligent alternative. I have begun to refuse FHA appraisals due to safety concerns and if the conventional volume continues, that will be our ongoing policy.
Cobblestone Appraisal, Inc..
How simple it would be for HUD to require a Home Inspection on all FEDERALLY INSURED SFR loans. We are NOT home inspectors nor are we licensed contractors. Since 09/14/2015, I’ve been declining FHA orders. The AMC’s haven’t changed their fees, so am changing assignment accepting behavior. If and when FHA/USDA assignments reach the $1,000 threshold for the additional liability and physical requirements, I might jump back in, but for now, I’m just going to hang back and watch it play out.
Heck, from what I’ve read and heard, the statistics show the majority of appraisers presently appraising are in there 50’s+. and with the AMC’s fishing for the lowest fee, and there getting them, we can’t afford to share our fees with trainees, and who wants the additional liability. I feel within the next 10 years, the appraisers that are willing to stick it out that long, will either be making $1,000 an assignment due to the lack of appraisers, or lenders will figure out a way to bypass the appraiser, AVM’s, appraisal data base with a home inspection report, who knows. What I do know, within the 10 years there will have been more appraisers leaving the industry than entering.
Good luck All
I do not think it is cutting corners. Having discussed this multiple times with many there are a lot of opinions about what it says. I have heard a lot of them saying you got to look at every inch of the crawl space. It does not say that. It says readily observable. I too am older and although with my previous background could have just as easily done home inspections it does not fit with my physical condition and age. I believe like most of you that I am not a home inspector and the FHA manual 4000.1 specifically states that. Therefore if it looks out of the ordinary I will call for a third party inspection. The instructor I had did a face to face with the writer of the manual who stated that the intent is not to make you an inspector but to have you observe these items and look for things out of the ordinary. I only do a sample of turning on lights, turning on the HVAC, If it works at that time it is on. I cannot tell you the condition tomorrow or the next day just what I observe today at the time. A water pipe can burst tomorrow or the oven might blow up but I cannot predict the future and obviously I will do my best to inspect but if I cannot get in the space then I will let them know just like it says and if there are concerns will call for a qualified third party. A home inspector’s job is to inform the condition of the dwelling mine is to value it and if that home inspector finds some fault it can affect my value. I do appraisals not inspections.
The Problem is that people read into the manuals and guidelines. I don’t cut corners just do what it says.
I called for a nationwide strike many years ago, back with banker hours ruled all except appraisers. Appraisers worked weekend, holidays and evenings. When I was the state director for two year, part of my presentation was NOT working weekends, etc. I tried to explain that we ARE Professionals and if we want to be as one, we need to band together and change our image as door mats. 1980 was when I was first introduced into appraisal. The first of every year out price went up $25, every other appraiser in The general Seattle/Tacoma areas. We were busy. We started billing $350 or whatever but we offered $50 discount if paid within 30 days. That ended the slow payers! With the new FHA requirements, I stopped doing FHA. Busy may be slower, but, your sleep will be better not worrying about your “inspection” Please stop using that term! We are NOT performing an inspection! We are appraising a property. I think on the anniversary of HVCC we should all be on vacation. Our problem is that appraisers are loners and don’t want to join and most would take advantage of time off. Our WA State Coalition (ACOW) has had great results in our Capital. We have a paid Lobbiest and at our annual appraisal weekend, they will listen and lobby for our state appraisers. Join yours and become involved, it’s the future.
I would like to believe the comments made above. I too have done FHA appraisals for more than 30 years, and I’m taking an on line course now regarding the changes. As I see it, the new reg requires you to observe the entire crawl space. From the hatch you can’t see it with hanging insulation. You can’t see it if it is large, and you can’t see it if the foundation isn’t square or rectangular. If there is a water drip into the crawl space from a bath or kitchen, you can’t observe a slow drip from the hatch, you have to be close. IF you have to crawl the space, in most, you will do it on your back due to height constriction. You will take with you a mag light, a camera and a recorder to document your findings if like me, your memory isn’t as good as it used to be. Remember, FHA says you are responsible for the entire crawl space. That doesn’t mean to me that you observe and report on just what you can see from the hatch if you can’t see it all, and believe me, you can’t. As well as being a long term appraiser I am also a licensed home inspector and was active at it for more than two years. I have crawled hundreds of crawl spaces I know what it takes, and any appraiser who thinks they will just shoot a picture from the hatch and call ‘er good does not read the new rules as I understand them. It will take you 15 to 30 minutes minimum to observe the crawl space, up to an hour on larger houses or more difficult crawl spaces. FHA does not hold the appraiser to the level of inspection as a home inspector, but it does not say just a head and shoulders inspection with photos is adequate. That is what we have been doing, and the new standards of observe and report are different than what we have been doing. When you crawl a crawl space and are finished, you are dirty, often times sweaty, and you are pulling off boots, coveralls, head protection, gloves and a respirator. If you go into a crawl without a respirator having the highest level of filters, you might as well drive the freeway without a seat belt at full speed in the fog. There are things in a crawl that will make you sick if you breath them, coming from rodent and small animal feces. There is a possibility that there are things that will kill you, like Hunta Virus (sp?) that is occasionally found coming from mice.
Hope I’m wrong, and the other folks are right in the interpretation of the new guidelines concerning crawls and attics. I think it is up to FHA to more clearly explain what it is in the real world they expect appraisers to do. If it is crawl through crawl spaces to observe and report, I wouldn’t do it for a $500 bump in an appraisal fee.
It is pretty obvious that people are going to personally interpret the new FHA guidelines and complete the level of observation that they see fit. Although the new guidelines for “observing” attics and crawl spaces give the appraiser a reprieve under certain circumstances, they should not be interpreted as not having to comply with the rules in most cases. There always will be a certain percentage of the appraiser population who will suck the air out of the room by cutting corners and working cheap for market share rather than doing the work and charging a commensurate fee.
First the manual says “Appraiser refers to an FHA Roster Appraiser who observes, analyzes and reports the physical and economic characteristics of a Property and provides an opinion of value to FHA. An Appraiser’s observation is limited to readily observable conditions and is not as comprehensive an inspection as one performed by a licensed home inspector.” “Attic Observation Requirements. The Appraiser must observe the interiors of all attic spaces. The Appraiser is not required to disturb insulation, move personal items, furniture or debris that obstructs access or visibility. If unable to view the area safely……..the Appraiser must contact the Mortgagee to reschedule ….or complete the appraisal subject to inspection by a qualified third party. in cases where access through a scuttle is limited and the Appraiser cannot fully enter the attic, the insertion of at least the head and shoulders of Appraiser will Suffice.” Where does it say you have to crawl through the attic? If one enters the attic and attempts to walk the joists they will disturb insulation so why would someone think that you have to crawl across the attic. It states similar requirements for crawl spaces. “The appraiser must visually observe all areas of the crawl space…. In cases where access through a scuttle is limited, and the Appraiser cannot fully enter the crawl space, the insertion of at least the head and shoulders of the Appraiser will suffice.” No where does it state the Appraiser in his professional dressed clothing must crawl through the attic or the crawl space. Observation is only made and moving of personal items or destroying insulation, vapor barriers etc. is not required. Having previously worked for the Government for 30 years. I can see that some FHA employees might interpret the manual to state you have to crawl through the attic and crawl space. I read the book not listen to some employee or their interpretations. If FHA wanted you to crawl through the attic and crawl space they should have stated it plain and simple. Taking the update class from an instructor that had face to face contact with those writing the manual stated if you cannot readily observe just note it and explain why. If other evidence exists such as ceiling stains, moisture in the crawl space, discoloration of floor around baseboards or hardwood or smell then call for some qualified 3rd party just like it says. The appraiser per the manual only observes, analyzes, and reports and then walks away.
Since the manual requires photos of the Attic and Crawl space and cameras are available today that take good quality with zoom lens. Taking multiple photos or videos of readily observable areas to denote condition sounds like observation to me without destruction of the home, contents, insulation or accidental falling through the ceiling. If a scuttle is 10 feet off the floor and your ladder is not tall enough note it and call for someone qualified. I have no room for 20 foot ladders in my vehicle and no where does it say I have to have one.
This is minor compared to the requirement to turn on all appliances. “Cabinets and built in appliances that are considered Real Property must be present and operational.” (Cabinets? Do the doors open? the drawers pull out? ) “The appraiser must note appliances present in the house at the time of observation and indicate whether that appliance is consider Personal Property or Real Property. The Appraiser must operate all conveyed appliances and observe their performance.” (page 442 e iii) How about swimming pools “must be operational to provide full Contributory Value” (Guess bring your bathing suit will take a swim (ha ha). Want to make sure its operating, right?)
You can go on and on. Best thing is to be reasonable read it and “observe, analyze, and report” Just like it says.
You are right on the mark with all of your comments. I’ve been FHA approved for over 30 years, and it’s now to the point of being ridiculous. I’m sure my AARP insurance doesn’t cover rat bites or being electrocuted.
Jim did a great job with his comments. The attic and crawl space is just the tip of the iceberg. Three of my favorites are (is the heating and air installed to manufacturer’s recommendations)(does the heating and air comply with all local coded and regulations governing such equipment)(the electrical system must be adequate to support the electrical requirements of the subject). FHA is making a big thing of liability as well. If some of this doesn’t change, it wouldn’t surprise me to see E&O insurers opting out of FHA insuring. Of course that won’t happen until the claims start rolling in. If, in your judgement, you think things haven’t changed, you need to read the book again. I don’t see anything confusing in 4000.1. It is what it is.
Crawl spaces and attics are among the reasons why this office never has and never will do FHA appraisals. The fees are far from adequate to account for the red tape, liability and physical requirements.