The primary elements of the FHA Minimum Property Requirements (MPR) are: safety, soundness and security, also known as the three Ss. The "head and shoulders" test, another icon of FHA appraisal protocols, is the level of due diligence that must be performed by the appraiser in order to properly assess the three Ss. An integral part of the inspection of the home, the head and shoulders test simply means that the appraiser must inspect the attic and basement/crawl space by entering the access point, at minimum, to the head and shoulders level to enable the appraiser to visually get a sense of the condition of the space and note any deficiencies. The appraiser should have a flashlight or other device to illuminate the space being inspected and should always provide photographs of problem areas to document required repairs and/or inspections. Typically, entry to attics can be achieved via a pull down stairway or scuttle located in the ceiling. Entry to most basements is straight forward while access to crawl spaces can be problematic. If the means of entry are secured or blocked in such a way as to prevent entry, the appraiser must contact the lender and re-schedule an inspection when such entry ports are unblocked and accessible. The appraiser is not required to move items such as furniture, equipment or debris that may block entry and it is the responsibility of the lender to ensure that such access ports are freely accessible. If access is not feasible and/or places the appraiser in physical danger, the appraisal must be conditioned upon a satisfactory inspection by a qualified third party. The appraiser may want to provide photographic documentation to the lender to support a claim of inaccessibility. If the design of the home does not permit inspection of an area (such as the attic in cases of flat roofs), the appraiser must comment on this within the report.
Attics should always be ventilated and any evidence of water or fire damage, structural problems, exposed and frayed wiring or other hazards in either the attic or basement/crawl space must be noted and the appraisal must be conditioned on their repair/correction. Standing water in a basement/crawl space or bulging foundation walls are clear signs of deficiencies that require correction. Water collecting on the interior side of roof sheathing is a clear sign of leakage or system failure and the condition must be corrected.
A corollary to the "head and shoulders? test is functionality testing of a home’s mechanical, electrical and plumbing systems, which cannot be accomplished without the utilities being on. If the utilities are not operational at the time of inspection, the appraiser must notify the lender and reschedule an inspection at a time that the utilities are operational.
The "head and shoulders" test and functionality testing do not assume any special expertise or skills on the appraiser’s part, nor are they technically exhaustive. FHA appraisers are to report on what is readily observable and must have access to all improvements. Being alert and conscientious during the course of the property inspection will increase the probability that deficiencies or other adverse conditions that can pose a threat to the health and safety of the occupants or adversely impact the value and marketability of the property are noted and accounted for in the appraisal.
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