Dan Ardis Mortgage Specialist, Barrett Financial Group
Barrett Financial Group Commercial Division
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FHA Appraisals

FHA Appraisal Issues: Required Repairs, Property Standards, and How to Save the Deal

FHA appraisals come with property condition requirements that conventional appraisals do not. When the appraiser flags issues, most buyers and agents panic. Here is exactly what is required, what is not, and how to close anyway.

Dan ArdisBy Dan Ardis·Senior Mortgage Loan Originator·NMLS# 1412272

What This Guide Covers

  • FHA Minimum Property Standards: what the appraiser is required to flag
  • Required repairs vs lender overlays: an important distinction
  • How to negotiate repairs, seller credits, and escrow holdbacks to close
  • When to switch from FHA to conventional or use a 203(k) renovation loan

How FHA Appraisals Work and What Standards Apply

FHA appraisals serve two purposes simultaneously: they establish the property's market value and they assess whether the property meets HUD's Minimum Property Standards (MPS). This dual purpose is why FHA appraisals flag conditions that a conventional appraisal would note without requiring correction.

The FHA appraiser is required to report conditions that affect the safety, security, or soundness of the property. Safety means hazards to occupant health or life. Security means the property can be secured against unauthorized entry. Soundness means the structure is not in immediate danger of failure.

HUD's MPS for existing properties focus on five categories: the site (grading, drainage, hazards), the structure (roof, foundation, walls), the mechanical systems (electrical, HVAC, plumbing), health hazards (lead-based paint on pre-1978 homes, well water potability), and utilities (water, sewer, and electricity must be active and functional at the time of appraisal).

The appraiser does not make repair decisions. They observe and report conditions. The lender's underwriter then reviews the appraisal and determines which noted conditions must be resolved before the loan can close.

Required Documentation

  • FHA appraisal report (ordered by lender, provided to buyer)
  • Appraiser's list of required conditions or repairs from Section L of the appraisal
  • Contractor repair estimate for any conditions requiring remediation
  • Seller's signed agreement to complete repairs (or escrow holdback agreement if applicable)
  • Re-inspection report from original appraiser confirming repairs are complete
  • If 203(k): contractor agreement and HUD Consultant report

What Most Lenders Get Wrong

  • 1.Treating all appraiser observations as required repairs. The appraiser notes conditions. The lender's underwriter determines what must be corrected. Some conditions noted by the appraiser are advisory, not mandatory. Borrowers who are told all observations must be repaired may be working with a lender who has overlays stricter than FHA requires.
  • 2.Not offering escrow holdbacks as an alternative to completed repairs. FHA allows escrow holdbacks for certain repair types, holding 1.5 times the repair estimate in escrow until the work is complete after closing. Many lenders do not know how to execute this correctly.
  • 3.Not suggesting the 203(k) loan for properties with significant condition issues. An FHA 203(k) rehabilitation loan can close on a property that would not qualify for a standard FHA loan by rolling the repairs into the loan amount.
  • 4.Failing to explain FHA appraisal portability. An FHA appraisal is tied to the property for 120 days. If one buyer's deal falls through, the next FHA buyer within 120 days may be assigned the same appraisal, which protects the new buyer from a low value but also means they inherit any unresolved conditions.

What FHA Appraisers Are Actually Required to Call Out

Understanding what the FHA appraiser must flag versus what they may note as an observation is the difference between a manageable condition list and a deal-killing one.

Required to flag: peeling or deteriorating paint on any interior or exterior surface of a home built before 1978 (lead-based paint hazard). Missing or broken windows. Exposed electrical wiring or non-GFCI outlets in wet areas. A roof with less than two years of remaining useful life as estimated by the appraiser. Standing water in the crawl space or basement. Non-functional heating system in climates requiring heat. Inoperable kitchen appliances if they are conveying with the property. Evidence of active pest infestation.

Often flagged but not always required: deferred maintenance items like faded paint on exterior wood, minor cracks in drywall, old but functional HVAC. These are judgment calls the appraiser makes based on severity.

Not required under standard FHA guidelines but sometimes flagged by overzealous appraisers: cosmetic issues like dated kitchens or bathrooms, minor concrete cracks in driveways, older roofs that still have functional life remaining, outbuildings in disrepair that are not part of the primary dwelling.

For Kern County's older housing stock, particularly homes built in the 1960s through 1980s, peeling paint and aging roofs are the most common FHA appraisal conditions. Both are correctable, but they require the seller's cooperation or the buyer's willingness to fund the repairs.

Strategies to Close When FHA Appraisal Conditions Are Called

When an FHA appraisal flags required conditions, the deal does not have to die. There are four primary strategies, and the right one depends on the type of condition, the severity, the seller's position, and the loan timeline.

Strategy one: seller repairs before closing. The seller hires a contractor, completes the required repairs, and the appraiser conducts a re-inspection to confirm completion. This is the cleanest path when the seller is cooperative and the repairs are not extensive. The re-inspection typically costs $150 to $300 and must be completed before the loan closes.

Strategy two: price reduction and buyer-funded repair. If the seller is unwilling to repair, they may agree to a price reduction that accounts for the repair cost. The buyer then handles the repair, either before closing using their own funds or through an escrow holdback.

Strategy three: FHA escrow holdback. For certain minor repairs, FHA allows closing with an escrow holdback of 1.5 times the estimated repair cost. The funds are held in escrow and released to the contractor after the repair is completed post-closing. Not all lenders offer this, and HUD has specific guidelines on which repair types qualify. This is the most useful strategy when a seller will not repair and a buyer wants to close and handle the work themselves.

Strategy four: switch to a 203(k) loan or conventional financing. If the required repairs are substantial, an FHA 203(k) rehabilitation loan rolls the cost of the repairs into the purchase loan and allows closing on a property that would not otherwise qualify. If the borrower can qualify conventionally, switching loan programs eliminates the FHA property standards entirely, which applies standard appraisal requirements rather than FHA MPS.

Dan Ardis
Dan's Take
NMLS# 1412272

FHA appraisal conditions are the most common reason deals fail unnecessarily. The appraiser writes something, the listing agent tells the seller it is a dealbreaker, and both sides walk. In reality, most FHA conditions are fixable with one of four strategies, and the right strategy can be identified within 24 hours of seeing the appraisal. I have saved more deals by knowing the escrow holdback and 203(k) paths than by any other single piece of knowledge.

Are you dealing with FHA appraisal conditions on a property and want to know your options?

Call Dan at (661) 342-9381. He will review your specific situation and documentation in a free call.

Frequently Asked Questions

Can the seller refuse to make FHA-required repairs?
Yes. The seller has no legal obligation to make repairs. However, if the property has required conditions and the seller will not fix them, the FHA loan cannot close unless the buyer finds an alternative solution (price reduction, escrow holdback, or switching to a 203(k) or conventional loan). In a buyer's market, sellers are more likely to negotiate. In a seller's market, buyers often need to come prepared with alternative strategies.
Does FHA require an inspection in addition to the appraisal?
FHA does not require a standard home inspection. The FHA appraisal is a different document from a home inspection and has a different purpose. However, buyers are strongly encouraged to hire an independent home inspector, as the appraiser is not a home inspector and will miss many issues that a full inspection would catch.
My home was built in 1975 and has old paint. Is that an automatic FHA problem?
Not necessarily. Pre-1978 construction triggers the FHA lead-based paint requirement, but the appraiser is specifically looking for peeling, chipping, or deteriorating paint, not just old paint. If the paint is in good condition, the lead-based paint requirement may be noted as a disclosure item rather than a repair condition. If the paint is peeling anywhere, that specific area must be addressed.
Can I buy an as-is property with an FHA loan?
FHA does allow as-is appraisals in some circumstances, primarily for HUD REO properties sold through the HUD homestore. For standard sales, as-is means the seller will not make repairs, not that FHA waives the property standards. If the property meets FHA MPS in its current condition, as-is is fine. If it does not, the required conditions must still be resolved.
What is a Reconsideration of Value and when should I request one?
A Reconsideration of Value (ROV) is a formal request to the appraisal management company to have the appraiser reconsider their value conclusion based on additional comparable sales evidence. It is appropriate when the appraisal came in below the purchase price and you have evidence of recent comparable sales the appraiser did not use. The request must go through the lender and include specific comps with MLS data. It is not a guarantee of a value increase, but it is the correct process to follow before accepting a low value.

Are you dealing with FHA appraisal conditions on a property and want to know your options?

Dan will review your specific documentation and match you with the right lender. Call (661) 342-9381 or apply online.

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