Exactly which photographs an FHA appraiser must include under HUD Handbook 4000.1 after Mortgagee Letter 2025-18, what was removed, how grading and drainage problems are handled, and why none of it governs your MLS marketing photos.
Last reviewed against the published sources listed below.
Under HUD Handbook 4000.1 § II.D.4.a, an FHA appraiser must photograph the front and rear of the dwelling, a street scene, contributory improvements not shown in those shots, the kitchen, main living area, bathrooms, bedrooms, basement, recent renovations, any value-affecting view, every deficiency needing repair or inspection, and the front of each comparable. Mortgagee Letter 2025-18 (June 27, 2025) dropped the 'opposite angles to show all sides' rule and the attic and crawl-space photos. These rules bind the appraiser, not listing photos.
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Most FHA photo checklists online still describe the pre-June 2025 rules: side views at opposite angles, attic and crawl-space photos, and the appraiser's own photos of every comparable. HUD removed those items for Title II appraisals in Mortgagee Letter 2025-18, and agents still confuse the appraiser's photo exhibits with listing photos.
This guide quotes the current FHA Minimum Photograph Requirements table, shows the before-and-after of the June 2025 change, explains the grading and drainage standard appraisers apply, and gives a careful listing agent's pre-appraisal checklist, with every requirement linked to the HUD source.
HUD Handbook 4000.1 § II.D.4.a requires photographs of the subject's front and rear, contributory improvements not captured in those photos, a street scene, the kitchen, main living area, bathrooms, bedrooms, other rooms representing overall condition, the basement, recent updates, view influences that substantially affect value, deficiencies requiring inspection or repair, and a front view of each comparable used.
Benefit: One accurate list instead of outdated checklists
Effective immediately on June 27, 2025, HUD removed photo requirements it said exceeded industry standards: front and rear photos 'at opposite angles to show all sides', attic and crawl-space photos, new-construction grade and drainage photos, two-to-four-unit common-area photos, condominium common-area photos, and the requirement that appraisers add their own photos of comparables alongside MLS photos.
Benefit: Know which old requirements no longer apply
Handbook 4000.1 § II.D.3.b.iv(D) requires the appraiser to check for readily observable grading and drainage problems and to make the appraisal subject to repair if grading does not provide positive drainage away from the improvements. A deficiency must be photographed.
Benefit: Fix the slope before the appraiser sees it
The FHA photo table is addressed to the appraiser. Listing photos are governed by your MLS rules and state law. If you edit or virtually stage listing photos, BuildMyListing labels every altered image and pairs it with its unedited original, with a hosted disclosure page and QR code, so buyers and appraisers can see the real condition.
Benefit: Edited marketing photos that don't misstate condition
The FHA-approved lender (mortgagee) engages an FHA Roster Appraiser. The appraisal's intended use is to help FHA assess the risk of the property securing the insured mortgage, and FHA and the lender are its intended users (HUD 4000.1 § II.D.4.b).
The appraiser takes the photos required by the FHA Minimum Photograph Requirements table (front, rear, street scene, required interior rooms, basement, recent updates, view influences, deficiencies, comparables) and may add any other photos that support the analysis.
Where the property does not meet Minimum Property Requirements or Standards (MPR/MPS), such as grading that does not drain away from the house, the appraiser reports the needed repairs, an estimated cost to cure and descriptive photographs, and conditions the appraisal (§ II.D.3.n). The lender decides which repairs are required.
Recommendation: before an FHA appraisal, have the seller correct visible MPR issues (negative grading, standing water at the foundation, peeling paint on pre-1978 homes, missing handrails). Editing listing photos does not change what the appraiser observes on site.
| Photo exhibit | Required now (Title II, HB 4000.1 § II.D.4.a) | Before ML 2025-18 (pre-June 27, 2025) | Notes |
|---|---|---|---|
| Front and rear of dwelling | Required | Required, 'at opposite angles to show all sides of the dwelling' | Side coverage is no longer a stated minimum |
| Improvements with contributory value not in front/rear photos | Required | Required | e.g., detached garage, outbuilding, pool |
| Street scene | Required | Required, to include a portion of the subject site | |
| Grade and drainage photos (new construction) | Removed | Required | Grading/drainage still checked under § II.D.3.b.iv(D) |
| Grade of vacant lot (proposed construction) | Required | Required | |
| Kitchen, main living area, bathrooms, bedrooms | Required | Required | Plus any other rooms representing overall condition |
| Basement | Required | Required (with attic and crawl space) | |
| Attic and crawl space photos | Removed from photo table | Required | Observation duties remain (§ II.D.3.j, § II.D.3.l) |
| Recent updates (restoration, remodeling, renovation) | Required | Required | |
| Common areas of 2-4 unit properties | Removed | Required | |
| Comparables | Front view of each comparable utilized | Front view, front-and-side angle when possible; MLS photos acceptable but appraiser's own photos also required | |
| View influences that substantially affect value | Required | Required | Negative or positive |
| Deficiencies requiring inspection or repair | Required | Required | Also 'descriptive photographs' with repair conditions (§ II.D.3.n) |
| Condominium common areas and amenities | Removed | Required | |
| Title I manufactured home loans (§ II.F.8) | Older table still printed: opposite-angle front/rear, attic and crawl space, comparables with appraiser's own photos | Same | ML 2025-18 applied to Title II forward and HECM |
| Listing agent's MLS/marketing photos | Not covered by the FHA photo table | Not covered | MLS rules and state law apply |
Scenario: A seller added fill dirt and mulch beds that slope toward the house; water pools at one corner after rain. The buyer is using FHA financing.
Process: The appraiser checks for readily observable grading and drainage problems → negative slope or standing water adjacent to the foundation is noted → appraisal made subject to repair, with photos of the deficiency → lender decides on the required repair → seller regrades and a re-inspection follows.
Compliance: Recommendation: regrade so soil slopes away from the foundation and fix downspouts before the appraisal. Hiding the problem in listing photos does not help; the appraiser observes the site in person.
Scenario: A flipped home has a new kitchen and baths; the crawl space is damp. The agent assumes the appraiser no longer looks at crawl spaces because the photo requirement was dropped.
Process: Kitchen, baths and recent updates are photographed as required → crawl space photos are no longer a table minimum, but § II.D.3.l still requires observation of safely accessible areas → excessive dampness makes the appraisal subject to inspection or repairs.
Compliance: Dropping a photo requirement did not drop the observation requirement or the MPR.
Scenario: The listing's empty rooms were virtually staged for the MLS. The FHA appraiser schedules an interior inspection.
Process: The appraiser photographs actual rooms and condition → MLS marketing images play no role in the subject photo exhibits → the agent's obligation is to label staged images under MLS rules and any state law.
Compliance: BuildMyListing provides compliance documentation tools, not legal advice. Consult a licensed real estate attorney, and the FHA lender for appraisal conditions, about your specific transaction.
Primary sources checked on the dates shown below. Rules and statutes can change; confirm the current text before publishing.
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