FHA New Construction With No Certificate of Occupancy: What Does the File Need?

The file needs three inspections: footing, framing, and final. When the jurisdiction issues no building permit and no certificate of occupancy, FHA asks for each one to be documented on form HUD-92051, the Compliance Inspection Report.

Have a new-build file in a county that does not inspect? See HUD-92051 new construction inspections at Scapular Engineering.

How do I know the file is headed for this condition?

Ask the borrower or builder one question at application: who issues the building permit and the certificate of occupancy for this address? If the answer is "nobody" or "the county doesn't do that," the file will need the three inspections. Rural lots outside city limits are where it comes up.

Finding out at underwriting is too late for two of the three. Finding out at application leaves time to arrange them.

What should a loan officer do first?

1. Confirm the jurisdiction in writing. A short email from the county or city office saying it issues no building permit or certificate of occupancy for the address belongs in the file.
2. Confirm who can inspect. FHA looks first to an ICC-certified Residential Combination Inspector or Combination Inspector. Where none is available, a registered architect or a structural engineer may do the three inspections. Your underwriter confirms which the file can use.
3. Get the builder's schedule. The footing inspection has to happen before the concrete pour.
4. Put the inspector in touch with the builder. The builder calls for each visit; the loan officer should not be the relay.

What does the underwriter receive?

Three Compliance Inspection Reports, one per stage, each identifying the property, the stage inspected, and whether the work observed complies. They sit in the file alongside the appraisal, the builder's certification, and the warranty documents, which are separate items.

What if the house is already finished?

The footing and framing inspections cannot be done after the work is covered, and an inspector cannot sign for work that was never observed. Tell the underwriter exactly which stages were and were not inspected, and ask which FHA documentation path the file can use. An engineer can describe what an evaluation of the finished structure can and cannot cover.

Is this the same as a manufactured-home foundation certification?

No. A manufactured home on a permanent foundation follows a different path, with an engineer's certification that the foundation meets HUD's permanent-foundation guide. That is the report this site covers. A site-built house with no local inspections follows the HUD-92051 path above.