Paul S. Henderson, REALTOR®, CRS, South Puget Sound Washington Agent/Broker! (Fathom Realty Washington LLC)

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Anna "Banana" Kruchten
HomeSmart Real Estate - Phoenix, AZ

Yes I think that is correct.  It's been a while since I've had any of these loans but I do recall 2 layers is max for a roof.  Ask John Meussner !

Sep 08, 2023 05:48 PM
Margaret Rome Baltimore 410-530-2400
HomeRome Realty 410-530-2400 - Pikesville, MD
Sell Your Home With Margaret Rome

It may depend on the condition of the existing roof. We are allowed a maximum of two layers. If the underlayment is shot, I would hope not...But who is checking? Have you ever seen an appraiser up on a roof?

Sep 08, 2023 09:03 PM
Nina Hollander, Broker
Coldwell Banker Realty - Charlotte, NC
Your Greater Charlotte Realtor

Sorry, but I have no clue... a lender specializing in these loans would know.

Sep 08, 2023 01:37 PM
Big Block Realty 858.232.8722 - La Jolla, CA
Serving Coastal San Diego, Veteran's & Seniors

Appraisers do not arrive with ladders and do not typically inspect roofs unless there's a blatantly obvious condition. They would typically have no way of knowing the roof condition or layer quantity. In 24+ years I've never had any appraiser look at a roof anymore than they can see it from their exterior walk around. But, I'll defer to Jason E. Gordon to correct me if I've just been lucky and there's more to this than I've experienced.

Sep 09, 2023 06:36 AM
Fred Griffin Florida Real Estate
Fred Griffin Real Estate - Tallahassee, FL
Licensed Florida Real Estate Broker

As Peter Mohylsky, Beach Expert said, not in Florida.

  Even if VA or FHA appraisers "allowed it", Florida building codes will most likely prevent it.  We have some of the most stringent roofing laws in the nation... multiple inspections are required, every nail and every piece of felt is subject to examination. 

   The days of applying a new layer of shingles over an existing roof in Florida are long gone.

Sep 09, 2023 06:20 AM
Brian England
Ambrose Realty Management LLC - Gilbert, AZ
MBA, GRI, REALTOR® Real Estate in East Valley AZ

I don't know the answer to that, I am glad others do and commented.  Q & A is always a good learning opportunity in the Rain!

Sep 09, 2023 04:38 AM
Peter Mohylsky, Beach Broker
PMI. Destin - Miramar Beach, FL
Call me at 850-517-7098

Not in Florida.

Sep 09, 2023 03:38 AM
Kathleen Daniels, Probate & Trust Specialist
KD Realty - 408.972.1822 - San Jose, CA
Probate Real Estate Services

My sense is that it may depend not only on the lender guidelines, it may also be subject to the appraiser's discretion, to some degree.  

Caroline Gerardo - what say you?


Sep 08, 2023 04:14 PM
Lyn Sims
Schaumburg, IL
Real Estate Broker Retired

In my area you can. Max of 2 shingles

Don't forget that pealing gutter paint.

Sep 08, 2023 11:28 AM
Richie Alan Naggar
people first...then business Ran Right Realty - Riverside, CA
agent & author

This is a good question...lets find out Paul

Sep 08, 2023 10:41 AM
Candice A. Donofrio
Next Wave RE Investments LLC Bullhead City AZ Commercial RE Broker - Fort Mohave, AZ
928-201-4BHC (4242) call/text

(misplaced intended comment on Fred Griffin Florida Real Estate 's answer . . . ActiveRain Member Support can we no longer IMMEDIATELY delete an answer? BC I couldn't!

We have some of the most stringent roofing laws in the nation

I bet you do! 

We've had to have many roof certs as condition of closing . . . we don't have hurricanes but high winds yes. And why many many homes have tile or metal roofs!


Sep 09, 2023 07:03 AM
Wayne Martin
Wayne M Martin - Oswego, IL
Real Estate Broker - Retired

Been retired for a while now, so I will go with Nina Hollander, Broker and move on!

Sep 09, 2023 05:09 AM
Doug Dawes
Keller Williams Evolution - 447 Boston Street, Suite #5, Topsfield, MA - Topsfield, MA
Your Personal Realtor®

I do believe a roof with one layer is allowed an up and over 2nd layer

Sep 09, 2023 04:29 PM
Diana Zaccaro Broker Associate
ZOOM Realty Group - Cocoa Beach, FL
"The Accidental Blogger" Cocoa Beach, Florida

I don't know about VA/FHA but I would not recommend that anyone do this.


When we bought our first house up north (eons ago), one house that we looked at had hairline cracks in the middle of the dining room and living room ceilings. When we asked about that, eventually we were told that the "new" shingles were placed over the old and the added weight caused too much stress which resulted in the cracks.


That was a deal breaker for us since there was no way of knowing if there was a problem under the old shingles before the new ones were added or if the stress cracks would get worse over time if what we were told was true.


Sep 09, 2023 12:57 PM
Roy Kelley
Retired - Gaithersburg, MD

Appraisal requirements for FHA mortgage loans are found in HUD 40001., and include guidelines for electrical systems, plumbing, paint, and also requirements for the roof.

The condition of the roof is important as it’s a major source of headaches for a homeowner if there is a problem down the line. Borrowers should remember that the appraisal does not guarantee the roof is free of problems, and a home inspection should be carried out to include a closer look at the roof than an FHA appraisal will give.

FHA loan appraisal fees do not cover this inspection, but the inspection is an important investment that could save you thousands of dollars later on.

What is an FHA appraiser required to do when considering the roof? HUD 4000.1 says, “The Appraiser must notify the Mortgagee of the deficiency…if the roof covering does not prevent entrance of moisture or provide reasonable future utility, durability and economy of maintenance and does not have a remaining physical life of at least two years”.

An FHA appraiser is required to view the roof, but does not specifically have to step out onto the surface of it. That’s one big difference between an appraisal and a home inspection. “The Appraiser must observe the roof to determine whether there are deficiencies that present a health and safety hazard or do not allow for reasonable future utility. The Appraiser must identify the roofing material type and the condition observed in the ‘Improvements’ section of the report.”

As you can see from the reading of HUD 4000.1 above, the rules do not require or instruct the appraiser to step out onto the roof. A home inspection, paid for by the borrower, would include a closer look at the roof than what is required here by HUD 4000.1.

Page 489 adds the following:

“The Appraiser must report if the roof has less than two years of remaining life, and make the appraisal subject to inspection by a professional roofer. When the Appraiser is unable to view the roof, the Appraiser must explain why the roof is unobservable and report the results of the assessment of the underside of the roof, the attic, and the ceilings.”

It cannot be emphasized enough that an FHA appraisal is not meant to be a top-to-bottom inspection of the roof. The FHA official site has a section titled, For Your Protection Get A Home Inspection, which urges borrowers to pay for the optional procedure.

The FHA official site also warns borrowers that there is no financial help from the FHA for those who opt not to get the inspection and later discover defects or other problems with their home (on the roof or anywhere else in the home) once the loan has closed.

Sep 09, 2023 10:58 AM
Carla Freund
Keller Williams Preferred Realty - Raleigh, NC
NC Real Estate Transition & Relocation 919-602-848

I don't know but we don't usually see roof with extra shingles.

Sep 09, 2023 10:13 AM
Joan Cox
House to Home, Inc. - Denver Real Estate - 720-231-6373 - Denver, CO
Denver Real Estate - Selling One Home at a Time

In Denver, the City code says only one layer of roofing.   Not sure what an appraiser would allow.

Sep 09, 2023 07:01 AM
Brenda Mayette
Miranda Real Estate Group, Inc. - Glenville, NY
Getting results w/ knowledge & know-how!

I've never had one ask... 

Sep 09, 2023 06:48 AM
Jeff Dowler, CRS
eXp Realty of California, Inc. - Carlsbad, CA
The Southern California Relocation Dude

It may depend on the lender requirements, as well as the appraiser's recommendations.

Sep 08, 2023 07:52 PM
Debe Maxwell, CRS
Savvy + Company (704) 491-3310 - Charlotte, NC

2 layers are allowed here but, I would think the lenders here would have better answers than us Realtors®! 

I would have to question when the last time you had a VA or FHA appraiser walk a roof. That certainly doesn't happen here!

Sep 09, 2023 09:01 PM
Don Baker
Lane Realty - Eatonton, GA
Lake Sinclair Specialist

county code doesn't so there's not likely to find one.  The exception is metal over shingles... that is allowed if done correctly.

Sep 09, 2023 02:08 PM
Bob Crane
Woodland Management Service / Woodland Real Estate, KW Diversified - Stevens Point, WI
Forestland Experts! 715-204-9671

Not sure why fha thinks that they know better than the local building codes and that their appraisers know more than the building inspectors.

Sep 09, 2023 10:00 AM
Tammy Lankford,
Lane Realty Eatonton, GA Lake Sinclair, Milledgeville, 706-485-9668 - Eatonton, GA
Broker GA Lake Sinclair/Eatonton/Milledgeville

unless one is putting a metal roof over a shingle roof it's just not something that occurs in my market.  Roofers pull off shingles, inspect and replace decking as needed, and re-shingle.  I'd NEVER heard of putting shingles over shingles until I read it on AR and I still find it absurd.

Sep 09, 2023 09:09 AM
Bob "RealMan" Timm
Ward County Notary Services - Minot, ND
Owner of Ward Co Notary Services retired RE Broker

I never ran into this Paul S. Henderson, REALTOR®, CRS even though many loans here are VA due to our AFB. 

Sep 10, 2023 09:18 AM
John Juarez
The Medford Real Estate Team - Fremont, CA

If you need a roof inspections, get an inspection done by a inspection company. I do not believe appraisers are competent judges of the quality of a roof other the what is obvious to anyone. 

This seems to be an issue that varies from region to region.

Sep 10, 2023 10:05 AM
Paul S. Henderson, REALTOR®, CRS
Fathom Realty Washington LLC - Tacoma, WA
South Puget Sound Washington Agent/Broker!

Thank you it just goes to show how smart you all are and I appreciate your comments 🙂

Sep 13, 2023 05:19 PM
Caroline Gerardo
Licensed in 20 states - Newport Beach, CA
C. G. Barbeau the Loan Lady nmls 324982

If in Tornado Alley or recent hurricane area the Underwriter will see inspections mentioned in the contract. So the leap there is the roof was damaged and what is local code. Are the rafters sound, the underlayment still intact, does the ceiling show signs of leaks? In Tacoma a contractor can get aluminum roof installed over good existing shingled roof signed off by planning. Two layers are "okay" in your city.     However with a VA loan the Underwriter who reviews everything (not just the appraiser) could say that this is not the most sound roof for the veteran and seller gets stuck as with VA loan often the buyer doesn't have $20000 to install a new roof and seller won't allow before closing. My answer is less worrisome with FHA. If there is no mention in the contract of inspection and no counters about roof viability and the roof appears perfect then the Underwriter might never notice and appraiser might not note there are two layers. It depends how the appraiser mentions it, city code varies by location, how it appears, how good the work was...   Most appraisers come with a ladder AND they use a long pole like a selfie stick to take pictures of the roof for their references. They may go look at permits. They also can see if the eaves are dry rot or where leaks are patched. Appraiser is not a guarantee for an inspection but they are pretty snoopy

Sep 10, 2023 03:59 PM