• 0
      1. Your cart is currently empty.
    • item(s)$0.00
September 28, 2022 Kathi Markan

September HUD-REAC Newsletter: Water Stains/Water Damage/Mold/Mildew (Common Areas, Units)

Water Stains/Water Damage/Mold/Mildew

(Common Areas, Units)



*Our next HUD-REAC/UPCS Webinar Training Series starts this Thursday, September 29th!*

Register here: Getting REAC Ready Webinar Series


In this September 2022 issue of our HUD-REAC Monthly Newsletter, I am going to discuss the deficiencies associated with – Water Stains/Water Damage/Mold/Mildew. 

This is a deficiency that could potentially result in a “double-ding” where points are assessed against you for the Level 1 or Level 3 wall/ceiling/floor and points are assessed for the Health & Safety if the mold and/or mildew is over 1 square foot.

Even at a Level 3, the point value for the wall/ceiling/floor is only around 0.2 but the Health & Safety: Air Quality: Mold and/or Mildew is typically worth approximately 1 point on the average property.  (Point values vary based on the size of your property and how many N/A’s the inspector record in the inspectable areas).

Per the Federal Register

Common Areas and Units Level 1 Level 2 Level 3
Ceiling More than 1 sq ft

Less than 4 sq ft*

(I believe this to be in error – I believe they meant 4 sq inches to 1 sq foot – could help on an appeal!)

Under Units it does state 4 sq inches – 1 sq foot

N/A More than 1 sq ft
Floors N/A 4 sq inches – 1 sq ft More than 1 sq ft
Walls 4 sq inches – 1 sq foot N/A More than 1 sq ft


Per the Federal Register, the deficiency H&S Air Quality – Mold/Mildew can only be recorded under Common Areas, Units and Systems.  However, this deficiency under Systems is an error and appealable – mold/mildew should only be recorded in the space its observed whether it be common area or units).

The inspector’s software permits them to record this H&S under Site and Building Exterior – if this happens, it is not listed in the Federal Register which should support an appeal.  In most situations, if you’re in open air, your chances of having a reaction from exterior mold/mildew should be greatly reduced.


Per the Compilation Bulletin:

Only ceilings are considered cumulative – not walls or floors…this may also have been an oversight on HUD’s part.

“Holes, paint, and water stains/water damage/mold/mildew defects are cumulative when they appear on any one ceiling surface (per room).”

Determine the cause of the problem!

  1. Exhaust fans – unplugged, clogged with dust/debris, not used, inoperable/ineffective
  2. Persistent humidity or condensation – ventilation of the home is imperative – dehumidifiers could help too!
  3. Leaking roofs, pipes or AC system
  4. Drainage issues
  5. Cracks/gaps in the foundation or walls

Mold spores are literally everywhere – in the air and on every surface.  They will grow with sufficient moisture.  According to the experts, in high-enough quantities, it can negatively affect those that have an allergy to it, are immunosuppressed, or have other health conditions.  I have attached numerous links below from these experts if you want to know more!