§01
FHA requirements, Title 24 + Handbook 4000.1
FHA-insured single-family loans (HUD Handbook 4000.1, 2026 revision) require: lead paint disclosure under Title X (federal law) for pre-1978 properties. Disclosure of known lead-based paint and pamphlet provision; minimum property standards including safe water supply + sewage disposal + structural integrity. FHA does NOT require automatic radon testing. But FHA does require radon disclosure when the seller has tested + known elevated radon (above 4.0 pCi/L). Mold + asbestos: FHA appraisers note visible mold or visible deteriorated paint; specific testing is the buyer's discretion + lender-specific underwriting decision.
§02
VA loan requirements, VA Lenders Handbook
VA-guaranteed loans follow VA Pamphlet 26-7 + VA Lenders Handbook. Environmental requirements are discretionary based on appraiser observations + lender underwriting. VA does not have a mandated radon testing requirement but VA appraisers note visible mold, visible moisture damage, peeling paint (lead-paint indicator on pre-1978 housing), and other observable environmental conditions. VA appraisers can require corrections to MPR (Minimum Property Requirements) deficiencies before loan approval.
§03
Conventional loan environmental requirements
Conventional loans (Fannie Mae + Freddie Mac eligibility) follow GSE underwriting guidelines. Environmental testing is generally discretionary based on appraiser observation + lender underwriting policy. Some conventional lenders (M&T, KeyBank, PNC in commercial; varies in residential) apply additional environmental requirements on certain property types or risk profiles. Phase I ESA on commercial property is typically required by conventional lenders above certain loan thresholds. See our separate guide on commercial Phase I requirements.
§04
When radon testing is functionally required even without a mandate
Radon testing is functionally required (even without a federal mandate) when: (1) the seller has tested and disclosed elevated radon; (2) the buyer requests testing as a contingency in the purchase agreement; (3) the property is in EPA Zone 1 (which includes Allegheny County PA and many WNY counties) and the lender has internal underwriting requirements; (4) the property is in an FHA Zone 1 county and the seller has not provided radon documentation. Best practice: test radon on any closing in EPA Zone 1 regardless of mandate.
§05
Lead paint testing on pre-1978 properties
Federal Title X (Lead-Based Paint Hazard Reduction Act) requires disclosure of known lead-based paint hazards on pre-1978 housing. For both sales and rentals. The seller/landlord must provide the EPA-required lead-paint pamphlet + disclose any known lead conditions. Lead testing itself is not mandatory but is increasingly common in pre-1978 transactions, especially in markets like Buffalo, Erie, Pittsburgh with significant pre-1978 housing stock. XRF analyzer testing produces immediate results suitable for disclosure documentation.
