VA Loan Lead Paint Requirements for Pre-1978 Homes

The No-Exceptions Rule

If you're using a VA loan to buy a home built before 1978, there's a rule in the process that surprises almost everyone who encounters it: any peeling, chipping, or deteriorating paint is presumed to be a lead hazard and must be fixed before the VA will approve the loan.

Not tested. Not verified. Presumed.

The VA's logic is straightforward: lead-based paint was banned for residential use in 1978. Any older home may contain it. If the paint is deteriorating, lead exposure is possible. The VA won't finance that risk — and they don't care whether the specific peeling paint on the specific window trim in the specific bathroom actually contains lead or not.

In the Army, we had regulations that worked this way — rules where the intent was so clear that no exceptions were entertained. You could argue the specifics, but the policy wasn't debatable. VA lead paint requirements are that kind of regulation.

What the Appraiser Looks For

During the VA appraisal of a pre-1978 home, the appraiser specifically examines all painted surfaces for deterioration:

• Peeling paint — Paint lifting from the surface in sheets or curls
• Chipping paint — Paint breaking off in small pieces, often along edges
• Flaking paint — Paint separating in thin layers that fall away
• Scaling paint — Paint deteriorating in a fish-scale pattern
• Chalking paint — Paint leaving powder residue when touched

These conditions apply to both interior and exterior painted surfaces. Windows, doors, trim, walls, ceilings, porches, siding, garage doors, fascia — everything painted is evaluated.

If the appraiser finds deteriorating paint anywhere, it gets noted as an MPR deficiency. There's no "well, it's just one small area" exception. The documentation threshold is: is there deteriorating paint? Yes or no.

The Presumption Principle

Here's what makes the VA's approach different from how you might expect a reasonable policy to work: the VA doesn't require testing to prove lead is present. They presume it.

Pre-1978 + deteriorating paint = lead hazard. That's the equation, and there's no variable to change.

This means you can't argue "but we tested and it's not lead paint." The VA's position is: if it might be lead, treat it as lead. The cost of being wrong about lead — a child with permanent neurological damage — vastly exceeds the cost of being cautious — scraping and repainting a window frame.

In nursing, we applied this same logic to certain medications and allergies. If a patient reported a possible penicillin allergy but wasn't sure, we didn't give them penicillin to find out. We assumed the risk was real and chose an alternative. The VA applies this principle to lead paint. The stakes justify the presumption.

The Required Fix

The VA specifies exactly how deteriorating paint in pre-1978 homes must be addressed:

Standard Process

1. Scrape — Remove all loose, peeling, chipping, or flaking paint
2. Prime — Apply appropriate primer to bare surfaces
3. Paint — Apply two coats of suitable non-lead paint

Alternative: Encapsulation or Covering

Instead of scraping and repainting, the deteriorating paint can be covered with gypsum wallboard (drywall), plywood, plaster, or other approved materials. This option makes sense when scraping would be impractical — complex trim work, textured surfaces — or when the surface is being renovated anyway.

Either approach satisfies the MPR requirement. Choose based on what makes practical sense for the specific surfaces involved.

Who Does the Work — And Who Pays

Interestingly, the VA doesn't specifically require that lead paint remediation be done by a licensed lead abatement contractor — though many lenders prefer it and some states have additional requirements. The key requirements are mechanical: all loose paint removed, surfaces properly prepared, two coats applied, work areas cleaned.

Cost negotiation follows the standard VA MPR pattern:

• Seller pays: Most common for VA transactions — the deficiency is in their property
• Price credit: Seller credits buyer at closing, but the work must still be completed before closing for lead paint
• Buyer pays: Sometimes necessary to preserve a deal, especially in competitive markets

For minor deterioration — a peeling window sill, a couple of chipping door frames — the cost is typically a few hundred dollars and a day's work. Extensive deterioration throughout the house is another matter entirely, potentially reaching into thousands. Have your contractor quote the work before you negotiate, so you're working from real numbers, not guesses.

After the Fix: Verification

After remediation is complete, the VA requires verification:

• The VA appraiser may return to confirm the work is done
• Or another qualified party may verify and document completion
• The lender receives confirmation before proceeding

Documentation is your friend here. Photos before, during, and after. Contractor invoices showing work completed. If you had lead paint testing done independently, include those results. The more thorough your documentation, the faster the verification clears.

"Lead paint requirements are the one VA MPR issue where the rule is perfectly clear: no peeling paint on pre-1978 homes. Period. No judgment calls, no gray areas, no waivers. In a process full of nuance and interpretation, this one is refreshingly binary."

The Bigger Picture: Why Testing Still Matters

The VA's presumption rule handles deteriorating paint. But what about intact paint that contains lead? What about lead dust from past deterioration that's settled into carpet or soil? What about the window wells where lead dust accumulates from friction surfaces every time you open and close a window?

The VA doesn't address any of that. Intact lead paint isn't flagged. Lead dust isn't measured. Lead paint testing goes beyond what the VA requires — confirming actual presence and levels, identifying which surfaces contain lead for future renovation planning, and especially assessing risk for households with young children.

If you're buying a pre-1978 home and plan to renovate, or if young children will live there, independent lead testing provides information the VA process simply doesn't generate. The presumption rule is a safety net. Testing is a diagnostic.

Planning Ahead

If you're looking at pre-1978 homes with your VA loan:

1. Inspect paint condition during showings — Look for deterioration before you make an offer. If every window and door frame is peeling, factor that into your timeline and negotiation.
2. Factor repair costs into your offer — If paint is deteriorating, price accordingly from the start rather than negotiating remediation as an unexpected cost later.
3. Address issues before the appraisal — If the seller is willing to remediate proactively, the appraisal goes smoothly.
4. Get a home inspection — A thorough inspection identifies paint issues comprehensively before the appraisal.

Homes with obvious paint problems aren't necessarily bad deals. Many of the best-value properties in Oklahoma's older neighborhoods have cosmetic issues that scare away buyers who don't understand the cost of fixing them. A few hundred dollars in scraping and painting shouldn't cost you a home you love — but only if you plan for it instead of being surprised by it.