HUD Renewal and Recertification
*Ms. Riggin is not admitted to the practice of law.
The U.S. Department of Housing and Urban Development published notice in the Federal Register on June 18, 2013 that it is seeking public comments on the information used by FHA to verify that lenders meet all approval, renewal, update and compliance requirements. The notice solicits comments on ways to enhance the quality, utility, and clarity of the information and to minimize the burden of the collection of information on those who are to respond, such as electronic submission of responses.Submitting comments on how the Department can reduce the burden of this obligation may benefit mortgagees and the Department. Mortgagees that have contended with the overly broad definition of “unresolved findings” and/or the ambiguity of reporting matters associated with HUD’s ineligibility criteria are aware of the challenges a mortgagee may encounter in completing the annual recertification process and complying with the Department’s requirements for reporting business changes. In this regard, it may be helpful to make suggestions that the Department could rely upon to clarify reporting obligations, better define terminology, and improve upon the method of reporting business changes. It also may be helpful to explain the difficulties mortgagees face in responding to the Department’s requests for copies of regulatory examination reports that are subject to strict confidentiality provisions.
Comments are due by July 18, 2013. Please contact us for additional information or for assistance in formulating comments.