In June 2020, we received letters from members of Congress, including the chairpersons of the House Committee on Financial Services and Oversight and Investigation Subcommittee, expressing concern that the U.S.

We prepared this memorandum to provide the Office of Housing at the U.S. Department of Housing and Urban Development (HUD) with key considerations from prior audits of the HUD Single Family Default Monitoring System (SFDMS) and the partial claim loss mitigation option.  These audits identified HUD’s lack of effective controls to ensure that lenders reported default information accurately and in a timely manner, lenders promptly filed and reported partial claims, and partial claims fully reinstated delinquent loans.

HUD OIG is auditing HUD's Office of Single-Family Housing - Federal Housing Administration (FHA) program partly in response to media reports which have highlighted instances when lenders did not properly administer the COVID-19 forbearance options.  The audit objective is to determine whether FHA insured borrowers properly received the CARES Act forbearance options.

HUD OIG is reviewing HUD's real estate owned (REO) program for Section 184 Tribal Trust land properties.  Through this program, HUD can sell foreclosed properties previously endorsed under section 184 of the Housing and Community Development Act of 1992.  The objective of the review is to determine whether HUD is appropriately tracking, marketing, and selling REO Section 184 Tribal Trust Land properties.

HUD OIG is auditing HUD’s oversight of Federal Housing Administration (FHA) refunds.  FHA insures mortgages to increase homeownership opportunities.  An upfront insurance premium, paid at the time of closing, is refundable if the loan ends early, whether through sale, foreclosure, or refinancing.  We received a hotline complaint describing roadblocks to obtaining refunds.

HUD-OIG is auditing COVID-19 single family forbearance reporting. The audit will help HUD to determine how accurately the servicers are reporting the forbearance assistance offered to their customers. The audit will further enable HUD to adequately forecast the performance of its FHA loan portfolio in order to maintain an adequate capital ratio. The audit objective is to determine whether data available in HUD’s single family default monitoring system (SFDMS) is consistent with information maintained by loan servicers.

HUD OIG is  researching prior audits of HUD’s partial claims loss mitigation option.  On July 8, 2020, FHA issued Mortgagee Letter 2020-22 informing mortgagees the full suite of loss mitigations available to single family borrowers affected by the COVID-19 pandemic.  The purpose of this research is to provide HUD information regarding lessons learned and risks identified in these prior audits that HUD should act on now to ensure program integrity and mitigate the risk of financial loss for COVID-19 related partial claims.  

HUD OIG is researching prior audits of HUD’s Single Family Default Monitoring System to provide HUD information regarding lessons learned and risks identified in these prior audits.  The forbearances will result in increased claims filed against the insurance fund.  The lessons learned from prior audits identify what actions HUD should take now to ensure program integrity and mitigate the risk of financial loss for COVID-19 related forbearance assistance and foreclosure moratorium related to single family loans.  

HUD OIG is reviewing HUD's corrective actions in response to four specific recommendations made in audit reports 2012-PH-0004, 2013-PH-0002, 2014-PH-0001, and 2015-PH-0004.  Our prior audits showed that HUD’s controls did not always ensure that HECM loan borrowers complied with program residency requirements.  The audits included a recommendation to prevent and mitigate instances of borrowers violating the principal residency requirements.   The objective of our audit is to determine whether HUD's actions to address the recommendations were adequate.

We initiated an audit of the U.S. Department of Housing and Urban Development’s (HUD) oversight of Federal Housing Administration (FHA) refunds to determine whether HUD appropriately, effectively, and efficiently tracked, monitored, and issued FHA refunds owed to homeowners with terminated loans. During the audit field work, the Coronavirus 2019 (COVID-19) pandemic began and as a result, we developed a second, more urgent audit objective to determine how COVID-19 affected policies, procedures, and distribution of FHA refunds and whether HUD’s response was appropriate.