We performed an audit of MidFirst’s compliance with Federal Housing Administration (FHA) requirements for foreclosures that started in 2022.  Pursuant to the Coronavirus Aid, Relief and Economic Security Act (CARES Act), as extended by the Secretary, from March 18, 2020, through July 31, 2021, there was a pause on new and ongoing foreclosures for FHA single‐family mortgages for homes that remained occupied. We selected MidFirst Bank because it was among the first servicers to resume initiating foreclosures after the moratorium ended with a foreclosure rate above 1 percent.  Our audit objective was to determine whether MidFirst Bank complied with FHA’s requirements for loss mitigation before initiating and continuing foreclosure.

 MidFirst Bank did not follow FHA’s requirements for more than 14 percent of its foreclosures in 2022.  Based on a statistically valid sample drawn from a universe of 7,363 FHA-insured loans totaling $890 million, MidFirst did not complete the required loss mitigation activities before initiating or continuing foreclosure for an estimated 1,038 loans.