Develop a control to detect loans that did not maintain the required flood insurance to put $1.5 billion to better use by avoiding potential future costs to the FHA insurance fund from inadequately insured properties.

Corrective Action Taken

In November 2022, FHA published the Acceptance of Private Flood Insurance for FHA-Insured Mortgages final rule (Docket No. FR-6084-F-02) in the Federal Register and issued Mortgagee Letter 2022-18, Acceptance of Private Flood Insurance for FHA-Insured Mortgages (ML 2022-18). These policy changes not only strengthened Single Family’s Mortgagee requirements regarding flood insurance, but they also introduced the ability for borrowers and Mortgagees to purchase private flood insurance. In January 2023, the sections in ML 2022-18 that pertain to HUD’s forward mortgage programs were superseded by the FHA Single Family Housing Policy Handbook (Handbook 4000.1), adding a requirement that the Mortgagee review all FHA-insured properties annually to determine if the property is located within a Special Flood Hazard Area (SFHA). For properties located within a SFHA, the Mortgagee must ensure flood insurance is in force for the life of the mortgage and that the property has sufficient flood insurance coverage. To ensure compliance with the policy requirements, the Mortgagee must include updated flood insurance information for properties where flood insurance is required in the Servicing and Claims File. In addition, Handbook 4000.1 includes flood insurance servicing policy updates. HUD submitted a revised management decision reflecting this action on June 22, 2023.

Develop a comprehensive process to ensure that complaints received by HUD’s Multifamily Housing Clearinghouse are resolved in a timely manner.

Status

October 2023, the Office of Multifamily Housing Programs reported that HUD was transitioning the Multifamily Clearinghouse responsibilities to the Federal Housing Administration (FHA) Resource Center. The Office stated that it had requested IT Technology Fund funding for FY 2024 for system enhancements to coordinate tenant complaints throughout Multifamily Housing including Multifamily field staff and the Multifamily Clearinghouse Call Center.

Analysis

In June 2024, the Office reported that because the FY 2024 funding was not approved by Congress, it will use the FHA Resource Center and its system that will allow for tracking and monitoring of customer calls. In addition, the Office will request assistance from its Project Based Contract Administrators to use a standard, Multifamily-wide reporting format to standardize and aggregate tenant complaints.

Develop agencywide policies and procedures for the intake, monitoring, and tracking of health and safety complaints.

Status

October 2023, the Office of Multifamily Housing Programs reported that HUD was transitioning the Multifamily Clearinghouse responsibilities to the Federal Housing Administration (FHA) Resource Center. The Office stated that it had requested IT Technology Fund funding for FY 2024 for system enhancements to coordinate tenant complaints throughout Multifamily Housing including Multifamily field staff and the Multifamily Clearinghouse Call Center.

Analysis

In June 2024, the Office reported that because the FY 2024 funding was not approved by Congress, it will use the FHA Resource Center and its system that will allow for tracking and monitoring of customer calls. In addition, the Office will request assistance from its Project Based Contract Administrators to use a standard, Multifamily-wide reporting format to standardize and aggregate tenant complaints.

Develop and implement an action plan that includes sufficient policies, procedures, and controls that address households living in multifamily housing units having a sufficient supply of safe drinking water […]

Status

As of June 2024, the Office of Multifamily Housing has revised its procedures and related documents and is waiting for final approval.

Analysis

To fully address this recommendation, HUD’s Office of Multifamily Housing must provide evidence of an action plan that includes its procedures that address households living in multifamily housing units to ensure that they have a sufficient supply of safe drinking water. We have not been provided a copy of the final procedures developed; therefore we cannot assess whether they will be sufficient to address the recommendation.

Implementation of this recommendation will enable HUD to have sufficient oversight and control activities in place to ensure households living in multifamily housing units have a sufficient supply of safe drinking water.

Require lenders to obtain the borrowers’ consent to verify the existence of delinquent Federal taxes with the IRS during loan origination and deny any applicant with delinquent Federal tax debt and no payment plan or a noncompliant payment plan or an applicant refusing to provide consent from receiving FHA insurance to put at least $6.1 billion to better use by avoiding potential future costs to the FHA insurance fund.

Status

As of October 2023, the Office of Single Family Housing reported it will need additional tax information from the Internal Revenue Service to complete the planned action, and that the Office of the Chief Financial Officer will assist the Office of Single Family Housing. As of June 2024, no new update has been reported.

The final action target date was May 23, 2024, but was updated in June 2024 to May 23, 2025.

Analysis

To fully address this recommendation, HUD will need to provide evidence that it established a method of borrower consent to verify the existence of delinquent federal taxes.

Implementation of this rule should result in HUD putting $6.1 billion to better use.

Implement a change to regulations at 24 CFR Part 203 to require curtailment of preforeclosure interest and other costs that are caused by lender servicing delays, resulting in $413,513,975 in funds to be put to better use. This should include updating or seeking statutory authority to update HUD’s regulations as necessary and coordinating with HUD’s Office of Finance and Budget, well before any changes go through departmental clearance, to ensure that planned curtailment requirements can be consistently enforced through the claims process.

Status

This audit recommendations cannot be closed out without the publication of the Federal Housing Administration (FHA): Maximum Claim Rule. The proposed changes have been on HUD’s regulatory agenda since Spring 2020 but, as of June 2024, the Office of Single Family Housing does not have an estimated publication date.

Analysis

To fully address this recommendation, HUD must publish the FHA Maximum Claim Rule.

Implementation of this rule should result in HUD putting $413 million to better use.

Develop a method for using the Do Not Pay portal during the underwriting process to identify delinquent child support and delinquent Federal debt to prevent future FHA loans to ineligible borrowers to put $1.9 billion to better use.

Status

The Office of Housing has approved prioritization of funding for Integration between Do Not Pay portal and CHUMS. Funding was allocated to the CHUMS IT contractor on January 26, 2024, to integrate Treasury’s Do Not Pay system with CHUMS, and the IT development project was kicked off the week of February 5, 2024.

As of June 2024, the Office of Single Family Housing reported that it is working with OCIO and Treasury on the business needs for the project, and estimated that the project would be complete by September 30, 2024.

Analysis

To fully address this recommendation, HUD must provide evidence that it has implemented applicant screening against the Do Not Pay portal to identify delinquent child support and delinquent Federal debt to prevent future FHA loans going to ineligible borrowers.

Implementation of this rule should result in HUD putting $1.9 billion to better use.

Issue a change to regulations at 24 CFR Part 203, which would avoid unnecessary costs to the FHA insurance fund, allowing an estimated $2.23 billion to be put to better use. These changes include (1) a maximum period for filing insurance claims and (2) disallowance of expenses incurred beyond established timeframes.

Status

This audit recommendations cannot be closed out without the publication of the Federal Housing Administration (FHA): Maximum Claim Rule. The proposed changes have been on HUD’s regulatory agenda since Spring 2020 but, as of June 2024, the Office of Single Family Housing does not have an estimated publication date.

Analysis

To fully address this recommendation, HUD must publish the FHA Maximum Claim Rule.

Implementation of this rule should result in HUD putting $2.23 billion to better use.

Update selection rules for CAIVRS to provide for complete reporting of all ineligible borrowers to put $9.5 million to better use.

Status

In 2020, HUD suspended reporting delinquencies and defaults to the Credit Alert Verification Reporting System (CAIVRS) because these debts are owed to the lender and are not delinquent Federal debt. A debt is not delinquent until a payment is past due to HUD for a deficiency judgment against the borrower in connection with an FHA claim. Rather than add the missing borrowers to CAIVRS, HUD determined it would remove default and claim data from the system and use it to exclusively identify borrowers with delinquent Federal debt. This will resolve the issue of incomplete reporting of delinquent federal debts greater than 3 years old. As of early June 2024, the Office of Single Family Housing stated that it was on target to complete its action plan by June 28, 2024.

Analysis

To fully address this recommendation, HUD must provide evidence that it removed default and claim data from CAIVRS.

Implementation of this recommendation should result in HUD putting $9.5 million to better use.