An explanation of HUD audit requirements and corresponding electronic submission requirements can be found in the document titled “Submission and Review Requirements & REMS Critical Data Fields for Annual Financial Statements”

“Refinance – Replacing an Old FHA Loan with a New FHA Loan – No Change in Ownership or Control” section VI. E.

When a HUD-insured loan is replaced with a new HUD-insured loan with no changes in ownership, there is no break in financial reporting. The owner must file a full twelve-month AFS. REMS ownership information, including the “Date Owner Assumed Financial Responsibility (FASS)” (FASS date) remains unchanged. If the new loan is a new construction or substantial rehabilitation loan, then the FASS date is the day after cost certification cut-off.

[Note from AHACPA: At the time of the FASSUB electronic submission, the FHA number may not be updated in the template.  This is not a cause for concern.  Annual submissions are tracked in HUD’s system via Tax ID Number, not FHA number.  Additionally, there is no new setup required to access the submission.]