| ID | Status | Date | Public/Private | Industry | AHACPA Contact |
|---|---|---|---|---|---|
| #8275 | Closed | public | FHA Lender | Les Sparks |
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Anonymous: Per chapter 7 of the HUD audit guide, Section 7-5,3(e)(2)(a) (page 7-10 of the guide issued 5/2014), “The holder (seller) is required to report the “sale of loans” to HUD within 15 calendar days”. 1. None of the clients were aware of this requirement Based on the HUD guide, we have had findings in the past for our clients and have made our clients aware of the need to follow this procedure. The fact that they have not changed to incorporate this procedure as part of their policy, AND the fact that they have not been cited from any other source (not their outside QC company and not by HUD) makes us wonder if this is indeed a requirement or if it should be dropped from our procedures for the compliance section of our audit. Would appreciate a timely response since we are in the midst of our “busy season” and are not sure how to approach this item. |
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[answer from Les Sparks] Thanks for the question. It’s been a while since I had to answer this question. The actual requirement can be found in Mortgagee Letter 2011-33. This requirement is then reiterated in the new Handbook 4000.1. I will include that below. I am quite sure that this is ignored and even more sure that outside QC reviewers are not doing it. Why? Just because this is what we always find. For the attached Handbook, the references are difficult to describe. The easiest thing is to just open it and do a search for “15 days”. That should clarify any remaining issues. |