| ID | Status | Date | Public/Private | Industry | AHACPA Contact |
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| #6949 | Closed | public | FHA Lender |
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We have a mortgage loan originator client who was audited by HUD this past year. They are a 10/31/16 fiscal year end. The auditors had a sample of approximately 30 loans that they requested backup documentation for. In the initial documentation, the client did not provide all of the backup that HUD was looking for, and there was back and forth correspondence for several weeks. At one point, HUD did label several loans missing documentation as “findings” in their correspondence. However, in their final letter, they did document that all prior “findings” were considered closed and there was to be no further action. Our question is – should those findings be documented in our HUD financial statements, or as they were considered closed findings prior to fiscal year end, are we fine omitting them from the statements? |
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From Mike Olsen: If there were findings, then those findings would need to included in the report. Here is what the HUD Audit Guide says about reporting these findings: 2-4 F. Schedule of the Status of Prior Audit Findings, Questioned Costs, and Recommendations. If, however, HUD withdrew the findings, then the findings would not need to be reported. From client: Thanks for your quick reply. We went back through our documentation, and believe that all the findings were refuted by providing additional documentation except potentially one, that being Ingraham. It seems like client is saying they did not get proper documentation at the time of closing, but have gotten it since and to their good luck the loan was deferred. We believe that item should be a finding, but wanted to get your thoughts based on that as well as the HUD reply that the findings were closed. I’ve attached two pages of correspondence for your reference, first page being the management response to the loan, and the second page being the HUD final response. Any input you have would be appreciated! From Mike Olsen: I would agree that this should be a finding. In addition, based on the letter received from HUD, the findings they reported, even thought they are now closed, should be disclosed in the prior audit findings report, as stated in the previous email. |