From Mike Olsen:
Yes, we have been seeing the delays relating to your 2nd client, in fact we talked about that in the Lender Update. If they answer NO to any of the certification questions, then they are required to send in a response as to the reason. Once they answer no to one of those questions, the submission process is stopped until someone at HUD reviews their response and hopefully accepts it and unlocks the submission to allow them to continue the submission process. I have not heard how long HUD takes to review their response, but I would guess, based on what I have heard, it takes a couple weeks. It would be a really good idea to have your clients start the submission process the 1st part of January (for year end clients) and answer the certification questions so that they have plenty of time in case they cannot certify to all of the questions. Also, you may want to go over the certification questions with your clients to make sure they understand and answer the question correctly.
For the branch office delays, this is the first I have heard about it. For your year end clients, if they have any changes to their branches, especially those that have closed or no longer need to be registered, those changes need to be done before the end of the year, otherwise they will be required to pay for them. The recertification fee is based on branches on record as of Jan. 1. If they delete a branch after Jan. 1, they will still need to pay the recertification fee for the current year.
The best one to contact is Monique White-Chiselom. Her email address is:
Monique.R.White-Chiselom@hud.gov
Phone is 202-402-8262