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HUD/FHA Audit - where are the items in my plans?

Lender, Agency, and Investor Approval

HUD/FHA Audit - where are the items in my plans?

This rubric will help you locate where audit items are within your policies and procedures - specifically for HECM Lenders

Last updated on 03 Nov, 2025

Compliance with FHA Requirements:

Request

Location

Manual

Section Number

Notes

Policies and procedures for compliance with new FHA requirements

Compliance Updates and Regulatory Monitoring

2-0 Compliance

2.1

Contains procedures for collecting updates and implementing compliance with FHA requirements

Policies and procedures for pricing FHA loans

Mortgage Insurance Endorsement Process

1-A Quality Control

1.53

Details pricing policies for FHA loans and endorsement process


Quality Control (QC) Program:

Request

Location

Manual

Section Number

Notes

Copy of the most recent version of the QC Plan (Must include HECM section)

Higher Risk Criteria Loans - HECM

1-A Quality Control

1.22.4

Details the quality control for HECM loans

Provide examples (templates) of all QC checklists and other loan review checklists used in QC audits

Production Review Elements – Checklist System

1-A Quality Control

1.30.2

Contains QC checklists and templates for audits


Closing/Post-Closing and Endorsement:

Request

Location

Manual

Section Number

Notes

Policies and procedures for closing/post-closing and endorsement

Mortgage Insurance Endorsement Process

1-A Quality Control

1.53

Covers the pre-endorsement checklists and FHA document templates

Process of completing the Insurance Application Function in FHAC and submission to HOC

Mortgage Insurance Endorsement Process

1-A Quality Control

1.53

Process for data integrity and submitting case binders

Provide the procedures for Late Endorsement

Corrective Action – Remediation of Late Payments

1-A Quality Control

1.53

Describes procedures for remediating late endorsements


Performance Monitoring:

Request

Location

Manual

Section Number

Notes

Policies and procedures for tracking and evaluating the performance of key participants

Higher Risk Transactions Selection

1-A Quality Control

1.22.5

Reviews how key participants are monitored for performance

Policies and procedures for approving and evaluating retail operations

Field Review Items

1-A Quality Control

1.25.1

Describes the process for retail operation approvals and reviews


Branch Eligibility and Employment Checks:

Request

Location

Manual

Section Number

Notes

Policies and procedures for branch eligibility

Field Review Items

1-A Quality Control

1.25.1

Contains criteria for branch registration and operational oversight

Policies and procedures for employment checks (Conflicts of interest, dual compensation, exclusion from HUD programs)

Disbarred Employees/Ineligible Participants

2-0 Compliance

1.12

Details employment checks and conflict of interest verification processes


Training:

Request

Location

Manual

Section Number

Notes

Policies and procedures for training

Employee Training Program

2-0 Compliance

2.16

Contains guidelines for training staff, including FHA-related changes


Marketing and Advertising:

Request

Location

Manual

Section Number

Notes

Policies and procedures for marketing and advertising

Field Review Items

1-A Quality Control

1.25.1

Describes marketing compliance and advertising standards


Mortgage Insurance Premiums:

Request

Location

Manual

Section Number

Notes

Policies and procedures for mortgage insurance premiums

Mortgage Insurance Endorsement Process

1-A Quality Control

1.53

Details the procedures for mortgage insurance premium remittance


Compliance and Sanctions:

Request

Location

Manual

Section Number

Notes

Policies and procedures for Repurchase Demands, Suspensions, Terminations, or Other Sanctions and Compliance

QC Financial and Compliance Audit

1-A Quality Control

1.60

Describes handling of sanctions and repurchase demands


Consumer Complaints:

Request

Location

Manual

Section Number

Notes

Written procedures for handling consumer complaints

Field Review Items

1-A Quality Control

1.25.1

Details procedures for documenting and handling consumer complaints


Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) Records:

Request

Location

Manual

Section Number

Notes

A copy of the Company’s AML Program

AML Program Overview

1-A Quality Control

1.60

Contains the Company’s AML program description

The name of the compliance officer responsible for AML

Compliance Officer Roles

1-A Quality Control

1.60

Lists the designated officer and responsibilities

Copies of BSA/AML risk assessments

Risk Assessment Process

1-A Quality Control

1.60

Details risk assessments performed by the Company

Copies of CTRs and SARs filed

SARs and CTRs Recordkeeping

1-A Quality Control

1.60

Discusses the filing process for SARs and CTRs

Independent reviews of the BSA/AML program

BSA/AML Independent Review

1-A Quality Control

1.60

Contains the most recent independent review process

Training program for employees for BSA/AML

BSA/AML Employee Training Program

1-A Quality Control

1.60

Details employee training procedures for AML compliance

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