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
Written by Thomas Morgan
Updated on September 6, 2024
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 |