HUD: FHA INFO #20-85: Updates to FHA Single Family Housing Policy Handbook 4000.1

Investor Update
November 18, 2020 

Source: HUD

Today, the Federal Housing Administration (FHA) published an update to Single Family Housing Policy Handbook 4000.1 (SF Handbook). This update includes revisions and additional clarifications to various FHA policies and programs throughout the SF Handbook since its last update on January 2, 2020, as well as the incorporation of changes previously announced in the Mortgagee Letters included in the Handbook Transmittal, which can be found on the Housing Handbooks page on hud.gov.

FHA encourages Mortgagees and other interested stakeholders in FHA transactions to review and familiarize themselves with the changes in this update as outlined in the Handbook Transmittal. Additionally, a separate redline version of the SF Handbook has been posted on its Handbook Information Page.

As a quick reference, following are some Key Changes included in each Handbook section:

Section I — Doing Business with FHA

• Clarification of the application and eligibility financial requirement for the covered audit period by stating a Mortgagee’s audited financial statements must cover the most recent fiscal year. For companies operating fewer than 12 months, the audited financial statements must cover all months of operation.

• Clarification and alignment with 24 C.F.R. § 202.5(m)(1) of the Post-Approval reporting requirement for a Mortgagee that experiences an operating loss of 20 percent or greater of its net worth.

• Clarification of the notification requirements for a Mortgagee that ceases operations to submit a change request in the Lender Electronic Assessment Portal (LEAP) for voluntary withdrawal of FHA approval.

Section II — Origination Through Post-Closing/Endorsement

• Clarification of the definition of an Accessory Dwelling Unit (ADU) located on a single family residential property. A one-unit property with an ADU will be treated as a one-unit property; however, an ADU located on any property with two or more units must be considered as an additional unit.

• Instructions for addressing situations where, during the application process, it is discovered that an existing debt or obligation secured by a Mortgage is not listed on the credit report and not considered by the Automated Underwriting System (AUS).

• Adding Form HUD-9991 and other Required Condominium Documents to the Case Binder Stacking Order.

Section III — Servicing and Loss Mitigation

• Incorporation of guidance on enhancements to FHA’s Claims Without Conveyance of Title (CWCOT) Procedures

• Incorporation of guidance on Loss Mitigation Options for Borrowers affected by the COVID-19 National Emergency.

Section IV — Claims and Disposition

• Incorporation of guidance on use of FHA Catalyst for Supplemental, Loss Mitigation Home Retention, and Reconveyance claims submissions.

Section V — Quality Control, Oversight and Compliance

• Clarification of the existing requirement for conducting field reviews of appraisals on early payment default (EPD) mortgages by requiring Mortgagees to perform field reviews on all (100 percent) of the EPDs underwritten by the Mortgagee.

• Incorporation of FHA’s Defect Taxonomy Appendix 7.0 into the Title II Loan Review section of Mortgagee Monitoring.

The effective dates for the various SF Handbook sections are as follows:

• SF Handbook changes that are incorporated to reflect a ML (as identified in Section II of the Transmittal) have an effective date as previously announced in the respective ML. Changes identified in Sections I.A, V.A, and V.E.4.b must be implemented immediately.

• Changes identified in Section II.A may be implemented immediately; however, implementation is mandatory for mortgages with case numbers assigned on or after February 16, 2021.

• All other changes may be implemented immediately; however, implementation is mandatory not later than February 16, 2021.

As mentioned, all interested parties in FHA transactions are strongly encouraged to familiarize themselves with the policy and program updates and clarifications as outlined in the PDF version of SF Handbook that published today. The online version of the SF Handbook is currently being updated and will be available soon.

Quick Links:
• Review the November 18, 2020 SF Handbook Transmittal at: http://portal.hud.gov/hudportal/HUD?src=/program_offices/administration/hudclips/handbooks/hsgh

• Access the SF Handbook online and/or portable document format (PDF) on the Housing Handbooks page on HUDClips at: http://portal.hud.gov/hudportal/HUD?src=/program_offices/administration/hudclips/handbooks/hsgh

• View the redline version of the SF Handbook at: https://www.hud.gov/program_offices/housing/sfh/handbook_4000-1

Resources
Contact the FHA Resource Center:
• Visit our online knowledge base to obtain answers to frequently asked questions 24/7 at:
www.hud.gov/answers.
• E-mail the FHA Resource Center at: answers@hud.gov. Emails and phone messages will be responded to during normal hours of operation, 8:00 AM to 8:00 PM (Eastern), Monday through Friday on all non-Federal holidays.
• Call 1-800-CALL-FHA (1-800-225-5342). Persons with hearing or speech impairments may reach this number by calling the Federal Relay Service at 1-800-877-8339.

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CEO

Alan Jaffa

Alan Jaffa is the Chief Executive Officer for Safeguard Properties, steering the company as the mortgage field services industry leader. He also serves on the board of advisors for SCG Partners, a middle-market private equity fund focused on diversifying and expanding Safeguard Properties’ business model into complimentary markets.

Alan joined Safeguard in 1995, learning the business from the ground up. He was promoted to Chief Operating Officer in 2002, and was named CEO in May 2010. His hands-on experience has given him unique insights as a leader to innovate, improve and strengthen Safeguard’s processes to assure that the company adheres to the highest standards of quality and customer service.

Under Alan’s leadership, Safeguard has grown significantly with strategies that have included new and expanded services, technology investments that deliver higher quality and greater efficiency to clients, and strategic acquisitions. He takes a team approach to process improvement, involving staff at all levels of the organization to address issues, brainstorm solutions, and identify new and better ways to serve clients.

In 2008, Alan was recognized by Crain’s Cleveland Business in its annual “40-Under-40” profile of young leaders. He also was named a NEO Ernst & Young Entrepreneur Of The Year® Award finalist in 2013.

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Esq., General Counsel and EVP

Linda Erkkila

Linda Erkkila is the General Counsel and Executive Vice President for Safeguard Properties, with oversight of legal, human resources, training, and compliance. Linda’s broad scope of oversight covers regulatory issues that impact Safeguard’s operations, risk mitigation, strategic planning, human resources and training initiatives, compliance, insurance, litigation and claims management, and counsel related to mergers, acquisition and joint ventures.

Linda assures that Safeguard’s strategic initiatives align with its resources, leverage opportunities across the company, and contemplate compliance mandates. She has practiced law for 25 years and her experience, both as outside and in-house counsel, covers a wide range of corporate matters, including regulatory disclosure, corporate governance compliance, risk assessment, compensation and benefits, litigation management, and mergers and acquisitions.

Linda earned her JD at Cleveland-Marshall College of Law. She holds a degree in economics from Miami University and an MBA. Linda was previously named as both a “Woman of Influence” by HousingWire and as a “Leading Lady” by MReport.

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COO

Michael Greenbaum

Michael Greenbaum is the Chief Operating Officer of Safeguard Properties, where he has played a pivotal role since joining the company in July 2010. Initially brought on as Vice President of REO, Mike’s exceptional leadership and strategic vision quickly propelled him to Vice President of Operations in 2013, and ultimately to COO in 2015. Over his 14-year tenure at Safeguard, Mike has been instrumental in driving change and fostering innovation within the Property Preservation sector, consistently delivering excellence and becoming a trusted partner to clients and investors.

A distinguished graduate of the United States Military Academy at West Point, Mike earned a degree in Quantitative Economics. Following his graduation, he served in the U.S. Army’s Ordnance Branch, where he specialized in supply chain management. Before his tenure at Safeguard, Mike honed his expertise by managing global supply chains for 13 years, leveraging his military and civilian experience to lead with precision and efficacy.

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CFO

Joe Iafigliola

Joe Iafigliola is the Chief Financial Officer for Safeguard Properties. Joe is responsible for the Control, Quality Assurance, Business Development, Marketing, Accounting, and Information Security departments. At the core of his responsibilities is the drive to ensure that Safeguard’s focus remains rooted in Customer Service = Resolution. Through his executive leadership role, he actively supports SGPNOW.com, an on-demand service geared towards real estate and property management professionals as well as individual home owners in need of inspection and property preservation services. Joe is also an integral force behind Compliance Connections, a branch of Safeguard Properties that allows code enforcement professionals to report violations at properties that can then be addressed by the Safeguard vendor network. Compliance Connections also researches and shares vacant property ordinance information with Safeguard clients.

Joe has an MBA from The Weatherhead School of Management at Case Western Reserve University, is a Certified Management Accountant (CMA), and holds a bachelor’s degree from The Ohio State University’s Honors Accounting program.

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Business Development

Carrie Tackett

Business Development Safeguard Properties