FHA Borrowers Did Not Always Properly Receive COVID-19 Forbearances From Their Loan Servicers

The U.S. Department of Housing and Urban Development (HUD), Office of Inspector General (OIG), completed an audit to determine whether FHA-insured borrowers properly received the COVID-19-related forbearance.  The Coronavirus Aid, Relief, and Economic Security Act (CARES Act), signed into law on March 27, 2020, provided a mortgage payment forbearance option for all borrowers who suffered a financial hardship due to the COVID-19 national emergency. We found that at least one-third of the nearly 335,000 borrowers who were delinquent on their FHA-insured loans and not on forbearance in November 2020, were either not informed or misinformed about the COVID-19 forbearance.  As a result, these borrowers experiencing a hardship due to COVID-19 did not benefit from the COVID-19 forbearance.  We also found that servicers improperly administered the forbearance for at least one-sixth of the nearly 815,000 borrowers on forbearance plans in November 2020.  Servicers also performed excessive communication and collection efforts for borrowers who were already in forbearance. As a result, these borrowers experienced additional burdens from improperly administered forbearance. We recommend that FHA identify borrowers who are delinquent and did not fully benefit from the COVID-19 forbearance and ensure that information about the CARES Act and COVID-19 forbearance is distributed to these borrowers. We also recommend that FHA review the 21 loans in our statistical sample with improperly administered forbearance to ensure that the borrowers were assisted by the servicers, if possible, and ensure that these servicers updated their forbearance procedures to prevent future noncompliance; ensure that the issues found during our audit are incorporated into servicing monitoring reviews to deter future noncompliance and prevent potential loss to the FHA fund; and provide additional guidance to the servicers so that they limit their communication and collection efforts for the borrowers in forbearance.