Open Recommendations
Recommendation Number | Significant Recommendation | Recommended Questioned Costs | Recommended Funds for Better Use | Additional Details | |
---|---|---|---|---|---|
2017-LA-0003-001-A | No | $0 | $0 | ||
Reconsider HUD's position on questioned borrower-financed downpayment assistance programs, including an analysis of the financial impact to FHA borrowers, risk to the FHA program, and whether current statute prohibits borrower-financed downpayment assistance programs as they are currently structured. | |||||
2017-LA-0003-001-C | No | $0 | $0 | ||
Develop specific requirements and guidance for lenders to review HFA downpayment assistance programs (for example, interest rates, fees, borrower certifications, lender reviews, impact to borrower, related agreements, etc.). Requirements and guidance should include evaluating the structure of downpayment assistance programs, including whether the programs' structure and funding mechanisms comply with all HUD requirements and guidelines. | |||||
2017-LA-0003-001-D | No | $0 | $0 | ||
Require lenders to obtain a borrower certification that details their participation in an HFA downpayment assistance program, including relevant details of the specific program (for example, impact on interest rate, mortgage payments, fees, equity, acknowledgement of other less costly loan products, etc.). | |||||
2017-LA-0003-001-E | No | $0 | $0 | ||
Ensure that lenders enter accurate and missing downpayment assistance gift data into FHA Connection when identified by HUD. | |||||
2017-LA-0003-001-F | No | $0 | $0 | ||
Implement new data fields where lenders would be required to enter specific downpayment assistance information (for example, name of the source, name of assistance program, name of government entity or HFA, etc.) to allow for auditability and for HUD to generate reports and perform risk assessments. | |||||
2017-LA-0003-001-G | No | $0 | $0 | ||
Review fees identified in this report that were charged as part of borrower-financed downpayment assistance programs and determine whether they are reasonable or necessary. HUD should immediately notify lenders to discontinue charging any fees that are determined to be unreasonable and unnecessary. | |||||
2017-LA-0003-001-H | No | $0 | $0 | ||
Require any participating lender to reimburse borrowers that received an FHA loan with borrower-financed downpayment assistance for any fees that were determined to be unreasonable and unnecessary. |