30 Day Extension for HUD Submissions Due March 31, 2020

The U.S. Department of Housing and Urban Development (HUD) has issued audit submission deadline extensions and other waivers for audits of certain for-profit entities under the HUD Consolidated Audit Guide.

Many financial institutions who conduct Title I and Title II lending with be granted an automatic 30- day extension to submit their audited financials and other financial data through LEAP (Lender Electronic Assessment Portal).  See below for information specific to the extension.

Lenders: HUD’s Federal Housing Administration (FHA), Office of Single-Family Housing, also updated its COVID-19 Questions and Answers on March 13, 2020. One of the questions (Question 4) provides an extension for the audit submission deadline. It indicates that audited financial statements due to HUD on March 31, 2020, will now have an extension to April 30, 2020. It also encourages lenders that have the ability to submit their audited financial statements before April 30th to do so. We have verified with FHA staff that even though Question 4 only refers an extension of the audited financial statements, the extension applies to everything associated with the annual recertification process and thus includes the related lender compliance audit and agreed-upon procedures engagement.

If you audit lenders subject to the FHA’s rules, you are encouraged to read the other Q&As provided and to make your clients aware of the document. Many of the questions address the status of various HUD activities surrounding the lending process at this time. There are also several questions that address how inspections and appraisals are to be carried out and a waiver is provided to the face-to face interview requirement under the FHA Default Servicing rules.

Finally, we also verified that the lender extension described above does not apply to entities that are audited under chapter 6 of the HUD Consolidated Audit Guide, Ginnie Mae Issuers of Mortgage-Backed Securities Audit Guidance. We have inquired about the status of any extensions to be provided for those entities and will communicate in a future GAQC Alert what we learn.

Please contact a Brady Martz financial institution team member with additional questions.  Our team is here to help. Thank you and stay safe!