Spring 2025 Unified Agenda of Regulatory and Deregulatory Actions published
The Spring 2025 Unified Agenda of Regulatory and Deregulatory Actions was published on September 4, 2025. Padgett Law Group is providing an analysis...
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The U.S. Department of Housing and Urban Development's Office of Inspector General released its Annual Work Plan for Fiscal Year (FY) 2026 (covering October 1, 2025, through September 30, 2026) on February 4, 2026.
Background behind the Plan:
“The OIG conducts audits and evaluations to prevent and detect fraud and abuse and promote the economy, efficiency, and effectiveness of HUD’s programs and operations. The AWP highlights audits and evaluations the OIG will initiate in FY 2026, as well as ongoing projects that continue from prior years. All of the projects span HUD programs and operations and take into account HUD’s Top Management and Performance Challenges we identified through our past oversight work, HUD’s priorities as described in its Annual Performance Plan for FY 2026, and recommendations for action we issued to HUD that remain open. The projects also encompass mandatory audits and evaluations required by laws or regulations.”
Key Plan Components Relevant to Mortgage Servicing:
Highlighted Planned Projects:
FHA Single Family Claims on Indemnified Loans Audit to determine whether servicers may be filing claims on indemnified loans without repaying HUD;
Delayed Dispositions on HUD Real Estate Owned and Claims Without Conveyance of Title Audit to assess lenders’ timeliness in executing foreclosure requirements and costs to HUD, if any, associated with the delays;
Equity Skimming Individual audits of HUD program participants’ oversight of and controls directed at detecting and preventing equity skimming;
HUD Program Offices’ and HUD Participants’ Fraud Risk Management Practices Individual audits of HUD program offices’ and HUD participants’, including grantees, lenders, and Public Housing Agencies (PHA), fraud risk management practices such as control activities to prevent, detect, and respond to fraud while administering HUD program funds;
FHA Single-Family Early Payment Default Origination Monitoring Audit of lenders’ origination practices to assess their quality controls and the controls’ impact on early payment defaults;
Lender Servicing Audit of lenders’ servicing practices to assess whether they are using all available tools to assist borrowers with loss mitigation
Assessment of Opportunities to Streamline FHA Processes Audit of FHA processes and requirements to assess whether opportunities exist to reduce or eliminate burdensome or unnecessary barriers;
Cash-Out Refinances Audit to assess whether properties experience negative impacts after borrowers participate in cash-out refinance transactions
Duplicate Property Inspections Evaluation to assess the extent to which HUD monitors, detects, and takes steps to prevent duplicate inspections of properties that are also inspected by the U.S. Department of Agriculture and the U.S. Department of Veterans Affairs
Projects of Note (Currently Underway):
Audit of NSC Partial Claims Tracking and Collection Audit of the National Servicing Center’s (NSC) partial claims tracking and collection to determine whether the NSC serviced all due and payable partial claims in accordance with HUD rules and regulations:
FHA-Insured Single-Family Loans Issued to Deceased and Incarcerated Individuals Evaluation to determine whether the approval process for FHA-insured single-family loans resulted in loans to deceased or incarcerated borrowers;
HUD, Ginnie Mae, and FHA Inactive Obligations Audit of HUD’s, Ginnie Mae’s, and FHA’s inactive obligations to determine if the obligations are still needed for the purposes intended and, if not, assess gaps in controls that prevented earlier deobligation;
Fraud Risk Inventories for the Capital Fund, Disaster Recovery, and Single-Family Housing Programs Audit of HUD programs to identify and develop inventories of fraud risks related to funds that HUD received for its Capital Fund, Disaster Recovery, and Single-Family Housing programs
Link to the Plan:
The Spring 2025 Unified Agenda of Regulatory and Deregulatory Actions was published on September 4, 2025. Padgett Law Group is providing an analysis...
Overview:
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