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Bank of America Corporation, Foreclosure and Claims Process Review Charlotte, NC

As part of the Office of Inspector General’s (OIG) nationwide effort to review the foreclosure practices of the five largest Federal Housing Administration (FHA) mortgage servicers (Bank of America, Wells Fargo Bank, CitiMortgage, JP Morgan Chase, and Ally Financial, Incorporated) we reviewed Bank of America’s foreclosure and claims processes. In addition to this memorandum, OIG issued separate memorandums for each of the other four reviews.

Bank of America, Seattle, Washington, Needs to Improve Its Compliance with HUD Requirements

We reviewed Bank of America's (servicer) home equity conversion mortgage (HECM) servicing division located in Seattle, Washington. Bank of America is one of the largest lenders of HECM mortgages for properties located in the five southwest states in the U. S. Department of Housing and Urban Development's (HUD) Region VI jurisdiction.

Enterprise Home Ownership partners-Dallas, INC., Dallas, TX Achieved Program Objectives But Did Not Fully Comply With Certain Requirements

We audited the U. S. Department of Housing and Urban Development (HUD) Community Development Block Grant (CDBG), Supplemental II Disaster Recovery program funds, administered by the Texas Department of Housing and Community Affairs (TDHCA). Specifically, we wanted to determine whether TDHCA monitored its program management firm (the Firm) to ensure compliance with Federal and State regulations and to ensure costs reimbursed for the Housing Assistance Program (HAP) and the Sabine Pass Restoration Program (SPRP) were adequately supported.

Assurity Financial Services, LLC, Englewood, CO, Did Not Properly Underwrite a Selection of FHA Loans

We performed a review of 20 Federal Housing Administration (FHA) loans underwritten by Assurity Financial Services, LLC (Assurity). Our review objective was to determine whether Assurity underwrote the 20 loans in accordance with Federal Housing Administration (FHA) requirements. This review is part of Operation Watchdog, an Office of Inspector General (OIG) initiative to review the underwriting of 15 direct endorsement lenders at the suggestion of the FHA Commissioner.

HUD Did Not Have Adequate Internal Controls over Its FHA Appraiser Roster

We audited HUD's controls over the FHA appraiser roster in response to a single-family loan origination audit that had raised concerns about FHA appraisers and appraisals. We reviewed HUD's appraiser roster (roster) to determine whether HUD's controls over the roster were adequate to ensure that only qualified/eligible appraisers were placed on the roster and whether the oversight and maintenance of the roster were sufficient to ensure that only currently eligible appraisers remained on the roster.

The Los Angeles Multifamily Hub Did Not Properly Monitor Its Performance-Based Contract Administrator, Los Angeles LOMOD

We audited the Los Angeles Multifamily Hub's monitoring of its annual contributions contract with its performance-based contract administrator (contractor), Los Angeles LOMOD (LOMOD). Our overall audit objective was to determine whether the U.S. Department of Housing and Urban Development (HUD) appropriately monitored LOMOD with respect to the annual contributions contract. The Los Angeles Multifamily Hub did not properly monitor its contractor.

Naomi Gardens, Arcadia, CA, Did Not Comply With HUD Procurement and Waiting List Requirements

We audited the Naomi Gardens housing project (project) in response to a congressional request from Representative David Dreier of the 26th District of California. The request to review the project was based on a constituent’s complaint that alleged the possible misuse of U.S. Department of Housing and Urban Development (HUD) funds, including the award of work to the family members of project employees without seeking proposals from other companies. The constituent later added concerns over waiting list violations and families occupying multiple units.

Final Civil Action - HUD Real Estate-Owned Program Violations (Report Not Available to the Public)

We reviewed alleged violations of U.S. Department of Housing and Urban Development (HUD) real estate-owned (REO) owner-occupancy program requirements by the subject (name withheld for privacy reasons). We concluded that the subject failed to comply with the HUD REO program requirement that an individual who purchases a REO home during its initial offering period must be the owner-occupant of the purchased home for one full year.

Final Civil Action – Loan Origination Fraud on Federal Housing Administration Loans (Report Not Available to the Public)

We reviewed alleged violations of U.S. Department of Housing and Urban Development (HUD) Federal Housing Administration (FHA) loan origination requirements by the subject. We concluded that the subject placed fraudulent information and documents in mortgage loan applications for Government-insured home loans. The Department of Justice filed a complaint under the Financial Institutions Reform, Recovery, and Enforcement Act; and in December 2011 reached a settlement with the subject.

Final Civil Action – Loan Origination Fraud on Federal Housing Administration Loans (Report Not Available to the Public)

We reviewed alleged violations of U.S. Department of Housing and Urban Development (HUD) Federal Housing Administration (FHA) loan origination requirements by the subject. We concluded that the subject created and altered documents used in mortgage loan applications for Government-insured home loans. The Department of Justice filed a complaint under the Financial Institutions Reform, Recovery, and Enforcement Act; and in December 2011 reached a settlement with the subject.