Develop and implement written policies and procedures regarding the designation of legal representation for applicants.

Research, develop, and implement policies and procedures to reduce the number of refunds that have remained unclaimed for an extended period, including consideration of a statute of limitations.

Develop and implement written policies and procedures (1) for locating homeowners who have unpaid refunds (for both existing and new refunds), (2) to establish a standard timeframe for mailing refund applications to homeowners after they are requested, and (3) to establish requirements for verifying the termination date based on supporting documents provided by homeowners.

Develop and implement written policies and procedures and controls for the FHA refund process to address the deficiencies identified in the audit report. These should include (1) controls to ensure that the website for the public listing of all unpaid refunds is complete, (2) controls to ensure that refund applications are sent only to the homeowners who requested them, (3) controls to ensure that refund applications are sent to all homeowners on the loan after loan termination, and (4) a formal monitoring framework for tracking the status of refunds.

Provide additional guidance to the servicers so they will limit their communication and collection efforts for the borrowers in forbearance.

Ensure that the issues found during our audit are incorporated into QAD’s servicing monitoring reviews.

Review the 21 loans with improperly administered forbearance to ensure that the borrowers were remedied by the servicers, if possible, and ensure that these servicers updated their forbearance procedures to prevent future noncompliance.

Ensure that this information is distributed to delinquent borrowers so it can benefit the greatest number of borrowers to put $5.43 billion to better use by avoiding potential future losses on 112,160 loans.

Develop a standardized brochure or informational pamphlet that would inform delinquent borrowers of their right to a forbearance under the CARES Act; and

Perform data analysis of FHA’s portfolio to identify borrowers who are delinquent and did not fully benefit from the COVID-19 forbearance, including those in bankruptcy;