Finding 1164795 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2025-12-15
Audit: 374600
Auditor: BRADY MARTZ

AI Summary

  • Core Issue: One borrower did not receive their escrow surplus within the required 30 days after loan payoff.
  • Impacted Requirements: The Agency must comply with federal regulations to return escrow surpluses promptly to avoid delays.
  • Recommended Follow-Up: Review and improve procedures for monitoring escrow surpluses post-loan payoff to prevent future delays.

Finding Text

AL 14.117 Federal Housing Commission Division Mortgage Insurance Criteria The Agency is required to return to the borrower any escrow surplus within 30 days of the loan payoff date. Condition Of the 25 loan payoffs tested, we noted one instance where the escrow surplus was not returned to the borrower within 30 days of the loan payoff. Cause The Agency updated loan tracking software in the current year. There was an issue with the ‘next due date’ on the payoff screen not updating once a payoff quote has been saved. Effect Borrowers are potentially not receiving escrow surpluses in a timely manner. Questioned Costs $0 Recommendation We recommend the Agency review its procedures to monitor any escrow surpluses that need to be returned after loans have been paid off. Views of Responsible Officials We acknowledge the finding that an escrow surplus related to a loan payoff was not fully released to the borrower within 30 days as required. The lapse occurred due to a system error that caused excess funds to be retained for PMI at payoff, as well as delays in reconciliation and manual processing workflows, and not due to intentional noncompliance. Management recognizes the importance of adhering to RESPA and internal policy requirements to ensure borrowers receive timely refunds and avoid compliance risk. Repeat Finding This is a new finding.

Corrective Action Plan

Corrective Action Plan: 1. System Remediation: Our servicing software payo􀆯 logic has been corrected to ensure no excess escrow mortgage insurance funds are held back at payo􀆯. Fix date: August 12, 2025 2. Sta􀆯 Training: Provide training to escrow and payo􀆯 sta􀆯 on the updated process and system changes, emphasizing regulatory requirements for escrow refund timeliness. 3. Monitoring: The existing control report used to identify escrow surpluses postpayo 􀆯 will now be run on a bi-monthly basis instead of monthly. 4. Accountability: The Servicing Coordinator will oversee corrective actions and provide periodic reporting to compliance and senior management. Target Completion Date: October 30, 2025 Responsible Party: Austin Ketterling, Servicing Coordinator

Categories

HUD Housing Programs Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1164794 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.117 MORTGAGE INSURANCE HOMES $172.22M
14.U01 GINNIE MAE - MORTGAGE INSURANCE - HOMES $118.30M
64.114 VETERANS HOUSING GUARANTEED AND INSURED LOANS $41.05M
14.149 RENT SUPPLEMENTS RENTAL HOUSING FOR LOWER INCOME FAMILIES $14.72M
64.U01 GINNIE MAE - VETERANS HOUSING GUARANTEED AND INSURED LOANS $9.71M
14.275 HOUSING TRUST FUND $6.99M
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $1.80M
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $515,683
14.856 LOWER INCOME HOUSING ASSISTANCE PROGRAM SECTION 8 MODERATE REHABILITATION $342,955
14.267 CONTINUUM OF CARE PROGRAM $100,633
14.169 HOUSING COUNSELING ASSISTANCE PROGRAM $32,384
14.228 COMMUNITY DEVELOPMENT BLOCK GRANTS/STATE'S PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII $6,056