At this point, the answer is “NO”. As you are probably aware, HUD is in the process of proposing some changes through the Federal Rulemaking Process. Currently, these changes are only PROPOSED, they have not been approved.
Following is the proposed changes summarized by the Affordable Housing Association of CPA’s, AHACPA:
Changes being Pursued by Rule Making Process:
1. Increasing the minimum net worth requirements by $1,000,000 for all non-supervised mortgagees, and
2. Mortgagees will assume responsibility for the Loan Correspondents (mortgage brokers) who they sponsor. In addition, Loan Correspondents will no longer receive independent FHA approval for origination eligibility.
If this proposal is approved, it appears that mortgage brokers will no longer be required to be approved by HUD to originate FHA mortgages. Remember that this change is only at the proposal stage. The above changes will need to be made through the rule making process. Brokers and auditors with pending financial statement or other compliance issues should continue to work to resolve these issues until notified by HUD that they are no longer required. At this stage, we do not have any estimate on the timing of a final rule. Further, other auditors have reported to us that many warehouse lenders are indicating that they will continue to require audits. Although, only hearsay evidence, audits may continue to be required at some level even if the Rule passes.
