source:
  type: regulation
  id: hud-ml-2025-12
  authority: HUD Mortgagee Letter 2025-12
  description: 'HUD Mortgagee Letter 2025-12. See obligation entries for operative

    requirements and verbatim primary-source citations.

    '
obligations:
- id: hud-ml-2025-12-loss-mit-eligibility-verification
  canonical_id: hud-ml-2025-12-loss-mit-eligibility-verification
  section: "HUD ML 2025-12 — Eligibility to Participate in HUD Programs (III.A.2.h.iii(A))"
  description: 'Before offering any FHA Loss Mitigation Option, [LENDER] must verify

    that the Borrowers are eligible to participate in HUD''s Loss Mitigation

    Program. To be eligible, the Borrower may not own other FHA-insured

    real estate (except under the stated exceptions); has not been the

    Borrower (except through inheritance or as co-signer only) on prior

    loans on which an FHA claim has been paid within the past three years;

    must not be debarred, suspended, or subject to a HUD LDP for the

    relevant home-retention options; and may not have unresolved delinquent

    Federal Debt for Partial Claim / Combination / Payment Supplement

    options.

    '
  type: do
  audit_question: For every FHA-insured Mortgage in Default for which [LENDER] offered a Loss Mitigation Option, can [LENDER] evidence the Borrower-eligibility verification (no other FHA-insured real estate beyond stated exceptions; no FHA-claim-paid prior loan in past 3 years; no debarment/suspension/LDP for relevant options; no unresolved delinquent Federal Debt for Partial Claim / Combination / Payment Supplement)?
  workflow_phase: servicing
  owner_role: loss_mitigation_specialist
  secondary_owner_role: default_servicing_analyst
  cadence: per-defaulted-loan
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hud-ml
  - fha
  - servicing
  - loss-mitigation
  - borrower-eligibility
  - promoted
  primary_source:
    tier: 1
    authority: "HUD ML 2025-12 — III.A.2.h.iii(A)"
    source_class: hud-ml-pdf
    source_url: https://www.hud.gov/sites/dfiles/OCHCO/documents/2025-12hsgml.pdf
    snapshot_id: 31bf9e2b0c437c70
    fetched_at: '2026-05-22T11:23:07Z'
    content_hash: sha256:6376f97e582a3d32727a36ce337f620c5dcb731d0c6f561b66a893c5d00dff48
    paragraph_quote: "The Mortgagee must verify that the Borrowers are eligible to participate in HUD’s \nLoss Mitigation Program."
    drafter_attestation: 'Copied verbatim from snapshot 31bf9e2b0c437c70 (content.txt) at

      2026-05-22T20:44Z. Substring is the (A) Eligibility to Participate

      in HUD Programs operative requirement from ML 2025-12; the four

      eligibility prongs are paraphrased in description.

      '
  promoted_at: '2026-05-22T20:17:43+00:00'
  promoted_from: hud-ml-2025-12-roundb-v1.yaml
  program_review: Does the program account for the loss-mit eligibility conditions before any option is offered — no other FHA-insured real estate beyond stated exceptions; no FHA-claim-paid prior loan (except inheritance/co-signer-only) in 3 years; no debarment/suspension/LDP for the relevant home-retention option; no unresolved delinquent Federal Debt for Partial Claim/Combination/Payment Supplement?
  file_review: Spot-check ML-2025-12 loss-mit files; confirm documented Borrower-eligibility verification before the option was offered.
  judgment: false
  feeds:
  - hud-ml-2025-12-loss-mit-90-day-evaluation
- id: hud-ml-2025-12-loss-mit-90-day-evaluation
  canonical_id: hud-ml-2025-12-loss-mit-90-day-evaluation
  section: "HUD ML 2025-12 — Loss Mitigation Program 90-Day Review (III.A.2.h.iii(B))"
  description: 'For each FHA-insured forward Mortgage in Default, [LENDER] must complete

    an evaluation of the Defaulted Mortgage for appropriate Loss Mitigation

    Options before four monthly installments are due and unpaid, and send

    a written Notice to Borrower with the determination of eligibility.

    '
  type: do
  audit_question: For every FHA-insured forward Mortgage in Default, can [LENDER] evidence completion of the loss-mit evaluation before four monthly installments became due and unpaid, and delivery of the written Notice to Borrower with the determination of eligibility?
  workflow_phase: servicing
  owner_role: loss_mitigation_specialist
  secondary_owner_role: default_servicing_analyst
  cadence: per-defaulted-loan
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hud-ml
  - fha
  - servicing
  - loss-mitigation
  - 90-day-review
  - promoted
  primary_source:
    tier: 1
    authority: "HUD ML 2025-12 — III.A.2.h.iii(B) 90-Day Review"
    source_class: hud-ml-pdf
    source_url: https://www.hud.gov/sites/dfiles/OCHCO/documents/2025-12hsgml.pdf
    snapshot_id: 31bf9e2b0c437c70
    fetched_at: '2026-05-22T11:23:07Z'
    content_hash: sha256:6376f97e582a3d32727a36ce337f620c5dcb731d0c6f561b66a893c5d00dff48
    paragraph_quote: "A Mortgagee is required to complete an evaluation of a Defaulted Mortgage for \nappropriate Loss Mitigation Options before four monthly installments are due and \nunpaid and send a written Notice to Borrower with the determination of eligibility."
    drafter_attestation: 'Copied verbatim from snapshot 31bf9e2b0c437c70 (content.txt) at

      2026-05-22T20:44Z. Substring is the (B) 90-Day Review operative

      standard incorporated into Handbook 4000.1 III.A.2.h.iii(B) by ML

      2025-12.

      '
  promoted_at: '2026-05-22T20:17:43+00:00'
  promoted_from: hud-ml-2025-12-roundb-v1.yaml
  program_review: Do the P&Ps ensure each defaulted forward Mortgage is evaluated for loss-mit options before four monthly installments are due and unpaid, with a written Notice to Borrower stating the eligibility determination?
  file_review: Pull defaulted forward-Mortgage files; confirm the evaluation completed before the 4th unpaid installment and the written Notice to Borrower with the determination.
  judgment: false
  feeds:
  - hud-ml-2025-12-permanent-home-retention-documents-15-days
- id: hud-ml-2025-12-permanent-home-retention-documents-15-days
  canonical_id: hud-ml-2025-12-permanent-home-retention-documents-15-days
  section: "HUD ML 2025-12 — Execution of Permanent Home Retention Option Documents (III.A.2.i.iii(D))"
  description: 'For each Borrower who successfully completes a Trial Payment Plan (TPP)

    on a Permanent Home Retention Option (Standalone Partial Claim,

    Standalone Loan Modification, Combination Loan Modification and Partial

    Claim, or Payment Supplement), [LENDER] must send the Permanent Home

    Retention documents to the Borrower within 15 Days from the successful

    completion of the TPP.

    '
  type: do
  audit_question: For every Borrower who successfully completed a TPP on a Permanent Home Retention Option under the ML 2025-12 framework, can [LENDER] evidence delivery of the Permanent Home Retention documents to the Borrower within 15 Days of TPP completion?
  workflow_phase: servicing
  owner_role: loss_mitigation_specialist
  secondary_owner_role: default_servicing_analyst
  cadence: per-loss-mit-workout
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hud-ml
  - fha
  - servicing
  - loss-mitigation
  - permanent-home-retention
  - tpp
  - promoted
  primary_source:
    tier: 1
    authority: "HUD ML 2025-12 — III.A.2.i.iii(D)"
    source_class: hud-ml-pdf
    source_url: https://www.hud.gov/sites/dfiles/OCHCO/documents/2025-12hsgml.pdf
    snapshot_id: 31bf9e2b0c437c70
    fetched_at: '2026-05-22T11:23:07Z'
    content_hash: sha256:6376f97e582a3d32727a36ce337f620c5dcb731d0c6f561b66a893c5d00dff48
    paragraph_quote: "The Mortgagee must send the Permanent Home Retention documents to the Borrower \nwithin 15 Days from the successful completion of a TPP."
    drafter_attestation: 'Copied verbatim from snapshot 31bf9e2b0c437c70 (content.txt) at

      2026-05-22T20:44Z. Substring is the (D) Execution of Permanent Home

      Retention Option Documents 15-Day standard added by ML 2025-12.

      '
  promoted_at: '2026-05-22T20:17:43+00:00'
  promoted_from: hud-ml-2025-12-roundb-v1.yaml
  program_review: Do the P&Ps ensure Permanent Home Retention documents are sent to the Borrower within 15 Days of successful TPP completion (Standalone Partial Claim, Standalone Loan Modification, Combination, or Payment Supplement)?
  file_review: Pull successful-TPP files; confirm Permanent Home Retention documents were sent within 15 Days of TPP completion.
  judgment: false
_promotion_history:
- promoted_at: '2026-05-22T20:17:43+00:00'
  candidate_path: obligations\_remediation\_round_b_drafts\hud-ml-2025-12-roundb-v1.yaml
  candidates_promoted: 3
  candidates_skipped_existing: 0
