source:
  type: regulation
  id: hud-ml-2023-11
  authority: "HUD Mortgagee Letter 2023-11 — Update to ML 2023-03 Regarding Loss Mitigation Options for Non-Borrowers Who Acquired Title through an Exempted Transfer"
  description: 'HUD ML 2023-11 reinstates FHA-HAMP Loss Mitigation for Mortgagees to review

    Non-Borrowers Who Acquired Title through an Exempted Transfer

    (III.A.2.j.ii(A)(4)(b)) and are in Default or Imminent Default, while

    leaving all other Borrowers under the COVID-19 Recovery Home Retention

    Options through October 30, 2024.

    '
obligations:
- id: hud-ml-2023-11-implementation-deadline
  canonical_id: hud-ml-2023-11-implementation-deadline
  section: "HUD ML 2023-11 — Effective Date"
  description: '[LENDER] may implement the provisions of HUD ML 2023-11 (reinstating

    FHA-HAMP for Non-Borrowers Who Acquired Title through an Exempted

    Transfer) immediately but must implement them no later than July 21, 2023.

    '
  type: do
  audit_question: Can [LENDER] demonstrate that the ML 2023-11 provisions reinstating FHA-HAMP review for Non-Borrowers Who Acquired Title through an Exempted Transfer were implemented in its loss-mitigation operations no later than July 21, 2023?
  workflow_phase: servicing
  owner_role: default_servicing_analyst
  secondary_owner_role: compliance_officer
  cadence: continuous
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hud-ml
  - fha
  - servicing
  - loss-mitigation
  - fha-hamp
  - effective-date
  - promoted
  primary_source:
    tier: 1
    authority: "HUD ML 2023-11 — Effective Date"
    source_class: hud-ml-pdf
    source_url: https://www.hud.gov/sites/dfiles/OCHCO/documents/2023-11hsgml.pdf
    snapshot_id: 236d0f2670b6db15
    fetched_at: '2026-05-22T19:57:44Z'
    content_hash: sha256:93cebe6403477fd20176e0ea63c4e4b02184158e26ca827128685d59ed377a96
    paragraph_quote: "The provisions of this ML may be implemented immediately but must be \nimplemented no later than July 21, 2023."
    drafter_attestation: 'Copied verbatim from snapshot 236d0f2670b6db15 (content.txt) at

      2026-05-22T20:00Z. Substring is the Effective Date trigger of

      ML 2023-11.

      '
  promoted_at: '2026-05-22T20:56:17+00:00'
  promoted_from: hud-ml-2023-11-roundb-v1.yaml
  program_review: Does the program account for the implementation deadline — adopting the ML 2023-11 FHA-HAMP-reinstatement-for-exempted-transfer-Non-Borrowers provisions no later than July 21, 2023?
  file_review: Review the loss-mit procedure version history; confirm the ML 2023-11 provisions were operational by July 21, 2023.
  judgment: false
- id: hud-ml-2023-11-non-borrower-exempted-transfer-ineligible-recovery
  canonical_id: hud-ml-2023-11-non-borrower-exempted-transfer-ineligible-recovery
  section: "HUD ML 2023-11 — Non-Borrowers Who Acquired Title through an Exempted Transfer Not Eligible for COVID-19 Recovery Options (III.A.2.o.iii(B))"
  description: 'Non-Borrowers Who Acquired Title through an Exempted Transfer

    (III.A.2.j.ii(A)(4)(b)) are not eligible for the COVID-19 Recovery Options

    and [LENDER] must instead evaluate them for FHA''s standard Loss Mitigation

    Options (III.A.2.j), including FHA-HAMP.

    '
  type: do
  audit_question: For every Non-Borrower Who Acquired Title through an Exempted Transfer evaluated for loss mitigation on or after July 21, 2023, can [LENDER] evidence that the Non-Borrower was evaluated for FHA's standard Loss Mitigation Options (III.A.2.j) including FHA-HAMP rather than for the COVID-19 Recovery Options?
  workflow_phase: servicing
  owner_role: default_servicing_analyst
  secondary_owner_role: compliance_officer
  cadence: per-loss-mitigation-evaluation
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hud-ml
  - fha
  - servicing
  - loss-mitigation
  - fha-hamp
  - exempted-transfer
  - promoted
  primary_source:
    tier: 1
    authority: "HUD ML 2023-11 — III.A.2.o.iii(B)"
    source_class: hud-ml-pdf
    source_url: https://www.hud.gov/sites/dfiles/OCHCO/documents/2023-11hsgml.pdf
    snapshot_id: 236d0f2670b6db15
    fetched_at: '2026-05-22T19:57:44Z'
    content_hash: sha256:93cebe6403477fd20176e0ea63c4e4b02184158e26ca827128685d59ed377a96
    paragraph_quote: "Non-Borrowers Who Acquired Title through an Exempted Transfer \n(III.A.2.j.ii(A)(4)(b)) are not eligible for the COVID-19 Recovery Options \nand must be evaluated for FHA’s standard Loss Mitigation Options \n(III.A.2.j)."
    drafter_attestation: 'Copied verbatim from snapshot 236d0f2670b6db15 (content.txt) at

      2026-05-22T20:00Z. Substring is the Non-Borrower exempted-transfer

      eligibility carve-out incorporated into Handbook 4000.1

      III.A.2.o.iii(B) by ML 2023-11.

      '
  promoted_at: '2026-05-22T20:56:17+00:00'
  promoted_from: hud-ml-2023-11-roundb-v1.yaml
  program_review: Does the program account for the exempted-transfer carve-out — evaluating Non-Borrowers Who Acquired Title through an Exempted Transfer under FHA's standard Loss Mitigation Options (including FHA-HAMP), not the COVID-19 Recovery Options?
  file_review: Spot-check exempted-transfer-Non-Borrower loss-mit files (on/after July 21, 2023); confirm evaluation under standard Loss Mitigation Options including FHA-HAMP rather than COVID-19 Recovery Options.
  judgment: false
_promotion_history:
- promoted_at: '2026-05-22T20:56:17+00:00'
  candidate_path: obligations\_remediation\_round_b_drafts\hud-ml-2023-11-roundb-v1.yaml
  candidates_promoted: 2
  candidates_skipped_existing: 0
