source:
  type: regulation
  id: hud-ml-2024-15
  authority: HUD Mortgagee Letter 2024-15
  description: 'HUD Mortgagee Letter 2024-15. See obligation entries for operative

    requirements and verbatim primary-source citations.

    '
obligations:
- id: hud-ml-2024-15-forward-mortgage-moratorium
  canonical_id: hud-ml-2024-15-forward-mortgage-moratorium
  section: "HUD ML 2024-15 — FHA-Insured Forward Mortgages: Extension of Foreclosure Moratorium for Maui County, Hawaii"
  description: 'For FHA-insured Single Family forward mortgages secured by Properties

    located in Maui County, Hawaii, [LENDER] must observe the extended

    foreclosure moratorium through January 1, 2025, applying both to the

    initiation of new foreclosures and to the completion of foreclosures

    already in process; first-legal-action deadlines and Reasonable Diligence

    Time Frames are extended by 180 Days from January 1, 2025.

    '
  type: dont
  audit_question: For every FHA-insured forward Mortgage with subject Property in Maui County, Hawaii, can [LENDER] evidence that no foreclosure initiation or completion occurred during the moratorium period (through January 1, 2025) and that first-legal-action / Reasonable Diligence Time Frame deadlines were extended by 180 Days from January 1, 2025?
  workflow_phase: servicing
  owner_role: default_servicing_analyst
  secondary_owner_role: compliance_officer
  cadence: per-affected-loan
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hud-ml
  - fha
  - servicing
  - foreclosure-moratorium
  - disaster-relief
  - promoted
  primary_source:
    tier: 1
    authority: "HUD ML 2024-15 — FHA-Insured Forward Mortgages"
    source_class: hud-ml-pdf
    source_url: https://www.hud.gov/sites/dfiles/OCHCO/documents/2024-15hsgml.pdf
    snapshot_id: c561f8c5edb51360
    fetched_at: '2026-05-22T19:54:47Z'
    content_hash: sha256:9f6d0ccaa4ca6817041e072089e1c5ed1173c8d6b8834aa970f930e7772aef7b
    paragraph_quote: "Properties located in Maui County, Hawaii and secured by FHA-insured \nSingle Family forward mortgages are subject to an extended foreclosure \nmoratorium through January 1, 2025. The moratorium applies to the \ninitiation of foreclosures and to the completion of foreclosures in process. \nDeadlines for the first legal action and Reasonable Diligence Time Frame \nare extended by 180 Days from January 1, 2025."
    drafter_attestation: 'Copied verbatim from snapshot c561f8c5edb51360 (content.txt) at

      2026-05-22T20:12Z. Substring is the forward-mortgage moratorium

      operative paragraph of ML 2024-15.

      '
  promoted_at: '2026-05-22T20:17:33+00:00'
  promoted_from: hud-ml-2024-15-roundb-v1.yaml
  program_review: Does the program account for the extended Maui-County moratorium — halting foreclosure initiation and completion on affected forward mortgages through January 1, 2025 and extending first-legal-action / Reasonable Diligence deadlines by 180 Days from that date?
  file_review: Spot-check Maui-County forward-mortgage files; confirm no foreclosure initiation/completion through January 1, 2025 and the 180-Day deadline extensions.
  judgment: false
- id: hud-ml-2024-15-hecm-moratorium
  canonical_id: hud-ml-2024-15-hecm-moratorium
  section: "HUD ML 2024-15 — HECM Foreclosure Moratorium for Maui County, Hawaii"
  description: "For FHA-insured HECMs secured by Properties located in Maui County,\nHawaii, [LENDER] must observe a moratorium on foreclosures through\nJanuary 1, 2025 — but only where the HECM is Due and Payable for reasons\nother than the death of the last remaining Borrower and is not subject\nto a Deferral Period — applying to both the initiation of foreclosures\nand foreclosures already in process.\n"
  type: dont
  audit_question: For every FHA-insured HECM with subject Property in Maui County, Hawaii that became Due and Payable for reasons other than death of the last remaining Borrower (and was not subject to a Deferral Period), can [LENDER] evidence that no foreclosure initiation or completion occurred during the moratorium period (through January 1, 2025)?
  workflow_phase: servicing
  owner_role: default_servicing_analyst
  secondary_owner_role: compliance_officer
  cadence: per-affected-loan
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hud-ml
  - fha
  - hecm
  - servicing
  - foreclosure-moratorium
  - disaster-relief
  - promoted
  primary_source:
    tier: 1
    authority: "HUD ML 2024-15 — HECM Foreclosure Moratorium"
    source_class: hud-ml-pdf
    source_url: https://www.hud.gov/sites/dfiles/OCHCO/documents/2024-15hsgml.pdf
    snapshot_id: c561f8c5edb51360
    fetched_at: '2026-05-22T19:54:47Z'
    content_hash: sha256:9f6d0ccaa4ca6817041e072089e1c5ed1173c8d6b8834aa970f930e7772aef7b
    paragraph_quote: "The Mortgagee must observe a moratorium on foreclosures of FHA-insured \nHECMs secured by Properties located in Maui County, Hawaii through \nJanuary 1, 2025."
    drafter_attestation: 'Copied verbatim from snapshot c561f8c5edb51360 (content.txt) at

      2026-05-22T20:12Z. Substring is the HECM moratorium standard

      of ML 2024-15; the applicability conditions (Due and Payable reason,

      Deferral Period exclusion) are enumerated in the description.

      '
  promoted_at: '2026-05-22T20:17:33+00:00'
  promoted_from: hud-ml-2024-15-roundb-v1.yaml
  program_review: Does the program account for the extended Maui-County HECM moratorium condition — halting foreclosures through January 1, 2025 only where the HECM is Due and Payable for reasons other than death of the last remaining Borrower and not in a Deferral Period?
  file_review: Spot-check qualifying Maui-County HECM files; confirm no foreclosure initiation/completion through January 1, 2025.
  judgment: false
_promotion_history:
- promoted_at: '2026-05-22T20:17:33+00:00'
  candidate_path: obligations\_remediation\_round_b_drafts\hud-ml-2024-15-roundb-v1.yaml
  candidates_promoted: 2
  candidates_skipped_existing: 0
