source:
  type: regulation
  id: hud-ml-2024-25
  authority: HUD Mortgagee Letter 2024-25
  description: 'HUD Mortgagee Letter 2024-25. See obligation entries for operative

    requirements and verbatim primary-source citations.

    '
obligations:
- id: hud-ml-2024-25-forward-mortgage-moratorium
  canonical_id: hud-ml-2024-25-forward-mortgage-moratorium
  section: "HUD ML 2024-25 — FHA-Insured Forward Mortgages: Extension of Foreclosure Moratorium for Hurricanes Helene and Milton"
  description: 'For FHA-insured Single Family forward mortgages secured by Properties

    located in FEMA-designated disaster areas for Hurricanes Helene and

    Milton (across Florida, Georgia, North Carolina, South Carolina,

    Tennessee, and Virginia per the FEMA Declarations enumerated in ML

    2024-25), [LENDER] must observe a moratorium on foreclosure through

    April 11, 2025, applying both to the initiation of new foreclosures and

    to the completion of foreclosures already in process.

    '
  type: dont
  audit_question: For every FHA-insured forward Mortgage with subject Property in any of the FEMA-Declaration areas listed in ML 2024-25 (Hurricanes Helene and Milton across FL, GA, NC, SC, TN, VA), can [LENDER] evidence that no foreclosure initiation or completion occurred during the moratorium period (through April 11, 2025) and that first-legal-action / Reasonable Diligence Time Frame deadlines were extended by 180 Days from April 11, 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
  - helene
  - milton
  - promoted
  primary_source:
    tier: 1
    authority: "HUD ML 2024-25 — FHA-Insured Forward Mortgages"
    source_class: hud-ml-pdf
    source_url: https://www.hud.gov/sites/dfiles/OCHCO/documents/2024-25hsgml.pdf
    snapshot_id: b3293b7ff0dc948d
    fetched_at: '2026-05-22T19:54:56Z'
    content_hash: sha256:43b30ab78e08f21c57c734f18ae46a67f04bd9e77d74ac921bf76d96a9ca3fba
    paragraph_quote: "Properties secured by FHA-insured Single Family forward mortgages are \nsubject to a moratorium on foreclosure through April 11, 2025. The \nmoratorium applies to the initiation of foreclosures and to the completion of \nforeclosures in process for the following FEMA Declarations for Hurricanes \nHelene"
    drafter_attestation: 'Copied verbatim from snapshot b3293b7ff0dc948d (content.txt) at

      2026-05-22T20:25Z. Substring is the forward-mortgage moratorium

      operative paragraph of ML 2024-25 (FEMA-Declaration table follows the

      quoted span).

      '
  promoted_at: '2026-05-22T20:17:42+00:00'
  promoted_from: hud-ml-2024-25-roundb-v1.yaml
  program_review: Does the program account for the Helene/Milton disaster moratorium — halting foreclosure initiation and completion on affected forward mortgages in the enumerated FEMA-Declaration areas (FL, GA, NC, SC, TN, VA) through April 11, 2025, with 180-Day deadline extensions from that date?
  file_review: Spot-check forward-mortgage files in the listed FEMA-Declaration areas; confirm no foreclosure initiation/completion through April 11, 2025 and the 180-Day deadline extensions.
  judgment: false
- id: hud-ml-2024-25-hecm-moratorium
  canonical_id: hud-ml-2024-25-hecm-moratorium
  section: "HUD ML 2024-25 — HECM Foreclosure Moratorium for Hurricanes Helene and Milton"
  description: "For FHA-insured HECMs secured by Properties located in FEMA-designated\ndisaster areas for Hurricanes Helene and Milton, [LENDER] must observe\na moratorium on foreclosures through April 11, 2025 — but only where\nthe HECM is Due and Payable for reasons other than the death of the last\nremaining Borrower and is not subject to a Deferral Period — applying\nto both the initiation of foreclosures and foreclosures already in\nprocess.\n"
  type: dont
  audit_question: For every FHA-insured HECM with subject Property in any FEMA-Declaration area listed in ML 2024-25 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 April 11, 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
  - helene
  - milton
  - promoted
  primary_source:
    tier: 1
    authority: "HUD ML 2024-25 — HECM Foreclosure Moratorium"
    source_class: hud-ml-pdf
    source_url: https://www.hud.gov/sites/dfiles/OCHCO/documents/2024-25hsgml.pdf
    snapshot_id: b3293b7ff0dc948d
    fetched_at: '2026-05-22T19:54:56Z'
    content_hash: sha256:43b30ab78e08f21c57c734f18ae46a67f04bd9e77d74ac921bf76d96a9ca3fba
    paragraph_quote: "The Mortgagee must observe a moratorium on foreclosures of properties \nsecured by FHA-insured HECMs through April 11, 2025, in the following \nFEMA Declarations for Hurricanes Helene and Milton:"
    drafter_attestation: 'Copied verbatim from snapshot b3293b7ff0dc948d (content.txt) at

      2026-05-22T20:25Z. Substring is the HECM moratorium standard of ML

      2024-25; the applicability conditions (Due and Payable reason,

      Deferral Period exclusion) are described, and the FEMA-Declaration

      table follows the quoted span.

      '
  promoted_at: '2026-05-22T20:17:42+00:00'
  promoted_from: hud-ml-2024-25-roundb-v1.yaml
  program_review: Does the program account for the Helene/Milton HECM moratorium condition — halting foreclosures through April 11, 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 HECM files in the listed FEMA-Declaration areas; confirm no foreclosure initiation/completion through April 11, 2025.
  judgment: false
_promotion_history:
- promoted_at: '2026-05-22T20:17:42+00:00'
  candidate_path: obligations\_remediation\_round_b_drafts\hud-ml-2024-25-roundb-v1.yaml
  candidates_promoted: 2
  candidates_skipped_existing: 0
