source:
  type: regulation
  id: hud-4000-1-iii-a-1-b
  authority: "HUD Handbook 4000.1 III.A.1.b — Responsibility for Servicing Actions"
  description: 'HUD Single-Family Housing Policy Handbook 4000.1, Section III.A.1.b

    (Responsibility for Servicing Actions). See obligation entries for

    operative requirements and verbatim primary-source citations.

    '
obligations:
- id: hud-4000-1-iii-a-1-b-holder-responsibility
  canonical_id: hud-4000-1-iii-a-1-b-holder-responsibility
  section: "HUD Handbook 4000.1 III.A.1.b — Responsibility for Servicing Actions"
  description: '[LENDER] (as Mortgage Holder) is responsible for all servicing actions,

    including the acts of its Servicers. [LENDER] (as Servicer) is

    responsible for its actions in servicing FHA-insured Mortgages,

    Partial Claim Subordinate Mortgages, and Payment Supplement

    Subordinate Mortgages, and is also responsible for actions taken at

    the direction, or on behalf, of the Mortgage Holder.

    '
  type: do
  audit_question: Can [LENDER] evidence (in its policies and operational records) accountability for all FHA servicing actions taken by itself and by any subservicer acting on its behalf?
  workflow_phase: servicing
  owner_role: compliance_officer
  secondary_owner_role: default_servicing_analyst
  cadence: ongoing
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hud-handbook-4000-1
  - fha
  - servicing
  - servicing-responsibility
  - promoted
  primary_source:
    tier: 1
    authority: "HUD Handbook 4000.1 III.A.1.b — Responsibility for Servicing Actions"
    source_class: hud-handbook-4000-1
    source_url: https://www.hud.gov/hud-partners/single-family-handbook-4000-1
    snapshot_id: 8c03836f77f317e1
    fetched_at: '2026-05-23T00:28:40Z'
    content_hash: sha256:411430f29b13f9b54a2ebb0e6f6e7087ecd2b90d0da22eb0c8c792eaa2d7d0df
    paragraph_quote: 'Mortgage Holders are responsible for all servicing actions, including the acts of its Servicers. '
    drafter_attestation: Copied verbatim from HUD Handbook 4000.1 snapshot 8c03836f77f317e1 (III.A.1.b) at 2026-05-23.
  promoted_at: '2026-05-23T00:37:32+00:00'
  promoted_from: hud-4000-1-iii-a-1-b-roundb-v1.yaml
  program_review: Do the P&Ps establish accountability for all FHA servicing actions taken by [LENDER] and by any subservicer acting at its direction or on its behalf (including Partial Claim / Payment Supplement subordinate mortgages)?
  file_review: Review policy and operational records; confirm documented accountability for [LENDER]'s and subservicers' FHA servicing actions.
  judgment: false
- id: hud-4000-1-iii-a-1-b-no-subservicing-cost-passthrough
  canonical_id: hud-4000-1-iii-a-1-b-no-subservicing-cost-passthrough
  section: "HUD Handbook 4000.1 III.A.1.b — Responsibility for Servicing Actions"
  description: '[LENDER] must not impose the costs associated with subservicing on the

    Borrower or pass those costs along to HUD in a claim for mortgage

    insurance benefits.

    '
  type: dont
  audit_question: Can [LENDER] evidence that no subservicing cost was billed to any Borrower or included in any claim for FHA mortgage insurance benefits?
  workflow_phase: servicing
  owner_role: compliance_officer
  secondary_owner_role: claims_specialist
  cadence: ongoing
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hud-handbook-4000-1
  - fha
  - servicing
  - subservicing
  - claim-integrity
  - promoted
  primary_source:
    tier: 1
    authority: "HUD Handbook 4000.1 III.A.1.b — Responsibility for Servicing Actions"
    source_class: hud-handbook-4000-1
    source_url: https://www.hud.gov/hud-partners/single-family-handbook-4000-1
    snapshot_id: 8c03836f77f317e1
    fetched_at: '2026-05-23T00:28:40Z'
    content_hash: sha256:411430f29b13f9b54a2ebb0e6f6e7087ecd2b90d0da22eb0c8c792eaa2d7d0df
    paragraph_quote: 'The costs associated with subservicing may not be imposed on the Borrower or passed along '
    drafter_attestation: Copied verbatim from HUD Handbook 4000.1 snapshot 8c03836f77f317e1 (III.A.1.b) at 2026-05-23.
  promoted_at: '2026-05-23T00:37:32+00:00'
  promoted_from: hud-4000-1-iii-a-1-b-roundb-v1.yaml
  program_review: Do the P&Ps ensure no subservicing cost is billed to any Borrower or included in any FHA insurance claim?
  file_review: Review Borrower billing and claim submissions; confirm no subservicing cost was passed through to the Borrower or HUD.
  judgment: false
- id: hud-4000-1-iii-a-1-b-transfer-15-day-report
  canonical_id: hud-4000-1-iii-a-1-b-transfer-15-day-report
  section: "HUD Handbook 4000.1 III.A.1.b.i(C) — Responsibility during Transfers of Servicing Rights, Required Documentation"
  description: 'When [LENDER] is the Transferor Servicing Mortgagee, [LENDER] must

    report the Transfer Date and update the mortgage record in FHA

    Connection (FHAC) or by Electronic Data Interchange (EDI) or Business

    to Government (B2G) within 15 Days of the Transfer Date.

    '
  type: do
  audit_question: For every transfer of FHA servicing rights, can [LENDER] (as Transferor Servicing Mortgagee) evidence reporting of the Transfer Date and update of the mortgage record in FHAC, EDI, or B2G within 15 Days of the Transfer Date?
  workflow_phase: servicing
  owner_role: compliance_officer
  secondary_owner_role: default_servicing_analyst
  cadence: per-servicing-transfer
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hud-handbook-4000-1
  - fha
  - servicing-transfer
  - 15-day-report
  - promoted
  primary_source:
    tier: 1
    authority: "HUD Handbook 4000.1 III.A.1.b.i(C) — Required Documentation"
    source_class: hud-handbook-4000-1
    source_url: https://www.hud.gov/hud-partners/single-family-handbook-4000-1
    snapshot_id: 8c03836f77f317e1
    fetched_at: '2026-05-23T00:28:40Z'
    content_hash: sha256:411430f29b13f9b54a2ebb0e6f6e7087ecd2b90d0da22eb0c8c792eaa2d7d0df
    paragraph_quote: 'The Transferor Servicing Mortgagee must report the Transfer Date and update the '
    drafter_attestation: Copied verbatim from HUD Handbook 4000.1 snapshot 8c03836f77f317e1 (III.A.1.b.i(C)) at 2026-05-23.
  promoted_at: '2026-05-23T00:37:32+00:00'
  promoted_from: hud-4000-1-iii-a-1-b-roundb-v1.yaml
  program_review: Do the P&Ps ensure that, as Transferor Servicing Mortgagee, the Transfer Date is reported and the mortgage record updated in FHAC/EDI/B2G within 15 Days of the Transfer Date?
  file_review: Pull servicing-transfer-out events; confirm the Transfer-Date report and mortgage-record update in FHAC/EDI/B2G within 15 Days.
  judgment: false
_promotion_history:
- promoted_at: '2026-05-23T00:37:32+00:00'
  candidate_path: obligations\_remediation\_round_b_drafts\hud-4000-1-iii-a-1-b-roundb-v1.yaml
  candidates_promoted: 3
  candidates_skipped_existing: 0
