source:
  type: regulation
  id: hud-ml-2024-08
  authority: HUD Mortgagee Letter 2024-08
  description: 'HUD Mortgagee Letter 2024-08. See obligation entries for operative

    requirements and verbatim primary-source citations.

    '
obligations:
- id: hud-ml-2024-08-forward-mortgage-moratorium
  canonical_id: hud-ml-2024-08-forward-mortgage-moratorium
  section: "HUD ML 2024-08 — 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 August 4, 2024, 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 August 4, 2024.

    '
  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 August 4, 2024) and that first-legal-action / Reasonable Diligence Time Frame deadlines were extended by 180 Days from August 4, 2024?
  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 2024-08 — FHA-Insured Forward Mortgages"
    source_class: hud-ml-pdf
    source_url: https://www.hud.gov/sites/dfiles/OCHCO/documents/2024-08hsgml.pdf
    snapshot_id: aaaa0ffbdea217b5
    fetched_at: '2026-05-22T19:54:44Z'
    content_hash: sha256:a85197d6a63cebb0ce22d69093128296b3c53eaf9e7778374c3e809871914cab
    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 August 4, 2024. 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 August 4, 2024."
    drafter_attestation: 'Copied verbatim from snapshot aaaa0ffbdea217b5 (content.txt) at

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

      operative paragraph of ML 2024-08.

      '
  promoted_at: '2026-05-22T20:17:32+00:00'
  promoted_from: hud-ml-2024-08-roundb-v1.yaml
  program_review: Does the program account for the Maui-County disaster moratorium — halting foreclosure initiation and completion on affected forward mortgages through August 4, 2024 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 during the moratorium and the 180-Day deadline extensions from August 4, 2024.
  judgment: false
- id: hud-ml-2024-08-hecm-moratorium
  canonical_id: hud-ml-2024-08-hecm-moratorium
  section: "HUD ML 2024-08 — 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 August\n4, 2024 — but only where the HECM is Due and Payable for reasons other\nthan the death of the last remaining Borrower and is not subject to a\nDeferral Period — applying to both the initiation of foreclosures and\nforeclosures 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 August 4, 2024)?
  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 2024-08 — HECM Foreclosure Moratorium"
    source_class: hud-ml-pdf
    source_url: https://www.hud.gov/sites/dfiles/OCHCO/documents/2024-08hsgml.pdf
    snapshot_id: aaaa0ffbdea217b5
    fetched_at: '2026-05-22T19:54:44Z'
    content_hash: sha256:a85197d6a63cebb0ce22d69093128296b3c53eaf9e7778374c3e809871914cab
    paragraph_quote: "The Mortgagee must observe a moratorium on foreclosures of FHA-insured \nHECMs secured by Properties located in Maui County, Hawaii through \nAugust 4, 2024."
    drafter_attestation: 'Copied verbatim from snapshot aaaa0ffbdea217b5 (content.txt) at

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

      from ML 2024-08; the applicability conditions (Due and Payable

      reason, Deferral Period exclusion) are enumerated in the description.

      '
  promoted_at: '2026-05-22T20:17:32+00:00'
  promoted_from: hud-ml-2024-08-roundb-v1.yaml
  program_review: Does the program account for the Maui-County HECM moratorium condition — halting foreclosures through August 4, 2024 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 during the moratorium period.
  judgment: false
_promotion_history:
- promoted_at: '2026-05-22T20:17:32+00:00'
  candidate_path: obligations\_remediation\_round_b_drafts\hud-ml-2024-08-roundb-v1.yaml
  candidates_promoted: 2
  candidates_skipped_existing: 0
