source:
  type: regulation
  id: hud-ml-2022-07
  authority: "HUD Mortgagee Letter 2022-07 — Update to the COVID-19 Recovery Loss Mitigation Options (40-Year Loan Modification)"
  description: 'HUD ML 2022-07 establishes a 40-year (480-month) loan modification as part

    of the COVID-19 Recovery Loss Mitigation Options for FHA-insured forward

    Mortgages, by updating Handbook 4000.1 section III.A.2.o.iii(C),

    COVID-19 Recovery Home Retention Options.

    '
obligations:
- id: hud-ml-2022-07-implementation-deadline
  canonical_id: hud-ml-2022-07-implementation-deadline
  section: "HUD ML 2022-07 — Effective Date"
  description: '[LENDER] may implement the 40-year COVID-19 Recovery Modification provisions

    of HUD ML 2022-07 immediately but must implement them no later than 90

    calendar days from the date of publication of the ML (i.e., on or before

    July 17, 2022).

    '
  type: do
  audit_question: Can [LENDER] demonstrate that the ML 2022-07 40-year COVID-19 Recovery Modification provisions were implemented in its loss-mitigation operations no later than 90 calendar days from publication of the ML?
  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
  - effective-date
  - promoted
  primary_source:
    tier: 1
    authority: "HUD ML 2022-07 — Effective Date"
    source_class: hud-ml-pdf
    source_url: https://www.hud.gov/sites/dfiles/OCHCO/documents/2022-07hsgml.pdf
    snapshot_id: 183852014de18db6
    fetched_at: '2026-05-22T19:55:12Z'
    content_hash: sha256:6ad7345b02ad1fe7198770839f51906685733e2bb0958aa337dbc77730ce778e
    paragraph_quote: "The provisions of this ML may be implemented immediately but must be \nimplemented no later than 90 calendar days from the date of publication of \nthis ML."
    drafter_attestation: 'Copied verbatim from snapshot 183852014de18db6 (content.txt) at

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

      ML 2022-07.

      '
  promoted_at: '2026-05-22T20:55:56+00:00'
  promoted_from: hud-ml-2022-07-roundb-v1.yaml
  program_review: Does the program account for the implementation deadline — adopting the 40-year COVID-19 Recovery Modification provisions no later than July 17, 2022 (90 days from publication)?
  file_review: Review the loss-mit procedure version history; confirm the 40-year Recovery Modification was operational by the July 17, 2022 deadline.
  judgment: false
- id: hud-ml-2022-07-recovery-mod-40-year-step-5
  canonical_id: hud-ml-2022-07-recovery-mod-40-year-step-5
  section: "HUD ML 2022-07 — COVID-19 Recovery Modification: 40-Year Modification Required When Lower Term Cannot Achieve Target (III.A.2.o.iii(C)(2)(c) Step 5)"
  description: 'Where [LENDER] cannot achieve the target payment for a COVID-19 Recovery

    Modification at Step 4 (30-year modification with principal deferment) and

    the Borrower has available Partial Claim funds, [LENDER] must modify the

    Mortgage to a 40-year (480-month) Loan Modification and provide a Partial

    Claim. A 40-year Loan Modification is not available without a Partial Claim.

    '
  type: do
  audit_question: For each COVID-19 Recovery Modification where Step 4 (30-year + deferment) did not achieve the target payment and Partial Claim funds were available, can [LENDER] evidence that the Mortgage was modified to a 480-month term with an accompanying Partial Claim?
  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
  - covid-19-recovery
  - loan-modification
  - promoted
  primary_source:
    tier: 1
    authority: "HUD ML 2022-07 — III.A.2.o.iii(C)(2)(c) Step 5"
    source_class: hud-ml-pdf
    source_url: https://www.hud.gov/sites/dfiles/OCHCO/documents/2022-07hsgml.pdf
    snapshot_id: 183852014de18db6
    fetched_at: '2026-05-22T19:55:12Z'
    content_hash: sha256:6ad7345b02ad1fe7198770839f51906685733e2bb0958aa337dbc77730ce778e
    paragraph_quote: "If the Mortgagee cannot achieve the target payment at Step 4 and \nthe Borrower has available Partial Claim funds, the Mortgagee must \nmodify the Mortgage to a 40-year (480-month) Loan Modification \nand provide a Partial Claim. A 40-year Loan Modification is not \navailable without a Partial Claim."
    drafter_attestation: 'Copied verbatim from snapshot 183852014de18db6 (content.txt) at

      2026-05-22T20:00Z. Substring is the Step 5 40-year-modification

      requirement incorporated into Handbook 4000.1

      III.A.2.o.iii(C)(2)(c) by ML 2022-07.

      '
  promoted_at: '2026-05-22T20:55:56+00:00'
  promoted_from: hud-ml-2022-07-roundb-v1.yaml
  program_review: Does the program account for the waterfall condition — when Step 4 (30-year + deferment) cannot reach the target and Partial Claim funds are available, requiring a 480-month modification WITH a Partial Claim (40-year not available without one)?
  file_review: Spot-check Recovery Modifications where Step 4 missed the target and Partial Claim funds existed; confirm a 480-month term with an accompanying Partial Claim.
  judgment: false
- id: hud-ml-2022-07-recovery-mod-report-within-90-days
  canonical_id: hud-ml-2022-07-recovery-mod-report-within-90-days
  section: "HUD ML 2022-07 — COVID-19 Recovery Modification Reporting to HUD (III.A.2.o.iii(C)(2)(f)(ii))"
  description: '[LENDER] must report the characteristics of all COVID-19 Recovery

    Modifications, including the rate and term, in FHA Connection (FHAC)

    within 90 Days of the executed COVID-19 Recovery Modification.

    '
  type: do
  audit_question: For every executed COVID-19 Recovery Modification, can [LENDER] demonstrate that the modification characteristics (rate and term) were reported in FHAC within 90 Days of execution?
  workflow_phase: servicing
  owner_role: default_servicing_analyst
  secondary_owner_role: compliance_officer
  cadence: per-modification
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hud-ml
  - fha
  - servicing
  - loss-mitigation
  - covid-19-recovery
  - fhac-reporting
  - promoted
  primary_source:
    tier: 1
    authority: "HUD ML 2022-07 — III.A.2.o.iii(C)(2)(f)(ii)"
    source_class: hud-ml-pdf
    source_url: https://www.hud.gov/sites/dfiles/OCHCO/documents/2022-07hsgml.pdf
    snapshot_id: 183852014de18db6
    fetched_at: '2026-05-22T19:55:12Z'
    content_hash: sha256:6ad7345b02ad1fe7198770839f51906685733e2bb0958aa337dbc77730ce778e
    paragraph_quote: "The Mortgagee must report the characteristics of all COVID-19 \nRecovery Modifications, including the rate and term, in FHAC \nwithin 90 Days of the executed COVID-19 Recovery Modification."
    drafter_attestation: 'Copied verbatim from snapshot 183852014de18db6 (content.txt) at

      2026-05-22T20:00Z. Substring is the FHAC reporting requirement

      for COVID-19 Recovery Modifications incorporated into Handbook

      4000.1 III.A.2.o.iii(C)(2)(f)(ii) by ML 2022-07.

      '
  promoted_at: '2026-05-22T20:55:56+00:00'
  promoted_from: hud-ml-2022-07-roundb-v1.yaml
  program_review: Do the P&Ps ensure the rate and term of every executed COVID-19 Recovery Modification are reported in FHAC within 90 Days of execution?
  file_review: Pull executed Recovery Modifications; confirm FHAC reporting of rate and term within 90 Days of execution.
  judgment: false
_promotion_history:
- promoted_at: '2026-05-22T20:55:56+00:00'
  candidate_path: obligations\_remediation\_round_b_drafts\hud-ml-2022-07-roundb-v1.yaml
  candidates_promoted: 3
  candidates_skipped_existing: 0
