HUD Requirements for Supervised Lenders without notes

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Understanding HUD Audit and
Reporting Issues for 2011 Audits
of Supervised Mortgagees
A Governmental Audit Quality Center Web Event
January 6, 2012
Administrative Notes
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Administrative Notes
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Presenters
Jean M. Joy, CPA
Wolf & Company, P.C.
&
Amanda Nelson, CPA
KPMG LLP
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What We Will Cover
HUD Audit Requirements and Related Updates
GAGAS
Financial Statement Audit
• Financial Statements and Supplementary Information
• SAS 119, Supplementary Information in Relation to the Financial
Statements as a Whole
Compliance Audit
• HUD OIG Handbook 2000.04,REV-2, Consolidated Audit Guide
for Audits of HUD Programs (HUD Audit Guide)
LASS Electronic Submission/Challenges
Annual Filing Requirements – Mortgagee Letter (ML)
2011-25
Resources
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HUD Audit Requirements – Who?
 Who is Subject to the HUD Audit Requirements?
• Supervised and nonsupervised HUD approved mortgagees and
lenders regardless of the number of loans made.
 Loan Correspondents/TPOs Reminders
• Loan correspondents are no longer approved participants in FHA
programs but will continue to have the opportunity to participate
in FHA programs as third-party originators (TPOs) through
sponsorship by FHA-approved mortgagees, as is currently the
case, or through application to be approved as an FHA-approved
mortgagee.
• FHA-approved mortgagees assume full responsibility to ensure
that a TPO adheres to FHA’s loan origination and processing
requirements.
• TPOs are not subject to annual recertification and reporting
requirements of FHA.
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HUD Audit Requirements – Where?
 Where Can You Find Further Guidance on
HUD Audit Requirements?
• HUD Audit Guide
http://www.hudoig.gov/reports/consolidated.php
• Various HUD Handbooks (e.g., 4060.1) as
referenced through this presentation
• AICPA Governmental Audit Quality Center
(GAQC) HUD information
http://www.aicpa.org/InterestAreas/GovernmentalAuditQuality/Resou
rces/HUDInformation/Pages/default.aspx
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HUD Audit Guide – Which Chapters Apply?
 Auditors of supervised mortgagees need to
refer to various chapters of the HUD Audit
Guide, as appropriate
 Chapter 1 - General Audit Guidance (always applies)
 Chapter 2 - Reporting Requirements and Sample Reports
(always applies)
 Chapter 6 - Ginnie Mae Issuers of Mortgage-Backed Securities
Audit Guidance
 Chapter 7 - HUD-Approved Title II Nonsupervised Mortgagees
and Loan Correspondents Audit Guidance
 Chapter 8 - HUD-Approved Title I Nonsupervised Mortgagees
and Loan Correspondents Audit Guidance
 Today’s presentation will focus on:
 Chapters 1, 2, and 7
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HUD Audit Requirements – What?
 What are the Audit Requirements?
• HUD Title I and Title II approved lenders and
mortgagees are required to have an annual audit and
submit their audited financial statements and
compliance reports electronically through the Lender
Assessment Subsystem (LASS) within 90 days of the
end of their fiscal year
• The audit should be performed in accordance with
Generally Accepted Government Auditing Standards
(GAGAS) and Generally Accepted Auditing Standards
(GAAS) or Public Company Accounting Oversight
Board (PCAOB) Standards, as appropriate
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HUD Audit Requirements: Reports
■ What are the required reports?
A. Financial Statement Audit:
 Opinion on the financial statements
 Report on internal control over financial reporting (no opinion is
issued)
 An opinion on supplementary information in relation to the financial
statements as a whole: consolidating schedules (if required),
schedule of adjusted net worth, and Financial Data Templates
B. HUD Compliance Audit:
 Report on internal control over compliance with HUD
requirements (no opinion is issued)
 Report on compliance with applicable laws and regulations
related to HUD-assisted programs

Major program (opinion is issued)

Non major program
■ Refer to Chapter 2, Reporting Requirements and Sample Reports, of
the HUD Audit Guide for more information
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Update to Requirements: Small Lenders
ML 2011-25 (7/28/11): Alternative Reporting
Requirements for Small Supervised Lenders and
Clarification of Requirements for Supervised
Lenders in Parent-Subsidiary Relationships
 FHA-approved supervised lenders that are regulated by the
FDIC, OTS, or NCUA whose consolidated assets do not
meet the threshold (currently $500MM) required by those
agencies for submitting audited F/S are not required to
submit audited F/S to FHA, nor an audited computation of
net worth. (Expires on April 7, 2012)
 The Q4 Call Report that aligns with the supervised lender’s
fiscal year-end is required to be submitted.
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Update to Requirements: Small Lenders
(continued)
 Small lenders are still required to submit an independent
auditor's report on:
 internal control as it relates to administering HUDassisted programs; and
 compliance with specific requirements applicable to
major and non-major HUD programs.
 The auditors’ report on compliance for non-major
programs is a negative assurance report based on a
financial statement audit and can only be issued when
auditors are engaged to perform the financial statement
audit.
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Update to Requirements: Consolidated
Lenders
 Per ML 2011-25, FHA-approved supervised lenders that
submit audited consolidated financial statements of a
parent company are no longer required to submit
internally prepared consolidating schedules.
 Net worth and liquidity requirements must be met by the
FHA-approved lender regardless of the lender’s financial
reporting documentation.
 Related FAQ
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Update to Requirements: Adjusted Net Worth
Requirements
New Net Worth Requirements – ML 2010-20 (June
2010):
 Required effective 5/20/11 (for lenders w/FHA approval
as of 5/20/10):
- Small business - >$500K
- Not a small business - >$1MM
A supervised lender is considered a small business if
average assets are <$175MM.
 Additional changes effective 5/20/13
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Government Auditing
Standards (GAGAS)
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Overview of GAGAS Requirements (2007)
 GAGAS are published by the Comptroller General of
the United States
http://www.gao.gov/new.items/d07731g.pdf
 Terms GAGAS, GAS, and Yellow Book often used
interchangeably
 2007 Revision of GAGAS to be used for 2011 audits
(see hyperlink above)
 As an FYI – GAO has issued a new 2011 Edition of
GAGAS that will not be effective until periods ending
on or after 12/15/2012
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Overview of GAGAS Requirements (continued)
General standards generally does not
incorporate AICPA standards
Field work standards incorporates AICPA
standards
Reporting standards incorporates AICPA
standards
(Chapter 3)
(Chapter 4)
(Chapter 5)
Note: GAGAS can be used in conjunction with other
auditing standards such as those issued by the PCAOB
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General Standards – Independence
■ Overarching principles: Audit organizations must
not
 Provide nonaudit services that involve performing
management functions or making management
decisions
 Audit their own work or provide nonaudit services in
situations in which the nonaudit services are
significant or material to the subject matter of the
audits
■ Categories of nonaudit services
■ Supplemental safeguards when providing nonaudit
services
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General Standards – CPE
Auditors performing work under GAGAS should maintain their professional
competence through CPE, as follows:
24-hour requirement topics
• The government environment
• Standards used in government auditing
• The specific or unique environment of
the audited entity
Remainder of the 80-hour
requirement
• Broad array of topics including courses
on firm’s audit methodology
80-hour total requirement
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General Standards – CPE (continued)
■ All professionals working on an engagement where
the report states that the engagement was
conducted in accordance with GAGAS are required
to meet the GAGAS CPE requirements, including:
- Audit professionals
- Internal specialists that are part of the engagement
team
- Internal auditors and subcontractors
■ Consider the team member’s responsibilities when
determining whether or not a certain course
qualifies for GAGAS CPE
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General Standards – CPE (continued)
■ Auditors who are only involved in performing field
work but not involved in planning, directing, or
reporting on the audit or attest engagement, and
who charge less than 20% of their time annually to
audits and attestations conducted in accordance
with GAGAS should comply with the 24 hour
requirement but are exempt from the remainder of
the 80 hour requirement
■ Exemptions from all GAGAS CPE requirements:
- Individuals performing support services, such as
administrative assistants
- Interns
- External specialists
- Internal specialists who have a consultative role
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Field Work Standards – Financial Audits
Auditor Communication
• GAGAS broaden the parties
included in the
communication and the
matters we communicate
to those parties
Results of Previous Audits &
Attestation Engagements
• Auditors are required to
evaluate whether the
audited entity has taken
appropriate corrective
action to address findings
and recommendations
from previous
engagements
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Violations of Provisions of
Contracts or Grant
Agreements or From Abuse
• Auditors are required to
design the audit to provide
reasonable assurance of
detecting material
misstatements resulting
from violations of
provisions of contracts and
grant agreements
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Reporting Standards – Financial Audits
Report on internal
control over financial
reporting
Report on compliance
with laws, regulations,
and provisions of
contracts and grant
agreements
• Report significant deficiencies and material
weaknesses in internal control
• At the financial statement level
• Report all instances of fraud and illegal acts,
unless inconsequential; and violations of
provisions of contracts or grant agreements, and
abuse that could have a material effect on the
financial statements
• At the financial statement level
 Report compliance with GAGAS
 Report views of responsible officials for findings
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Reporting Standards – Financial Audits (continued)
Elements of a Finding
Criteria
Condition
• The specific laws, regulations, contracts, or internal control
procedure, against which performance is compared or evaluated
• The nature of the deficiencies, e.g., a regulation not being
followed, a control procedure not followed
Cause
• Why the condition exists
Effect
• What happened as a result of the condition
Recommendation
Views of Responsible
Officials
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• What the auditee should do to correct the condition
• Provided by management
25
Financial Statement Audit
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Financial Statements and Supplementary
Information
Scenario
Level of financial
statements
Audited
consolidating
schedules
Financial Data
Templates
Net worth schedule
(in LASS)
Net worth schedule
(audited)
Stand-alone bank
Bank
N/A
Bank
Bank
Bank
Bank ≥ 40% of
consolidated entity;
No guarantee by
parent
Consolidated
Not required
(ML 2011-25)
Consolidated
Consolidated
Bank
Consolidated
Consolidated
Bank
Bank <40% of
consolidated entity;
Guarantee by parent
Consolidated
Not required
(ML 2011-25)
Bank <40% of
consolidated entity;
No guarantee by
parent
Consolidated
Required
Bank
Bank
Bank
Multiple banks, each
<40% of
consolidated entity;
No guarantee by
parent
Consolidated
Required
Each bank
Each bank
Each bank
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SAS 119, Supplementary Information in
Relation to the Financial Statements as a
Whole
Effective for periods beginning on or after
December 15, 2010
Addresses auditor’s responsibility when
reporting on supplementary information
(“SI”) in relation to financial statements as a
whole
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SAS 119, Supplementary Information in
Relation to the Financial Statements as a
Whole (continued)
Auditor should perform the following procedures:
 Inquire of management regarding the purpose of the SI
and the criteria to prepare the SI
 Determine if the form and content comply with the criteria
 Obtain an understanding of the methods used to prepare
the SI
 Reconcile the SI to the accounting records or financial
statements
 Inquire of management regarding significant
assumptions/interpretations
 Evaluate the appropriateness and completeness of the SI
 Obtain written representations from management
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SAS 119, Supplementary Information in
Relation to the Financial Statements as a
Whole (continued)
Other considerations:
 Auditor has no responsibility for subsequent events
 Reporting
Adds language to the opinion:
 Responsibility of management
 Derived from, and relates directly to, the underlying
accounting records
 SAS includes examples of the opinion (both separate and
part of audit opinion)
 Auditor is precluded from expressing an opinion on SI
when the audited financial statements contain an adverse
opinion or a disclaimer of opinion
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A Word of Caution
HUD Audit Guide Illustrative Report, Example A, not yet
updated for SAS 119 in-relation-to wording
AICPA will be working with HUD to assist them with
updating report language for SAS 119 in the HUD
illustration
In the meantime, look to SAS 119 to assist you in
modifying in-relation-to wording
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Compliance Audit
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Compliance Audit – Applicable Guidance
Auditing Standard - AU 801, Compliance Audits (SAS
117)
• http://www.aicpa.org/Research/Standards/AuditAttest/Download
ableDocuments/AU-00801.pdf
HUD Audit Guide (see slide 8 for hyperlink to access
Guide)
AICPA Audit Guide, Government Auditing Standards and
Circular A-133 Audits
• Chapters 1-4 may be useful for the Government Auditing
Standards portion of the engagement
• http://www.cpa2biz.com/AST/AICPA_CPA2BIZ_Specials/MostP
opularProductGroups/AuditAccountingGuides/PRD~PC012743/PC-012743.jsp
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Compliance Audit
Materiality
■ Establish and apply materiality levels for the compliance
audit based on the HUD audit requirement
■ Consideration of materiality is in relation to the lender’s
HUD program activities taken as a whole
Materiality is affected by:
■ The nature of the compliance requirements which may not
be quantifiable in monetary terms
■ Qualitative considerations, such as the needs and
expectations of HUD
American Institute of CPAs
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Compliance Audit (continued)
Performing Risk Assessment Procedures
 Obtain an understanding of the applicable HUD requirements and the
entity's internal control over compliance with HUD requirements
 Use the information obtained during risk assessment to determine the
nature, timing, and extent of the audit procedures for the HUD
compliance audit
Example risk assessment procedures include
 Inquiring of management about whether there are findings and
recommendations in reports or other written communications resulting
from other audits or external monitoring that directly relate to the
objectives of the HUD compliance audit
 Gaining an understanding of management's response to findings and
recommendations that could have a material effect on the entity's
compliance with HUD requirements (for example, taking corrective
action)
American Institute of CPAs
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Compliance Audit (continued)
 Risk of Material Noncompliance
Inherent Risk
Control Risk
Risk of Material
Noncompliance
 Inherent risk and control risk may be assessed
separately or combined
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Compliance Audit (continued)
Tests of Controls vs. Tests of Compliance
Control

What did the client do to ensure that
compliance was achieved?
Compliance

Was the compliance objective
achieved?
American Institute of CPAs
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HUD OIG Handbook 2000.04,
REV-2, Consolidated Audit
Guide for Audits of HUD
Programs (HUD Audit Guide)
- Chapter 1 – General Audit
Guidance (April 2011 update)
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HUD Audit Guide - Chapter 1 – General Audit
Guidance
Some key elements in April 2011 transmittal letter
include:
 Paragraph 1 - 4 displays the value to be used in making major
program determinations for each program covered by this
guide.
 Update: Increased major program threshold from $300,000 to
$2,000,000
 Paragraph 1 - 5 requires attribute sampling as the appropriate
sampling methodology. Minimum sample sizes are established
and are mandatory to provide sufficient audit evidence and
adequate audit coverage.
 Update: Made the attribute sampling requirements in Appendix A of
Chapter 1 applicable to all audits performed in accordance with the
HUD Audit Guide
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HUD Audit Guide - Chapter 1 – General Audit
Guidance (continued)
 Paragraph 1-5 (continued)
 The table below illustrates the minimum sample sizes in
Appendix A for testing compliance with HUD requirements. The
minimum sample sizes assume no exceptions are expected.
Importance/
Significance of
the Attribute
Being Tested
Confidence Level
Tolerable Rate
Minimum Sample
Size for
Populations over
200
Low
90%
5%
50
Low
90%
10%
25
High
95%
5%
65
High
95%
10%
35
 For population ≤ 200, minimum sample sizes generally range from
5-20 items.
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HUD Audit Guide - Chapter 1 – General Audit
Guidance (continued)
 Paragraph 1-6 requires the auditor to telephonically contact the
HUD OIG single audit coordinator if he/she becomes aware of
fraud or illegal acts.
 Paragraph 1 -7 requires information to be included in
engagement letters for all audits of HUD programs so that the
auditor and the client are in agreement and the client grants
permission for the auditor to obtain information from the prior
auditor and report fraud as provided for in the HUD Audit
Guide.
 Effective date: Chapter can be used upon issuance;
requirements apply to audits of years ended on or after
9/30/11.
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Chapter 7 – HUD-Approved Title II Nonsupervised Mortgagees and Loan
Correspondents Audit Guidance
(April 2007)
Programs Related to Single-family and Multi-family
Homes
[Currently under revision by HUD]
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HUD Audit Guide - Chapter 7
■ Compliance Requirements:
 Maintaining a quality control plan;
 Maintaining branch operations;
 Loan origination;
 Loan settlement;






Loan servicing;
Escrow accounts;
Section 235 assistance payments;
Federal financial and activity reports;
Kickbacks; and,
Mortgagee approval requirements (including maintaining an
acceptable adjusted net worth)
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HUD Audit Guide - Chapter 7 (continued)
■ Example HUD Compliance Procedures – Chapter 7
 Quality Control Plan – Each mortgagee is required to establish and
maintain a written quality control plan.
• Obtain a copy of the quality control plan and compare to HUD
Handbook 4060.1 requirements
•
•
•
•
•
For example, sample size and loan selection requirements
Determine procedures are in place to ensure that all employees
involved in origination and servicing understand quality control
policies and procedures
Assess competence of quality control reviewers
Determine corrective actions for all deficiencies were promptly
initiated
Determine whether employees were notified of any deficiencies
and provided instructions to prevent reoccurrence
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HUD Audit Guide - Chapter 7 (continued)
Branch Office Operations – Each branch office must be
registered by HUD. The mortgagee is fully responsible to HUD for
the actions of its branch offices. Brach office Facilities and Staffing
Requirements can be found in HUD Handbook 4060, Chapter 2.
• Determine whether all branches are registered with HUD
• Only branches that the audited entity uses to conduct FHA
related mortgage operations are required to be registered
with HUD
• Determine whether the branch is a true branch and is not a
subsidiary, independent contractor or separate entity
• Mortgagee Letter 2011-34 rescinded the “ branch office facilities”
requirements
 Update: Mortgagee Letter 2011-34 –Paragraphs 2.11.A through
2.11.D and 3.2.A.9 of Handbook 4060.1 related to office facilities
requirements have been rescinded

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HUD Audit Guide - Chapter 7 (continued)

Loan Origination – Loans should be originated with the same
care that would be exercised in originating a non-insured loan
entirely dependent on the property as security to protect
investment.
• Applicant’s personal information should be submitted directly to
the HUD registrant and not passed through any interested party
(e.g., realtor)
• For a sample of loans, review loan files to obtain evidence that
applicant’s information was verified as required by HUD
Handbook 4000.2
• For a sample of rejected loans, determine whether the rejection
was made based on established criteria and the reason was
provided to the applicant
FOLLOW THE NEW SAMPLING GUIDANCE
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HUD Audit Guide - Chapter 7 (continued)
 Loan Settlement – HUD has specified the types and
amounts of additional charges and fees. Up-front
mortgage insurance premiums should be remitted to
HUD promptly.
 Select a sample of HUD loans settled during the audit
period and perform the following:
• Test the mathematical accuracy of Form HUD-1
• Review appropriateness of fees and charges
collected
• Review supporting data to establish escrow accounts
• Examine canceled checks to ensure the mortgagee
remitted mortgage insurance premiums to HUD
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HUD Audit Guide - Chapter 7 (continued)
 Loan Servicing - Loan servicing procedures are to be followed
consistently and should not vary. The lender should have an organized
means of periodically identifying the payment status of delinquent
loans.
• For a sample of delinquent and defaulted loans, determine whether
loan file documentation reflects the delinquent status
• Review evidence that mortgagee made a reasonable effort to
communicate with mortgagor and determine the cause of default
• Review procedures for handling partial payments
• Determine compliance with HUD’s Loss Mitigation program and
Foreclosure Relief Program
• Determine procedures for paying mortgagee insurance premiums to
HUD
• Test insurance claim amounts on a sample basis
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HUD Audit Guide - Chapter 7 (continued)
 Section 235 Assistance Payments – HUD sends
assistance payments to the mortgagee; mortgagee
must meet other continuing eligibility criteria; the
mortgagee must secure re-certifications of income,
family composition and other items.
Instances of mortgages under this program should
be rare!
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HUD Audit Guide - Chapter 7 (continued)
 Federal Financial and Activity Reports – Mortgagees are required to
ensure that financial status, single-family default monitoring and reports
required under the Home Mortgage Disclosure Act (HMDA) contain
reliable data and are presented in accordance with the terms of the
agreement between the entity and HUD.
• Understand the process of preparing financial and activity reports
• For a sample of reports, determine if the reports were prepared in
accordance with HUD instructions
• Trace significant data to supporting documentation on a sample
basis
• Review significant adjustments to general ledger balances affected
by HUD-assisted program activity
REPORTS REQUIRED TO BE FILED BY MORTGAGEES CAN BE
FOUND IN HUD HANDBOOK 4330.1, CHAPTER 7, 41552.1
CHAPTER 3, AND ML 95-3
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HUD Audit Guide - Chapter 7 (continued)
 Kickbacks – kickbacks and similar payments are
prohibited.
♦ On a sample basis, test whether disbursements are
supported by invoices and were not for an unreasonable
amount
♦ Determine whether any fees or compensation paid are
prohibited by the Real Estate Settlement Procedures Act
♦ Consider whether fees paid or other type of payments,
observed during the review of loan origination and loan
settlement documents, represent kickbacks
♦ Determine if other suggested procedures in the HUD Audit
Guide are applicable to your circumstances
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HUD Audit Guide - Chapter 7 (continued)
 Mortgagee Approval Requirements – A mortgagee
should have and maintain required adjusted net worth in
eligible assets.
• Test whether the levels of adjusted net worth, liquid
assets, fidelity bond coverage and errors and
omissions bond coverage meet the applicable
requirements of HUD Handbook 4060.1 and ML
2010-20
.
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LASS Electronic
Submission
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LASS Electronic Submission
See HUD Audit Guide Chapter 7 (7-4B and 7-4C) for
LASS electronic submission requirement
 Not Relevant for small supervised lenders
LASS collects the following information:
1. Financial Data Template (FDT) –
 Data from the balance sheet, operations and
equity statement, cash flow statement, net worth
statement, and liquidity statement
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LASS Electronic Submission (continued)
LASS collects the following information:
2. Data Collection Form (DCF) –
 Basic information regarding the lender’s
recertification such as fiscal year end data, audit
period covered, lender and auditor information,
and the type and details of the audit opinions and
findings
 Signed audit opinion report, internal control report,
and compliance reports must be attached as
portable documents in a PDF file format
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LASS Electronic Submission (continued)
LASS collects the following information:
3. Notes and Findings –
 Collection of the lender’s footnotes
accompanying the financial statements, and if
applicable, the schedule of findings and
questioned costs and lender’s corrective action
plan.
 These documents must be attached as portable
documents in a PDF file format.
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LASS Electronic Submission (continued)
Single Family Housing Lender Assessment
Subsystem (LASS) User's Manual (updated as of
October 2009)
 Section 5.10 – For Independent Public Accountants,
Completing Agreed-upon Procedures (Online)
 http://portal.hud.gov/hudportal/HUD?src=/program_of
fices/housing/sfh/lass/lass_usermanual
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LASS Electronic Submission (continued)
The responsibility for the electronic submission
rests with the lender.
To assure the accuracy and completeness of the
data within LASS, auditors are required to perform a
separate agreed-upon procedure engagement.
 In general, the auditor must compare the electronic
data in LASS to the hard copy of the basic financial
statements, footnotes, audit reports, and FDT.
 This procedure should be performed under AICPA
SSAE No. 10.
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LASS Electronic Submission (continued)
To assure the accuracy and completeness of the
data within LASS, auditors are required to perform a
separate agreed-upon procedure engagement.
 To perform these procedures, auditors must register
with HUD’s Secure Connection system for a user ID
and password, as well as obtain a Unique
Independent Public Accountant (IPA) Identifier (UII).
 For further information about obtaining a user ID,
passwords, and UII, refer to the LASS User Manual
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LASS Challenges
The LASS template has not been formatted for a
supervised lender.
Supervised lenders and many independent auditors
are not familiar with the LASS template.
New requirements include submitting the Q4 Call
Report; should be labeled to indicate that it is not
subject to audit or agreed-upon procedures.
Auditors are required to issue an agreed-upon
procedure report related to LASS template data
(embedded in LASS and issued in hard copy).
As a result of the above, significant amounts of time
are expended by supervised lenders and their
auditors.
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LASS Challenges (continued)
Key issues to consider when trying to format the
LASS FDT for supervised mortgagees:
 Several changes to GAAP have evolved since the
LASS template was formatted.
 The FDT reflects a classified balance sheet; assets
and liabilities are classified as either current or noncurrent.
 The primary liabilities of a supervised generally include
deposits and borrowings, for which the FDT does not
include specific line items. As a result, “other assets”
and “other liabilities” will be significant (current/longterm?).
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LASS Challenges (continued)
Cash Flow Data
 FDT is based on changes in current and non-current
assets and liabilities.
 The cash flow data also does not reflect certain
significant sources and uses of cash flows for
a supervised mortgage.
 Many cash flow auto-fills do not correspond to a
GAAP presentation.
 To the extent that a supervised mortgagee’s assets,
liabilities or cash flows do not fit a specifically
identified line item in the FDT, a supervised
mortgagee is required to make judgments as to how
to report such assets, liabilities or cash flows.
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LASS Challenges (continued)
HUD Financial Data Template Line Definitions Guide
Find at:
http://portal.hud.gov/hudportal/documents/huddoc?i
d=DOC_12651.pdf
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Annual Filing
Requirements - ML
2011-25
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Annual Filing Requirements - ML 2011-25
Due to logistical issues relating to filing electronically on LASS
without financial statements or an agreed-upon procedures
report, HUD will accept manual filing from small supervised
lenders:
• Two copies of each report must be submitted.
• Cover letter with FHA lender/mortgagee ID number that claims the
exemption for supervised lenders under the April 7, 2011 waiver must
be included.
• FHA lender/mortgagee ID number must be written on the upper righthand corner of each separate document.
• All lenders must pay the annual fee and submit the annual certification
online via the FHA Connection.
• Lender's recertification will be considered "submitted" from the date of
receipt of mailed reports by FHA's Office of Lender Activities and
Program Compliance.
• HUD is revisiting the manual process in early January 2012.
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Annual Filing Requirements – ML 2011-25
(continued)
• Mail to (USPS):
Office of Lender Activities and Program Compliance
Attention: Jason Boldin
490 L'Enfant Plaza East, S.W.
Suite 3214
Washington D.C. 20024
• Courier address:
Office of Lender Activities and Program Compliance
Attention: Jason Boldin
451 7th Street, S.W.
Room B-133 – P3214
Washington D.C. 20024
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Resources
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RESOURCES
HUD.GOV
GAO Government Auditing Standards (The Yellow
Book) http://www.gao.gov/yellowbook
AICPA Standards
(http://www.aicpa.org/Research/Standards/Pages/def
ault.aspx)
AICPA Audit Guide, Government Auditing Standards
and Circular A-133 Audits
AICPA Governmental Audit Quality Center (GAQC)
• Main page: www.aicpa.org/GAQC
• HUD Information Page:
http://www.aicpa.org/InterestAreas/GovernmentalAuditQuality/R
esources/HUDInformation/Pages/default.aspx
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What You Will Find on GAQC HUD
Information Page
AICPA GAQC
• HUD Information
• GAQC Alerts, Web Events. Links to Illustrative Audit Reports,
and Other Resources
• HUD News (Current and Archive)
• HUD Consolidated Audit Guide
• Illustrative HUD Audit Reports
• Submission and Audit Requirements for PHAs and Multifamily
Program Participants
• HUD Offices Relevant to HUD Audits and Related Background
on FASS and LASS
• AICPA HUD Related CPE
• Directory of Helpful Web Sites
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Archived GAQC Web Event
To help you learn more about the Yellow Book in
more detail (open to the public)
• The 2007 Yellow Book: What a Beginner Needs to
Understand
• This archived Web event will be helpful to staff working on forprofit audits and dealing with a Yellow Book audit requirement
for the first time and other staff working on governmental or notfor-profit organization audits that are new to the Yellow Book or
want a refresher.
• No CPE available for viewing the archive
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Questions ?????
Governmental Audit Quality Center
71
Thank you for
participating!
Governmental Audit Quality Center
72
How do I get my CPE certificate?
Just follow these steps:
1. Log on to CPA2Biz.com
2. Click on “My Account” tab on the top of the page and enter your
username and password
3. Click on “My Online Learning” in the middle of the page
4. Click on “CPE Tracker” (a new window or tab will open)
5. Click on “My Transcript” on the upper left side of the page
6. Find your completed course and click on “Go” to get your
certificate.
If you cannot find your certificate on CPA2Biz.com, please contact
the AICPA Service Center at 888.777.7077 or service@aicpa.org
and ask for assistance.
Governmental Audit Quality Center
73
Evaluations
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us know what you thought about
today’s Web event, just click on
the link below to begin the
evaluation:
http://www.zoomerang.com/S
urvey/WEB22E9EQSPZLT/
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