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SINGLE FAMILY POST CLAIM REVIEWS
Solicitation number
HUD-2015-H-017
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ATTACHMENT 1

LIST OF MORTGAGEE LETTERS

SINGLE FAMILY POST INSURANCE DIVISION

POST CLAIM REVIEW CONTRACT

MORTGAGEE LETTERS

*Though this attachment lists all relevant mortgagee letters to date, the Contractor will be responsible for obtaining and reviewing all subsequent mortgagee letters

Doc #
Title
15-06
Home Equity Conversion Mortgage (HECM) - Delay in Effective Date for Financial Assessment and Property Charge Funding Requirements for the Payment of Certain Property Charges
15-03
Mortgagee Optional Election Assignment for Home Equity Conversion Mortgages (HECMs) with FHA Case Numbers assigned prior to August 4, 2014
15-02
Home Equity Conversion Mortgage (HECM) Program: Policy Guidance and Certifications for Eligible and Ineligible Non-Borrowing HECM Spouses and Seasoning Requirements Guidance
14-24
Increasing Use of FHA's Claims Without Conveyance of Title (CWCOT) Procedures
14-22
Home Equity Conversion Mortgage (HECM) Financial Assessment and Property Charge Requirements
14-21
Revised Changes to the Home Equity Conversion Mortgage (HECM) Program Requirements
14-19
New Single Family Loan Servicing Contractor
14-16
Electronic Retention of Foreclosure-Related Documentation
14-15
Updated Requirements for Pre-Foreclosure Sales (PFS) and Deeds in Lieu (DIL) of Foreclosure
14-12
Home Equity Conversion Mortgage (HECM) Program: New Principal Limit Factors
14-11
Home Equity Conversion Mortgage (HECM) Program: Limit on Insurability of Fixed Interest Rate Products under the HECM Program
14-10
Home Equity Conversion Mortgage (HECM) Program - Prohibition on Misleading or Deceptive Program Descriptions or Advertising and Prohibition on Restriction of Mortgagor’s Freedom of Choice
14-07
Home Equity Conversion Mortgage (HECM) Program: Non-Borrowing Spouse
14-03
Electronic Signatures
14-02
Revised Manual Underwriting Requirements
14-01
"Save Your Home: Tips to Avoid Foreclosure" - Brochure for Delinquent Mortgagors
13-45
Delay in Effective Date for Home Equity Conversion Mortgage (HECM) Financial Assessment Requirements and Funding Requirements for the Payment of Property Charges
13-44
HUD Single Family Real Estate Owned (REO) Properties: Updates on Ordering New Appraisals and Clarification on Comparables Used for Appraisals
13-43
Federal Housing Administration Maximum Loan Limits Effective January 1, 2014 through December 31, 2014 (Attachment 1,2)
13-39
Methods of Communication with Borrowers
13-38
Single Family Foreclosure Policy and Procedural Changes for HUDTitle II Forward Mortgages and HECM Reverse Mortgages; Reasonable Diligence Requirements; HUD’s Schedule of Allowable Attorney Fees
13-34
Delayed Implementation of "PFS Participation Requirement" Section included in Mortgagee Letter 2013-23, Updated Pre-Foreclosure Sale (PFS) and Deed in Lieu (DIL) of Foreclosure Requirements
13-33
Home Equity Conversion Mortgage Program's Mandatory Obligations, Life Expectancy Set-Aside Calculation, and Purchase Transactions
13-32
Update to FHA's Loss Mitigation Home Retention Options
13-29
Application of Unused Borrower Funds from an Escrow Account on an Existing Mortgage in FHA-Insured Refinance Transactions
13-28
Home Equity Conversion Mortgage (HECM) Financial Assessment and Property Charge Guide (Attachment)
13-27
Changes to the Home Equity Conversion Mortgage Program Requirements
13-23
Updated Pre-Foreclosure Sale (PFS) and Deed in Lieu (DIL) of Foreclosure Requirements
13-22
Extension of Unemployment Special Forbearance
13-19
Partial Claim Documentation and Delivery Requirements
13-18
Updated Clarification Regarding Title Approval at Conveyance
13-17
Interest Rates for Loss Mitigation Home Retention Options
13-16
Subordination of Partial Claim Liens Associated with Federal Housing Administration (FHA) Streamlined Refinances
13-15
Updated Delinquency/Default Status Codes for the Single Family Default Monitoring System; Special Forbearances and Trial Payment Plans; New Reporting Requirement for Non-Incentivized Loan Modifications
13-12
Lender Insurance Program
13-03
Extension of Implementation Date for Mortgagee Letter 2012-22, Revisions to FHA's Loss Mitigation Home Retention Options
13-02
Home Equity Conversion Mortgage (HECM) Program - Amended Late Request for Endorsement Procedures
13-01
Home Equity Conversion Mortgage Program - Consolidation of Pricing Options and Principal Limit Factors for Fixed Interest Rate Mortgages Mortgagee Letters
12-26
Federal Housing Administration Maximum Loan Limits, Effective Period: January 1, 2013, through December 31, 2013
12-22
Revisions to FHA’s Loss Mitigation Home Retention Options
12-21
Extension of Implementation Date for Mortgagee Letter 2012-11, Clarification Regarding Title Approval at Conveyance
12-19
Hazard and Flood Insurance Requirement Reminder
12-17
Home Equity Reverse Mortgage Information Technology (HERMIT) System for the Home Equity Conversion Mortgage (HECM)
12-14
Extension of Implementation Date for Mortgagee Letter 2012-11, Clarification Regarding Title Approval at Conveyance
12-12
Responsibilities of Mortgagees in Regard to State and Local Laws
12-11
Clarification Regarding Title Approval at Conveyance
12-7
New Single Family Loan Servicing Contractor
12-6
Changes to FHA's Occupied Conveyance Procedures
11-39
Federal Housing Administration Maximum Loan Limits Effective October 1, 2011 through December 31, 2012 (Attachment 1, 2)
11-29
Federal Housing Administration’s (FHA) Maximum Loan Limits Effective October 1, 2011 through December 31, 2011 (Attachment 1,2)
11-20
Termination of the HOPE for Homeowners (H4H) Program
11-12
Tier Ranking Scores - Incentive Round 42
11-9
Home Equity Conversion Mortgage (HECM) Counseling: Waiver of HECM Counseling Fees and Activities Included in the Time Recorded Portion of the HECM Counseling Certificate
11-8
FHA Single Family Insurance Claims Accounts Receivable Subsystem (ARS) Remittances: Pay.gov Implementation
11-6
Claim Process for FHA Refinances of Borrowers in Negative Equity Positions (ADP Codes 821, 822, 831, or 832)
11-1
Home Equity Conversion Mortgage Property Charge Loss Mitigation (Attachment)
10-39
Home Equity Conversion Mortgage (HECM) – HUD-1 Settlement Statement Closing Certification (Attachment)
10-1
Borrower Certification for FHA Refinance of Borrowers in Negative Equity Positions (Attachment)
10-23
FHA Refinance of Borrowers in Negative Equity Positions
10-22
Home Equity Conversion Mortgage (HECM) Program Submission of Case Binder Documents (Attachment)
10-18
Update of Property and Preservation (P&P) Requirements and Cost Reimbursement Procedures
10-14
Electronic Signatures On Third Party Documents
10-13
Appraisal Update and/or Completion Report (Fannie Mae Form 1004D/Freddie Mac Form 442/March 2005)
10-11
Availability of Treasury Success Payments for FHA-HAMP Modifications
10-9
Tier Ranking Scores – Incentive Round 38 (Attachment)
09-52
Short Sales and Short Pay Offs
09-50
2010 FHA Maximum Loan Limits (Attachment 1, 2)
09-49
Home Equity Conversion Mortgage Program: Subordinate Liens
09-48
Second Appraisal Reporting Requirements
09-45
Introduction of HUD's Web-Based Training Application: Electronic Class (EClass) on Loss Mitigation and Servicing System
09-44
Home Equity Conversion Mortgage (HECM) Program -- Clarification of Debenture Interest Calculation for HECM Claim Type 21; Claim Filing Instructions for HECM Claim Types 21 and 24
09-43
Hope for Homeowners Program - Comprehensive Guide Exhibits A, B, C, D
09-42
Sub-Servicing of FHA-insured Mortgages
09-39
Updated Claim Filing and Delinquency/Default Reporting Requirements For FHA's Making Home Affordable Modification Program (FHA-HAMP)-Appendix 1,2,3)
09-35
Loan Modification
09-34
Home Equity Conversion Mortgage (HECM) - Principal Limit Factors
09-23
Making Home Affordable Program: FHA's Home Affordable Modification Loss Mitigation Option - Attachment )
09-7
Loan Limit Increases for FHA (Attachments 1, 2)
08-36
2009 FHA Maximum Mortgage Limits (Attachments 1, 2)
08-21
FHA Loss Mitigation Program Updates
08-6
Temporary Loan Limit Increase for FHA (attachment 1 and 2)
08-5
Tier Ranking Scores - Incentive Round 30 (Attachment)
08-2
2008 FHA Maximum Mortgage Limits (Attachments 1 and 2)
07-3
Revision of Preservation and Protection Requirements and Cost Reimbursements (Attachment)
07-1
2007 FHA Maximum Mortgage Limits (Attachment)
06-31
Tier Ranking Scores (Attachment)
06-20
Home Equity Conversion Mortgage Program: Subordinate Liens and State and Local Court-Ordered Judgments and Judgment Liens
06-15
Future Delinquency Reporting Requirement (Appendix 1 &2)
06-7
Clarification of Mortgagee Letter 2006-04 - Closing Costs for Home Equity Conversion Mortgages
06-4
Revised Borrower's Closing Costs Guidelines
05-49
2006 FHA Mortgage Maximum Loan Limits (Attachment)
05-47
Tier Ranking Scores (Attachment)
05-30
Single Family Foreclosure Policy and Procedural Changes: Reasonable Diligence Requirements; Update to HUD's Schedule of Allowable Attorney Fees; and Update to HUD's Foreclosure Time Frames (Attachments 1,2,3,4)
05-22
Preservation and Protection Procedural Update (Attachment)
05-18
Success of Loss Mitigation and Increase in Incentive Payments
04-46
2005 FHA Maximum Mortgage Limits (Attachment 1, 2)
04-34
Clarification of Mortgagee Letter 2003-17; Elimination of Paper Mortgage Insurance Certificates and data Integrity Improvement
04-33
Debenture Interest Changes
04-30
Loss Mitigation Performance Scores (Attachment)
04-26
Filing Conveyance AND Pre-Foreclosure Sale Claims via the FHA Connection (Attachment A, B, C, D)
04-22
Elimination of Paper Mortgage Insurance Certificates for Home Equity Conversion Mortgage (HECM) Claims
04-16
A New Interactive Website for Preservation and Protection Cost Allowables
04-9
Update of Preservation and Protection Mortgagee Letter 2003-05
04-7
Update to Preservation and Protection Mortgagee Letters 2002-10, 2002-19, and 2003-05
04-5
Address Change for First Madison Services, Inc. Single Family Loan Servicing Contractor
04-1
FHA's Total Mortgage Scorecard Deployment
03-19
Partial Claims: Program Changes and Updates
03-12
Revisions to FHA Maximum Mortgage Areas and Limits (Attachment)
03-6
Loss Mitigation Performance Scores (Attachment)
03-5
Update of Mortgagee Letter 2002-10, 2002 Preservation and Protection Cost Schedule and Policy Updates/2002 Post Endorsement Guidelines, Fees and Schedules (Attachment)
02-19
Clarification Regarding Title Approval issues, Property Condition at Conveyance, Administrative Offsets and a New Process for Lender Appeal of Conveyance Issues
02-17
Special Forbearance: Program Changes and Updates
02-14
HUD-PA-426 How To Avoid Foreclosure (May 2001)
02-13
Deed-in-Lieu of Foreclosure Consideration Increase and the Authorization to Pay Cash to Occupants for Keys Prior to Eviction
02-11
Loss Mitigation Performance Scores (Attachments)
02-10
2002 Preservation and Protection Cost Schedule and Policy Updates/2002 Post Endorsement Guidelines, Fees and Charges (Attachments)
02-8
Proper Use of Direct Conveyance
01-28
Single Family Foreclosure Policy and Procedural Changes: Extension of Time to Initiate Foreclosure in the District of Columbia
01-19
Single Family Foreclosure Policy and Procedural Changes: Non-Judicial Foreclosure in Hawaii; First Legal Action to Commence Foreclosure in GU, IA, SD, & VI; Reasonable Diligence for Acquiring Possession; Update to HUD's Schedule of Allowable Attorney Fees; and Update to HUD's Foreclosure Time Frames (Attachments)
01-16
Home Equity Conversion Mortgage Program (HECM) Servicing and Claim Issues (Attachment)
01-14
FHA Loss Mitigation Clarification of Time Frames
01-8
Loss Mitigation Performance Scores (Attachment A, B)
01-2
Filing Loss Mitigation Incentive Claims via the FHA Connection (Attachments)
00-26
Preservation and Protection Cost Update for Debris Removal and Property Inspections; Clarifications on Boarding, Delayed Evictions and Lender Appeals (Attachments)
00-19
New Address for Single Family Claims Branch and Submission of Single Family Application for Insurance Benefits (Form HUD-27011) - Paper Claims and Mortgage Insurance Certificates for Electronic Part A Claims
00-11
Loss Mitigation Performance Scores (Attachment)
00-5
Loss Mitigation Program - Comprehensive Clarification of Policy and Notice of Procedural Changes
99-8
Clarification of Mortgagee Letter 98-26
99-6
Loss Mitigation Performance Scores
98-26
Single Family Default and Foreclosure Servicing Policy and Procedural Changes Including HUD Schedule of Allowable Attorney Fees (Attachments)
98-18
Risk Assessment for Defaulted Loans
98-12
Oklahoma City Central Servicing Office
98-9
Loss Mitigation Performance Scores (Attachment)
98-7
FHA Loss Mitigation Program Policy and Procedural Updates
97-44
Revised HUD-PA-426, How To Avoid Foreclosure (May 1997) (Attachment)
97-43
FHA Loss Mitigation - Mortgage Modification Clarifications
97-31
1997 Preservation and Protection/Post Endorsement Guidelines and Fee Schedules
97-25
Submission of Single Family Claims via Electronic Data Interchange (EDI)
97-18
Procedural Changes for Single Family Servicing and Single Family Claims
97-17
FHA Loss Mitigation - Clarification of Procedures (Attachment)
97-43
FHA Loss Mitigation - Mortgage Modification Clarifications
97-31
1997 Preservation and Protection/Post Endorsement Guidelines and Fee Schedules
96-66
Single Family Loan Production - Increase in FHA Maximum Mortgage Limits
96-65
Procedural Changes for Single Family Servicing and Single Family Claims
96-61
FHA Loss Mitigation Procedures - Special Instructions
96-49
Single Family Default Monitoring System (SFDMS) Status Code Changes
96-43
Mandate for Electronic Funds Transfer (EFT) for Single Family Claims
96-32
Loss Mitigation - Mortgage Modification
96-24
Termination of the Mortgage Assignment Program
96-16
1996 Preservation and Protection/Post Endorsement Guidelines and Fee Schedules
96-2
Single Family Loan Production - Increase in FHA Maximum Mortgage Limits
95-38
Single Family Servicing/Claims -- Correction of Erroneous ZIP Code in Handbook 4330.4 REV-1: "FHA Single Family Insurance Claims"
95-29
Foreclosure and Acquisition of Property Notice to Occupants of Pending Acquisition
95-25
1995 Preservation and Protection/Post Endorsement Guidelines and Fee Schedules
95-19
Comprehensive Update to the FHA Single Family Maximum Mortgage Limits

ATTACHMENT 2

SAMPLE LISTING OF MORTGAGEE SITES

Category /Size
Location
State
A
Des Moines
IA
A
Cincinnati
OH
A
Owensboro
KY
A
Troy
MI
A
Austin
TX

B

Lake Zurich
IL
B
Williamsburg
NY
B
Montgomery
AL
C
Tulsa
Ok
C
Casper
WY
C
Tupelo
MS
D
Providence
RI
D
Omaha
NE
E
Moor Park
CA
E
San Diego
CA

ATTACHMENT 3

TYPE OF CLAIMS

· 01—CONVEYANCE: The property is deeded/conveyed to HUD. The mortgagee transfers the property to HUD, usually after the mortgagee acquires it through foreclosure proceedings. Conveyances are paid in two parts. Part A of the Form HUD-27011 is filed first and is used to claim the unpaid loan balance. The Part B of a conveyance claim is filed after the designated M&M Contractor has approved the title evidence package and HUD Headquarters mails a title approval letter. The Part B declares expenses incurred by the mortgagee on the property, such as taxes, property preservation and protection expenses, and foreclosure costs. Conveyance claims result in the cancellation of FHA mortgage insurance.

· 02—ACD-601: Participating servicers in the Accelerated Claims Disposition (ACD) Demonstration (a pilot program) assign mortgage notes to HUD in return for insurance benefits. HUD continues to service the asset or disposes of the asset through other means. Form HUD 27011, Parts A and/or B, must be submitted together via EDI. ACD claims result in the cancellation of FHA mortgage insurance.

· 05—SUPPLEMENTAL CLAIMS: Supplemental claims are additional claims requesting adjustments and made relative to a prior claim submission. Mortgagees are allowed to file one supplemental claim up to six (6) months following the final settlement date of a claim (see Handbook 4330.4 for exceptions). Supplementals may be used to claim additional expenses or to adjust erroneous items on the original claim that could result in a mortgagee owing funds to HUD. Amounts due HUD are not subject to any time limitations. Form HUD 27011, Parts A and/or B, must be submitted together with supporting documentation.

· 06—Claims Without Conveyance of Title (CWCOT) The property deed passes to a third party. This claim type provides for the mortgagee to dispose of the foreclosed property without conveying title to HUD. Parts A and B must be submitted together; only one claim payment is made to the mortgagee. Non-conveyance claims result in the cancellation of FHA mortgage insurance.

· 07—PRE-FORECLOSURE SALE: The mortgagor sells the property before the mortgagee forecloses. Under certain circumstances, this claim type is used when the property’s fair market value is less than the outstanding indebtedness. HUD preauthorizes the terms of the sale and the minimum sales price, and the mortgagor attempts to sell the property. If the property is sold, a foreclosure is avoided and the mortgagee may file a claim to recover the difference between the sales proceeds and the total indebtedness (24 CFR 203.370). Pre-Foreclosure sale claims result in the cancellation of FHA mortgage insurance.

· 20-24—HOME EQUITY CONVERSION MORTGAGE: Home Equity Conversion Mortgages (HECMs) are also known as reverse mortgages. The mortgagee may submit a HECM assignment claim (type 22) when the outstanding principal balance is at 98% of the maximum claim amount or when a request for a line of credit draw will cause the outstanding principal balance to equal or exceed 98% of the maximum claim amount. A mortgagee may submit a foreclosure or deed-in-lieu claim (type 21) if the mortgage becomes due and payable under the circumstances noted at 24 CFR 206.27 (c). Likewise, a mortgagee may submit a mortgagor’s sale claim (type 23) under the conditions described at 24 CFR 206.125 (c). Parts A and B, Form HUD-27011 are submitted concurrently for each HECM claim type. A supplemental claim (type 24) may be submitted to recover approved amounts not claimed in the original HECM claim submission.

· LOSS MITIGATION CLAIMS: Claim types 31, 32, and 33 are reinstatement options for forward mortgages under the Department’s loss mitigation program and are considered home retention tools. These claim types are used in situations where the mortgagee considers the cause of the default to be curable and the borrower is committed to remaining in the home. Loss Mitigation Claims do not cause the cancellation of FHA mortgage insurance.

· 31—SPECIAL FORBEARANCE AGREEMENT: This type of claim provides for an incentive payment to mortgagees for entering into a written special forbearance agreement with a mortgagor containing a plan to reinstate a loan that has been delinquent for at least 90 days (24 CFR 203.614).

· 32—LOAN MODIFICATION: This type of claim provides for an incentive payment to mortgagees for making a permanent change in one or more of the terms of a borrower’s loan that, if made, allows the loan to be reinstated and results in a payment the borrower can afford (24 CFR 2033616).

· 33—PARTIAL CLAIM: Under this type of claim, the mortgagee receives an incentive payment (and the amount of the advance) for advancing funds on behalf of a borrower in an amount necessary to reinstate a delinquent loan not to exceed the equivalent of 12 months PITI. The borrower, upon acceptance of the advance, will execute a promissory note and subordinate mortgage payable to HUD (24 CFR 203.371).

· FHA’s HOME AFFORDABLE MODIFICATION LOSS MITIGATION OPTION (FHA-HAMP): The objective of FHA-HAMP is to assist FHA mortgagors who are in default to modify their mortgage to an affordable payment. A HAMP partial claim up to 30 percent of the unpaid principal balance as of the date of initial default may be used as a stand-alone option or in combination with a HAMP loan modification.

Note: FHA may develop additional loss mitigation options to assist mortgagors in retaining their homes, under pending legislation related to the existing foreclosure situation and also related to mortgagors in bankruptcy. After training, provided by FHA, the Contractor will be expected to perform post claim reviews on these new types of claim options.

ATTACHMENT 4

CLAIM REVIEW SIZE DESCRIPTION

1. Post Claim Reviews and Technical Support

For the purpose of this task, HUD anticipates that at the time of the contract award, the following determination of review size will be used to establish the appropriate statistical criteria. The number of claims to be reviewed will be based on a 95 percent confidence level, with a confidence interval no greater than 5 percent. The Contractor shall provide to the GTR/GTM a schedule for approval showing the number of claim files to be reviewed to attain the desired 95 percent confidence level/5 percent confidence interval based on the review sizes indicated below. Note that findings identified in the directed sampling will not be extrapolated but will be included as hard dollars in the monetary findings.

· Extra Large (Size A). Mortgagees that have submitted 2,000 or more claims since the ending date of the most recent post claim review. This review will also include 20 Loss Mitigation Home Retention Claims. HUD, at its discretion, may identify up to 12 cases as directed reviews in addition to the number of cases identified under the Audit Plan for this review size. In addition, HUD may elect to expand a review if the initial evaluation of cases in the sample indicates a potential for errors resulting in over claimed amounts that exceed HUD’s threshold for tolerance.

· Large (Size B). Mortgagees that have submitted between 500 and 1,999 claims since the ending date of the most recent post claim review. This review will also include 16 Loss Mitigation Home Retention Claims. HUD, at its discretion, may identify up to 10 cases as directed reviews in addition to the number of cases identified under the Audit Plan for this review size. In addition, HUD may elect to expand a review if the initial evaluation of cases in the sample indicates a potential for errors resulting in over claimed amounts that exceed HUD’s threshold for tolerance.

· Medium (Size C). Mortgagees that have submitted between 100 and 499 claims since the ending date of the most recent post claim review. This review will also include 10 Loss Mitigation Home Retention Claims. HUD, at its discretion, may identify up to 10 cases as directed reviews in addition to the number of cases identified under the Audit Plan for this review size. In addition, HUD may elect to expand a review if the initial evaluation of cases in the sample indicates a potential for errors resulting in over claimed amounts that exceed HUD’s threshold for tolerance.

· Small (Size D). Mortgagees that have submitted between 50 and 99 claims since the ending date of the most recent post claim review. These reviews do not require travel to the mortgagee’s site. The mortgagee will send copies of requested claims documentation to the Contractor. This review will also include 6 Loss Mitigation Home Retention Claims. HUD, at its discretion, may identify up to 8 cases as directed reviews in addition to the number of cases identified under the Audit Plan for this review size. In addition, HUD may elect to expand a review if the initial evaluation of cases in the sample indicates a potential for errors resulting in over claimed amounts that exceed HUD’s threshold for tolerance.

· Extra Small (Size E). Mortgagees that have submitted between 1 and 49 claims since the ending date of the most recent post claim review. These reviews do not require travel to the mortgagee’s site. The mortgagee will send copies of requested claims documentation to the Contractor. This review will also include 2 Loss Mitigation Home Retention Claims. HUD, at its discretion, may identify up to 5 cases as directed reviews in addition to the number of cases identified under the Audit Plan for this review size. In addition, HUD may elect to expand a review if the initial evaluation of cases in the sample indicates a potential for errors resulting in over claimed amounts that exceed HUD’s threshold for tolerance.

· Expanded Reviews. This category/size refers to the expansion of an initial review IF a valid statistical determination of findings cannot be achieved under the above categories. Based on the Contractor’s recommendation, HUD may authorize a request for additional claim files to develop a more accurate statistical determination of findings. Under these circumstances, HUD requests the mortgagee to send copies of such claims to the Contractor; however, HUD may authorize travel, depending on the number of additional files to be included in the expanded review.

· Reviews for Claim Types. At HUD’s direction, paid claims may be reviewed by specific claim type. As part of its proposal, the Contractor must provide HUD the cost to perform reviews by specific claim type based on the number of claims reviewed.

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