On December 19, 2022, the Federal Housing Administration (FHA) issued an additional extension of the temporary waiver of face-to-face contact required under 24 CFR § 203.604 Contact with the Mortgagor, under Mortgagee Actions under Subpart C – Servicing Responsibilities of 24 CFR Part 203 Single Family Mortgage Insurance.
Pursuant to 24 CFR § 203.604, a “mortgagee must have a must have a face-to-face interview with the mortgagor, or make a reasonable effort to arrange such a meeting, before three full monthly installments due on the mortgage are unpaid.”
FHA originally issued an initial partial waiver of the face-to-face requirement in March 2020 as a result of the Coronavirus Disease 2019 (COVID-19) pandemic. FHA previously extended the wavier through December 31, 2022 and has now extended it through December 31, 2023. According to the FHA, the extension of the partial waiver of required face-to-face contact is due to continued public health concerns surrounding the spread of COVID-19, Respiratory Syncytial Virus (RSV) and increased rates of the seasonal flu. FHA also considered the impact of inflation and the current job market on servicer staff and resources.
The partial extension allows mortgagees to utilize alternative means to meet the requirements of 24 CFR § 203.604, such as conducting phone interviews, e-mail, video calling services (e.g., Skype, Zoom, WebEx, Microsoft Teams, etc.) and other conferencing technology. In the recent waiver, FHA noted that the use of technology during the pandemic has been “successful in achieving the same goals as a face-to-face interaction thereby eliminating the need to take the risky step of returning to requiring in person contact.”
Mortgagees are required to document their contact with the borrower, noting the alternative methods of contact used. Further, the partial waiver does not apply to 24 CFR § 203.604(e)(1) governing the Section 248 insurance program.