NRMLA Suggests Improvements to Defect Taxonomy and Form 92900-A

NRMLA Suggests Improvements to Defect Taxonomy and Form 92900-A

NRMLA submitted two letters to the Department of Housing and Urban Development this past week that recommended adding HECM-specific improvements to FHA’s Defect Taxonomy and Addendum to the Uniform Residential Loan Application (Form 92900-A).

NRMLA commended HUD on its efforts through Defect Taxonomy to provide more clarity and transparency into FHA’s existing loan-level quality assurance processes. However, Defect Taxonomy does not accurately or sufficiently address the origination and servicing requirements for FHA-insured HECMs, said NRMLA. “Therefore, we respectfully request that HUD revise the proposed Defect Taxonomy to include additional and accurate examples of potential loan-level defects and remedies that apply to HECM loans.”

In the second letter, NRMLA requested that HUD clarify that HECM Mortgagees are not required to certify to FHA requirements and sections of the Single Family Housing Policy Handbook 4000.1 that are not applicable to reverse mortgages. In addition, NRMLA proposed that Part II of Form 92900-A be revised to allow non-borrowing spouses to provide their consent for the Social Security Administration to verify their Social Security Number since HECM mortgagees are required to verify this information.

“Further, in order to provide accurate information to HECM borrowers, we request that the Caution: Delinquencies, Defaults, Foreclosures and Abuses section in Part III of Form 92900-A be revised because certain statements provided in that section do not apply to HECM borrowers and could potentially mislead seniors,” added NRMLA.

Both letters can be read in their entirety by logging into the Comment Letters section of