Government Shutdown Update
At 12:01 AM Saturday December 22, 2018 the US Government has partially shut down due to the expiration of the nation’s spending authority. Due to this shutdown, some government agencies and services are closed or suspended, including the IRS and Social Security Administration. Below is a brief summary of the impact as a result of the shutdown.
- The FHA offices will be operating under a limited staff. Expanded turn times should be anticipated when contacting these agencies. In general, FHA systems (such as FHA Connection, CHUMS, etc.) will be operational; however, actions that require intervention by FHA personnel will either be delayed or suspended. Below are some of the common FAQs. Answers to additional FAQs can be found via the following link: HUD Government Shutdown FAQ
- The Office of Single-Family Housing will endorse new loans, except for (HECM) and Title I loans.
- FHA will support manual endorsement actions including case number cancellations, case number reinstatement, case number transfers, and resolution of the hold tracking queue;
- CAIVRS will be available. However, FHA may not be able to ensure that the
information contained in the system is up-to-date and may have limited staff to answer questions related to the efficacy of specific borrower data in CAIVRS; and
- While FHA staff will not be available to process condominium project approvals under the HUD Review and Approval Process (HRAP), lenders will be permitted to continue processing condominium approvals under the Direct Endorsement Lender Review and Approval Process (DELRAP).
VA is covered by an appropriation bill that has already passed. As a result, VA will remain open with no impact.
As a result of the shutdown, USDA will be unable to issue new conditional commitments during a shutdown. While lenders are permitted to close loans with outstanding commitments, USDA will also be unable to guarantee them until staff return to work.
- Loans without a commitment issued will not be able to fund
FANNIE/FREDDIE & NON-AGENCY:
These entities will operate as they normally due without impact from the shutdown, however requirements regarding 4506T tax transcript requirements will be impacted by the shutdown of the IRS.
4506T Tax Transcripts:
Orders for tax transcripts should continue to be placed and will be submitted by our vendors, however they will not be processed at the IRS until the shutdown is over and the expectation is that orders will be completed on a first in basis. Until such time that transcript orders resume normal processing the following actions will apply:
- Conventional, FHA, VA and USDA loans may close without transcripts during the government shutdown and until such time normal processing times are achieved following the end of the shutdown. Conditions may be waived for the transcripts.
- Non-Agency and Bond/HFA loans may close without transcripts; however, transcripts will be required for delivery to the applicable investor. Conditions for transcripts should be set to “Prior to Investor”.
- Credit policy will provide additional updates and guidance when standard guideline application of transcripts will resume following the end of the shutdown.
National Flood Insurance Program (NFIP):
- President Trump signed an extension on Saturday December 22nd which extends the program through May 31, 2019. As a result, there is no impact to the NFIP as a result of the shutdown.
Verbal Verification of Employment:
- For borrowers employed by the federal government where a verification of employment (VOE) cannot be obtained, the seller may obtain the VOE after closing but prior to loan delivery. If the VOE cannot be obtained prior to delivery, the loan will be ineligible for purchase.
We will continue to monitor the shutdown and provide updates on any new or existing impacts that may occur as additional information is learned.