FHA has proposed to shift the obligations for mortgagees to certify that they have upheld all legal requirements from the loan-level certification to the initial and annual lender level certification requirement. In principle, we are not opposed to shifting the placement of these requirements, so long as FHA vigorously enforces these requirements and upholds the need to provide timely annual updates to their certifications and timely review and processing if and when a lender falls out of compliance with the certification requirements.
