Looks like the public outcry has FHA rethinking their position. Note in bold–wording regarding seeking additional input.
Posted as an FHA notice late April 6:
In order to allow Mortgagees additional time to adapt their procedures to implement portions of the new guidance found in Mortgagee Letter 2012-03 (ML 2012-03), FHA is delaying the effective date of the following topics from ML 2012-03:
- Handling of Disputed Accounts, Public Records FHA Total User Guide Chapter 2, and
- Handbook 4155.1 4.C.2.e, Paying off Collections and Judgments.
The new effective date of this section is delayed until July 1, 2012. Prior to the effective date, FHA intends to seek additional input on this section and work to clarify guidance, as appropriate.
The Mortgagee Letter and FHA Total Scorecard User Guide will be updated and posted to HUD’s website on Monday April 9, 2012. Please Note: With this extension, any case numbers assigned prior to July 1, 2012 are subject to the previous guidance in effect for the subject topics.