As previously discussed HUD released a list of Frequently Asked Questions and provided answers clarifying new P&P guidelines released in ML 2007-03.

Following is a summary of the key clarifications included in the update.

On November 14, 2007 HUD posted a FAQ sheet in response to common questions surrounding the release of ML 2007-03 in April of 2007.  The FAQ sheet is posted on HUD's website on the P&P Questions and Answer page.
 
The FAQ sheet clarifies many of the topics discussed during industry conferences and calls, several of which pertain to P&P allowables and reimbursement:
 
G4 - Work completed prior to obtaining over allowable approval is claimable as a reimbursable expense.  HUD recognizes the servicer's prudence in completing work that requires immediate resolution.
 
G5 - Monthly inspections completed outside of the 25-35 day timeframe are reimbursable up to 15 inspections per 12 month period. If the inspection was completed after the 35th day the mortgagee will be at risk for failure to preserve and protect the property and may be held liable for resulting damages.
 
B1 - Servicers are approved to use the $550 emergency boarding allowable in areas where local ordinances and codes require boarding.  Servicers are not required to submit an over allowable request if the boarding can be completed within the $550 allowable.
 
D5 - HUD recognizes that individual dump receipts are not always available on each individual property and authorizes the servicer to provide a complete audit trail in lieu of a receipt from the dump facility. The audit trail must contain the name, address and phone number of the dump facility, date of disposal, number of cyds, and description of each hazardous item disposed of.
 
O1 - Email is an acceptable method by which to submit over allowable requests to the M&M Contractor.  Servicers should coordinate the appropriate email addresses with the applicable M&M Contractors.
 
P4 - Work completed prior to the effective date of ML 2007-03, April 30, 2007, is claimable under either the ML 2002-10/2003-05 or ML 2007-03 regulations.  This applies to claims submitted after May 30, 2007.
 
A1 - The GTR is required to respond to appeals within 5 business days of receipt of the request.
 
W2 - The heat is not to remain on for wet winterizations unless the state/regional variations specifically states the requirement.
 
Safeguard recognizes the clarifications provided as industry best practices.  HUD continues to issue guidelines and guidance to the industry representing the servicers and HUD's best interest in maintaining property condition and values. 

About Safeguard
Safeguard Properties is the largest privately held field services company in the country. Located in Cleveland, OH  and founded in 1990 by Robert Klein, Safeguard has grown from a regional preservation company with a few employees and a handful of contractors performing services in the Midwest, to a national company with over 450 employees.  Safeguard is supported by a nationwide network of subcontractors able to perform any requested superintendence, preservation, and maintenance functions, as well as numerous ancillary services in the U.S., the Virgin Islands, and Puerto Rico.