FHA Recertification Process – Unique Entity Identifier Renewal Reminder

Most, if not all, Federal Housing Administration (“FHA”) mortgagees are now familiar with the US Department of Housing and Urban Development’s (“HUD”) requirement, previously announced in Mortgagee Letter 2022-14, that all FHA-approved mortgagees must have registered for and obtained an active Unique Entity Identifier (“UEI”) at www.sam.gov and input that UEI into HUD’s Lender Electronic Assessment Portal (“LEAP”) on or before December 31, 2022. That Mortgagee Letter did not, however, include details regarding the process that an FHA-approved mortgagee must complete annually to renew its UEI to maintain its active status.

In a recent webinar covering HUD’s annual mortgagee recertification process, representatives of HUD’s Lender Approval Division advised FHA-approved mortgagees that each mortgagee will need to verify that it has renewed its UEI number through the System of Award Management (“SAM”). While a UEI number, once assigned, never expires, the UEI and SAM.gov system account registrations must be renewed annually. Specifically, an entity registration must be renewed every 365 days to remain active. If renewal is not completed on time, the system account will deactivate, and registrations will expire if not updated in a timely manner.

Importantly, an expired registration may affect the FHA-approved mortgagee’s ability to do business with the federal government, including HUD. As FHA-approved mortgagees with a fiscal year end date of December 31 are fast approaching FHA’s next annual renewal deadline, each FHA-approved mortgagee should check the status of its UEI and complete the SAM.gov UEI renewal process to ensure the mortgagee remains in active status and in compliance with HUD guidelines. Failure to obtain a UEI in active status during last year’s annual renewal process resulted in referrals to the Mortgagee Review Board, which could be the case for mortgagees who let the UEI active status lapse going forward.

FHA representatives stated during the webinar that HUD is working to create an interface with SAM.gov that will allow HUD to track each UEI’s expiration date in LEAP and generate electronic reminders for mortgagees; however, that system enhancement is not likely to be implemented before the end of the first quarter of 2024, when most mortgagees will have to complete their annual FHA recertification filings. In the meantime, the Federal Service Desk (“FSD”) (www.fsd.gov) provides helpful resources relating to the SAM.gov data services. Please see the FSD Knowledge Database for SAM.gov Data Services for more information and renewal instructions.