Housing and Urban Development Department
FHA INFO 2025-54: FHA Seeks Feedback on Proposed Updates to its Requirements for the Use of Independent Third-Party Providers in Connection with Claims Without Conveyance of Title
December 4, 2025
Summary
FHA posted draft ML 2025-54 proposing to revise CWCOT (Claims Without Conveyance of Title) rules by limiting the ban on affiliate/subsidiary third-party providers to affiliates of the mortgage holder only, thereby allowing servicers to use their own affiliates. The draft is open for public comment through January 19, 2026, and is not official policy until finalized; current restrictions remain in effect. This is a proposed change, not an adopted rule, so no compliance obligations change today.
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December 4, 2025 - Today, the Federal Housing Administration (FHA) posted a draft Mortgagee Letter (ML), Use of Independent Third-Party Providers in Connection with Claims Without Conveyance of Title (CWCOT), for review and feedback on FHA’s Office of Single Family Housing Drafting Table (Drafting Table) web page. This draft ML proposes updates to policies related to the use of independent third-party providers in connection with foreclosure and post-foreclosure sales, and the marketing of the properties during the CWCOT process.
Currently, FHA policy does not allow third-party providers in CWCOT transactions to be an affiliate or subsidiary of the mortgagee. This term includes both mortgage servicers and mortgage holders. Upon further review, FHA has assessed that its current policy restrictions may be unduly burdensome. With this proposed ML, FHA proposes a revision of its policy to limit the restrictions on the use of affiliate or subsidiary third-party providers to the affiliates or subsidiaries of the mortgage holder only. This change, if implemented, aligns with the Administration’s overarching goals of reducing restrictions on industry partners, increasing competition, reducing costs and making it easier to do business with FHA.
Interested stakeholders are encouraged to thoroughly review this draft ML and provide feedback through January 19, 2026, using the feedback instructions posted on the Drafting Table. FHA will carefully consider all feedback received before publishing a final ML.
As a reminder, this draft is not official departmental policy and cannot be used in connection with any FHA-insured mortgage until finalized. FHA’s existing policies remain in effect until amended.
Mortgagees and other parties interested in FHA transactions should contact the FHA Resource Center (referenced below) with questions.
Source: https://www.hud.gov/hud-partners/single-family-fha-info#fha-info-2025-54
Common questions
- What does "FHA INFO 2025-54: FHA Seeks Feedback on Proposed Updates to its Requirements for the Use of Independent Third-Party Providers in Connection with Claims Without Conveyance of Title" cover?
- FHA posted draft ML 2025-54 proposing to revise CWCOT (Claims Without Conveyance of Title) rules by limiting the ban on affiliate/subsidiary third-party…
- Which agency issued this update?
- This update was issued by Housing and Urban Development Department.
- When was it published?
- It was published on December 4, 2025.