The General Services Administration (GSA), an agency of the U.S. government designed to help manage and support the basic functioning of federal agencies, has announced that all companies and entities currently conducting or seeking to do business with the federal government must have a Unique Entity Identifier (UEI) registered in GSA’s System of Award Management (SAM.gov).
This includes all lenders, mortgagees, and institutions approved by the Federal Housing Administration (FHA). The requirement was announced in Mortgagee Letter (ML) 2022-14 on Tuesday, and may be implemented immediately but must be complete no later than December 31, 2022. FHA explained that the new requirement will be incorporated into a future version of the Single Family 4000.1 Handbook at a later date.
Compliance purposes
As a component of the new ML, FHA explains that one of the reasons this requirement has been implemented is to shore up its ability to remain compliant with previously-established laws.
“The UEI is an alpha-numeric identifier used by federal government agencies to maintain consistent name and address data about non-federal entities doing business with the government,” the ML explains. “An active SAM.gov registration and UEI is vital to HUD’s compliance with the Federal Funding Accountability and Transparency Act of 2006, as amended by the Digital Accountability and Transparency Act of 2014 which require[s] federal agencies to report data about federal awards and which are tracked using the UEI.”
The actual move to requiring UEI began a few years ago, with the 2014 law adding a provision specifically for mortgage entities to the Code of Federal Regulations (CFR).
“The federal government began transitioning to the UEI in July 2019, requiring all recipients of Federal funding to obtain a unique identifier,” the ML reads. “The definition of award types was expanded to include loans, insurance and loan guarantees with the release of 2 CFR part 25, extending the requirement to obtain a UEI and register in SAM.gov to Mortgagees and institutions seeking FHA approval as a Mortgagee.”
An active UEI will be required for all entities aiming to do business with FHA as part of their institution data in the Lender Electronic Assessment Portal (LEAP) or application for FHA approval, according to the publication of the ML.
While the requirement for establishing an active UEI is December 31, the ML also explains that a public comment period will be open for 30 days after the issuance of the new guidance, which in this case falls on September 22, 2022. Any feedback is instructed to be directed to the FHA Resource Center.
Making requested changes
In order to become compliant with the new guidance, all entities seeking to conduct business with the federal government broadly and FHA specifically will have to register a UEI. Instructions for how to accomplish this are posted on SAM.gov.
“While the deadline to input the UEI is December 31, 2022, Mortgagees may enter the identifier in LEAP as soon as it is received from SAM.gov,” the ML reads. “For detailed instructions on inputting the UEI in LEAP, please review Section 5.1 of the LEAP User Manual.”
Read ML 2022-14 at the U.S. Department of Housing and Urban Development (HUD) website.
