What are the requirements for a Closing Agent to be approved to close HUD REO sale transactions?

In order to conduct a closing on a sales transaction for a HUD REO Property, the Closing Agent must be an attorney, title company, or escrow company that meets all State and local requirements for eligibility to conduct closings as follows:

  • An attorney or law firm may act as Closing Agent if they are duly licensed to practice law in the State where the Property is located and state law allows an attorney to facilitate closings.
  • A title company may act as Closing Agent if they are duly licensed to do business in the State where the Property is located and are regulated by the state insurance commission, or similar regulatory agency recognized by the State.
  • An escrow company may act as Closing Agent if they are duly licensed to do business in the State where the Property is located and meet all state legal and regulatory requirements as a recognized and registered escrow company.
  • The Closing Agent is covered by errors and omissions insurance of at least $1,000,000.

 A Closing Agent cannot participate in any aspect of the closing or title clearance process if they are currently debarred, suspended, or otherwise excluded from participating in HUD’s programs.
 
The Closing Agent must complete a one-time registration to receive a HUD-issued Title ID Number.  The Closing Agent must provide to the Asset Manager (AM):

  • a copy of the Closing Agent’s state license; and
  • a Closing Protection Letter (CPL) evidencing errors and omissions insurance coverage.

 HUD will review the closing agent’s documentation and, if HUD approves, HUD will issue a Title ID Number. The AM will notify the Closing Agent of the issuance of the Title ID Number.
 
Once the Closing Agent has received a HUD-issued Title ID Number, the Closing Agent must contact the AM to request access to P260. The P260 is HUD’s web-based portal that must be used to upload closing information requested by the AM.
 
For additional questions, please contact the AM. To locate the AM contact information, please go to the HUD HomeStore website at:  http://www.HUDHomestore.com
 
Information on P260 is available at: https://www.hudp260.com/Pages/Resources/hudtraining_mm3_portal.aspx
 
See policy in Handbook 4000.1 Section I.B.6 at: https://www.hud.gov/program_offices/administration/hudclips/handbooks/hsgh

HQ Policy Determination


All policy information contained in this knowledge base article is based upon the referenced HUD policy document. Any lending or insuring decisions should adhere to the specific information contained in that underlying policy document.


Topic Number: KA-03632