U.S. Department of Housing and Urban Development
Office of Inspector General for Audit, Region V
Ralph H. Metcalfe Federal Building
77 West Jackson Boulevard, Suite 2646
Chicago, Illinois 60604-3507
Phone (312) 353-7832 Fax (312) 353-8866
Internet http://www.hud.gov/offices/oig/
MEMORANDUM NO.
2005-CH-1802
March 31, 2005
MEMORANDUM FOR: John W. Herold, Associate General Counsel for Program
Enforcement, CE
FROM: Heath Wolfe, Regional Inspector General for Audit, 5AGA
SUBJECT: Actions Under Program Fraud Civil Remedies Act
AIM Financial, Inc.
Kentwood, MI
INTRODUCTION
We completed a review of AIM Financial, Inc. (AIM), a former non-supervised loan
correspondent approved to originate Federal Housing Administration-insured loans. We
initiated our review based on a citizen complaint to our office. The review objective was to
determine whether AIM originated Federal Housing Administration-insured loans according
to the U.S. Department of Housing and Urban Development’s (HUD) requirements.
METHODOLOGY AND SCOPE
We performed file reviews of 26 selected loans and completed interviews with borrowers
to determine if AIM originated loans in accordance with HUD’s requirements. We
interviewed HUD’s staff, current and former staff of AIM, and former staff members of
Bedford Financial, Inc. (Bedford), a Federal Housing Administration loan correspondent. We
reviewed HUD’s Federal Housing Administration case binders and Single Family Mortgage
Insurance Program’s loan origination procedures, and AIM’s files. We verified the
borrowers’ employment and bank accounts, and interviewed the borrowers for 23 of the 26
loan files reviewed.
Our review covered the period January 1, 1998, through September 30, 2000. We extended
the review coverage as necessary. We conducted the review at HUD’s Grand Rapids Field
Office and AIM’s office from November 2000 through April 2002.
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Audit Memorandum
AIM is located at 4595 Broadmoor Avenue Southeast, Kentwood, MI. The President of
AIM Financial is Jeffry Baum.
BACKGROUND
HUD’s program involved in this review is the Title II Single Family home loan insurance
program. Pursuant to the National Housing Act, HUD has the authority to guarantee single-
family home loans. HUD’s Secretary is authorized and empowered to approve lenders who
are responsible and able to originate, underwrite, and service Federal Housing Administration-
insured single-family home mortgages. Through the Direct Endorsement program, HUD
approves mortgages to process and approve loans to borrowers.
HUD requires, as part of the loan origination and approval process, that the lender complete a
“Lender Certification” which is Part II of HUD form 92900A. By signing the Lender
Certification, the lender certifies that the loan terms furnished in the Uniform Residential Loan
Application are true, accurate, and complete. The Certification also states the information
contained in the loan application was obtained directly from the borrower by a full-time
employee of the undersigned lender or its duly authorized agent, and is true to the best of the
lender’s knowledge and belief. On this form, the lender’s representative must also certify that
mortgage loan documents, closing statements, application for insurance endorsement, and all
accompanying documents have been personally reviewed and make all certifications required
for the mortgage as set forth in HUD Handbook 4000.4.
RESULTS OF REVIEW
Our review determined that AIM, although at one time a Federal Housing Administration
approved lender, had, prior to its approval, originated Federal Housing Administration-insured
loans using the name and Federal Housing Administration number of another lender. AIM
executed HUD form 92900A for 10 insured loans, the earliest executed on January 22, 1999,
falsely certifying it was Bedford. At that time, Bedford was a Federal Housing Administration
approved lender, while AIM was not. In each of the 10 cases, AIM executed the Lender
Certification and Lender’s Certificate using Bedford’s name, address, and its Lender
Identification Code. AIM later obtained approval to originate Federal Housing
Administration-insured loans, which lasted from September 29, 1999, through July 15, 2002.
On July 29, 2003, we referred AIM to HUD’s Office of General Counsel for administrative
sanctions under the Program Fraud Civil Remedies Act of 1986. HUD filed a complaint
against AIM on February 18, 2005, seeking civil penalties. HUD executed a settlement
agreement with AIM effective March 28, 2005, without any admission of wrongdoing, for
$35,000. AIM issued a check payable to HUD dated March 24, 2005 for the $35,000
settlement amount.
RECOMMENDATION
We recommend that HUD’s Associate General Counsel for Program Enforcement:
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Audit Memorandum
1A. Posts the $35,000 settlement payment to HUD’s Audit Resolution and Corrective
Actions Tracking System.
We posted the settlement payment to HUD’s Audit Resolution and Corrective Actions
Tracking System. Therefore, no action is required and a management decision will be
concurrent with the issuance of this audit memorandum and final action.
Schedule Of Ineligible Cost 1/
Recommendation
Number Amount
A $35,000
Total $35,000
1/ Ineligible costs are costs charged to a HUD-financed or HUD-insured program
or activity that the auditor believes are not allowable by law; contract; or
Federal, State, or local policies or regulations.
If you or your staff has any questions, please contact Tom Towers, Assistant Regional
Inspector General for Audit, at (313) 226-6280, extension 8062 or me at (312) 353-7832.
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Actions Under Program Fraud Civil Remedies Act; AIM Financial, Inc.; Kentwood, MI
Published by the Department of Housing and Urban Development, Office of Inspector General on 2005-03-31.
Below is a raw (and likely hideous) rendition of the original report. (PDF)