I guess the FDIC better update their information:https://www.fdic.gov/regulations/compliance/manual/pdf/V-4.1.pdf
Timing of Notice
The notice must be given to a delinquent homeowner borrower no later than 45 days after the date on which the homeowner becomes delinquent. If, within the 45-day period, the borrower brings the loan current again, no notification is required.
I would also have to say that HUD has no ability to issue a mortgagee letter and set such requirements as the "law" requires the "The Secretary shall issue any regulations that are necessary to carry out this subsection." under 12 U.S.C. 1701x (c)(7). A mortgagee letter is not regulation as it didn't go through the vetting process.
The secretary also has no authority to set a 32 day minimum past due status before sending the notice as the law says "Notification under subparagraph (A) shall not be required with respect to any loan for which the eligible homeowner pays the amount overdue before the expiration of the 45-day period under subparagraph (B)(ii)."
Who in their right mind sends a past due notice to a customer between 32 and 45 days past due. These people are so out of touch.
I think someone needs to call them on all of this.