Preliminary Privacy Impact Assessment - CHUMS

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TITLE: Computerized Homes Underwriting Management System (CHUMS)

September, 2003

UPI # 025-00-01-01-01-1110-00-206-085

PCAS # 251400

Is this a new or substantially revised electronic information system? If revised describe revisions.

If any question does not apply, state not applicable (N/A) for each question and explain why.

I. Describe the information to be collected (e.g., nature and source). Be sure to include any information in an identifiable form, (e.g., name, address, social security number or other identifying number or code, telephone number, email address, etc).

FHA approved lenders collect personal data as an integral part of a loan application. Data collected includes the personal information mentioned above, with the exception of individual email addresses.

II. Why is the information being collected (e.g., to determine eligibility)?

In order to establish the creditworthiness of a borrower, lenders must review personal financial and employment related information to determine a borrowers' eligibility for FHA insured financing. Through underwriting, it is essential to safeguard the solvency of the FHA insurance funds.

III. How will the information be used (e.g., to verify existing data)?

The information is used to verify income and work history and other factors necessary to ensure accurate and complete underwriting of FHA loans.

IV. Will you share the information with others (e.g., another agency for a programmatic purpose)? If yes, list the entities.

HUD's policy is to protect the privacy of personal information collected in the loan origination and underwriting process. Only approved FHA lenders may access the system and view information regarding loans they have an interest in.

V. Describe what opportunities individuals have been given to decline to provide information or to consent to particular use of the information (e.g., whether an individual may withhold permission for a particular use).

FHA borrowers apply for insured financing as part of the agreement to purchase a home. A complete application is required for borrowers wishing to refinance existing FHA loans, as well. Borrowers are aware that a loan application requires the disclosure of personal information.

VI. How will the information be secured (e.g., administrative and technological controls)?

The CHUMS mainframe resides behind a firewall. Only approved HUD staff with proper User IDs have access to files. ID security is maintained by HUD and access levels are controlled as appropriate for each user.

VII. How will the data be retrieved (e.g., will it be retrieved by a personal identifier such as name, social security number, address, telephone number or some other identifier that is unique to an individual)?

CHUMS users most often retrieved data by FHA Case Number. However, when necessary, data can be accessed by personal identifiers.