The federal checklist is gone — the liability isn't In September 2025, HUD withdrew FHEO Notices 2020-01 and 2013-01, the checklist defense counsel relied on for years. Yet 24 C.F.R. §§ 100.202(d) and 100.204 remain fully in force. DOJ enforcement continues through settlements like Estrada, Gregory Estates, and Menendez. The stakes are already concrete.…