Mortgage Servicing and Loan Modifications: 12.1.4.1.7 Overpayments and recoupment
The third stage of FEMA legal issues involves FEMA repayment demands and recoupments (federal collections) for overpayments.80 Any improper financial payment to an applicant is referred to as an overpayment, whether it refers to a portion of the FEMA award or the entire FEMA award. These issues arise about four months to one year after the disaster and continue for up to three years or longer.