of 209

Mortgage Bankers Association Document Custodian General Training Session for GSEs

Published on March 2017 | Categories: Documents | Downloads: 7 | Comments: 0
27 views

Comments

Content

s Document Custody General lo c Training Session e w w
Presented by the Document Custody Sub-committee Education Workgroup

r u

r F e

u a

.c d

m o

to .S w

r o F p

w

r F Catch the Energy! re u s lo c re o F p to Release Your Potential! .S w w

u a

.c d

m o

General Training Session Objective

Did you know that Seattle is the home of where the FISH! Philosophy emerged from a film produced by John Christensen — current CEO of ChartHouse Learning — about Seattle's world-famous Pike Place Fish Market. Using the “FISH!” philosophy, it is our goal that in today’s session we will:
Have some fun

Make your day

Make a difference

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Session Agenda
Initial Certification Recertification Transfer Requirements Refreshment break Q&A

r o F Custodial Responsibilities p to Audit Tips and Most Common Findings .S Q & Aw w w

Annual or Recurring Reporting Requirements

c e

s lo

r AG F E reNDA u

u a

.c d

m o

Document Custody General Training Session

Today’s Speakers Are:

Lydia Thornton – Fannie Mae Tom Kumi – Ginnie Mae Kathleen Davidson – MPF Program with the Federal Home Loan Bank of Chicago Carole Andrade – Freddie Mac

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Document Custody General Training Session

Today’s Moderators Are:

w

r Angee Nolan – JP Morgan Chase F reInformation Linda Gentry – Stewart Mortgage u Linda Rogers- GMAC Banks Document Custodial o– l Division c Kelly Crunican- LaSalle Bank - Collateral Services re o F p to .S w w

u a

.c d

m o

Sample “Go Fish” Question

Ginnie Mae

Fannie Mae

Speaker Names

w w

to .S w

Tom Kumi

r o F p

c e

s lo

r u

Freddie Mac

r F e

u a

.c d

m o

MPF Program

Debra Thompson

Carol Andrade

Kathleen Davidson

Q & A Sessions

Q&A Sessions

c Questions Q&A Cards Are for Submitting re aisles Pass them towardo middle F p – We’ll Send Leave Business Card to Transcript. .S w w w

End of Phase 1 End of Phase 2 Stick to questions related to topics discussed

s lo

r u

r F e

u a

.c d

m o

Q&A CARD

TER-MI-NOL-O-GY

u etc. For today, ‘Agency’ = GSE, Investor, ra F re u Related Terms: s Ginnie Mae: ‘Issuer’ lo c Fannie Mae: ‘Lender’ re o Freddie Mac: ‘Seller/Servicer’ F MPF: ‘PFI’ (Participating Financial Institution) p to .S w w w

.c d

m o

w w

s Initial lo c re Certification o F p to .S w

r u

r F e

u a

.c d

m o

w w

to .S w

Initial r o Certification

Ginnie s o Mae l

r u

r F e

u a

.c d

m o

F p

c e

Ginnie Mae – Form Requirements

HUD11706 - Schedule of Pooled Mortgages

r Interest HUD11711A – Release of Security u s loand Agreement HUD11711B - Certification c re o F p to .S w w w

r F e

u a

.c d

m o

Ginnie Mae –

Initial Certification Procedures

Document Custodian Procedures:
Form HUD 11706:

Total number of loans reported = Collateral files received Completed for both issuer and custodian. Filed in related Pool Master File.

Form HUD 11711B:

w w

to .S w

Pool number = Ginnie Mae pool/loan package number on related form HUD 11706 Ensure one of the two boxes on the form has been checked. Verify original executed form HUD 11711A for any mortgages with a second-party security interest. Filed in related Pool Master File.

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Ginnie Mae – Initial Certification

When is the Initial Certification due to Ginnie Mae by the Custodian?
Ginnie Mae I and Ginnie Mae II Custom Securities:
No later than 2 business days from the settlement date. Settlement: 3rd business day

Ginnie Mae II Multiple issuer single family securities
No later than the date published by Ginnie Mae on its web site. M

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Ginnie Mae – Document Requirements
Original Note

Complete Endorsement Chain (Originator through pooling issuer to blank) Complete Assignment Chain (Originator to current Issuer or MERS) MOM Loans – No Assignments

r o Assumptions pF to Addendums, Riders, etc. .S w w w

c e

s lo

r u

r F e

u a

.c d

m o

Ginnie Mae – Document Requirements
Lost Instrument Bond with Limited Liability Requirements:

Name of issuer purchasing the bond Loan number of current issuer Name of original mortgagor Legal address of property Amount of bond Name of surety or insurance company (Obligor) Date bond executed by surety or insurance company Signature of representative for surety or insurance company Appropriate POA and certification as required by surety or insurance company

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Ginnie Mae - Data Verification
Mortgagor Name(s)

Property Address, City & State (No zip code!) (if property address is included on the note) Principal Loan Amount (alpha and numeric)

r o and last payment due dates) F Term of the loan (first p to .S w w w
P & I (alpha and numeric)

Interest Rate (alpha and numeric)

c e

s lo

r u

r F e

u a

.c d

m o

Ginnie Mae – Arm Data Verification Interest Rate Change Date Mortgage Margin

Interest Rate Cap Structure

r rate cap structure on the o correlate to Interest F p Note. to .S w w w

Pool type suffix on Form HUD 11706 must

c e

s lo

r u

r F e

u a

.c d

m o

Ginnie Mae – Note Endorsement

.c Complete chain of endorsements from the loan d u originator to the pooling issuer. ra by an Endorsement in blank and without recourse F re authorized officer of the issuer u s Facsimile signatures acceptable for endorsements: lo c re o F p to .S w w w

m o

Acceptable under the laws of the relevant jurisdiction in which the property is located. Not prohibited under the issuer’s corporate charter and bylaws Such signature authorized by Corporate Resolution Such signature be notarized when required by law

Ginnie Mae – Allonge Requirements
Allonges may be used:

u the Acceptable practice in the jurisdiction ina r which property is located. F re Allonges must be: u s Original lo Affixed (Stapled) to thec Note And clearly reference the Note re o the Allonge but such F Note may reference p required. reference is not to .S w w w

.c d

m o

Ginnie Mae – Electronic Documents

.c Proposed Minimum Functional Requirements: d u ra F re u s Prior to accepting an eNoteo l c re o F At the present p o time the only eRegistry that has been t Ginnie Mae is the MERS eRegistry evaluated by .S w w w
Registration Transfer Interface Identification Formal application submitted to Ginnie Mae Approval received to act as a Ginnie Mae approved eCustodian
®

m o

Ginnie Mae – Collateral Review Collateral Review:

Ensure presence, completeness, accuracy and correctness of required collateral documents.
Compliant with investor guidelines for delivery.

Complete chain of title from original lender to issuer. Verification of data agrees with form HUD 11706.

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

r Fannie Mae u c e s lo

r F e

u a

.c d

m o

w w

r Initial o F Certification p to .S w

Fannie Mae - Form Requirements

.c Fannie Mae Form 2005 (Schedule of Mortgages) d u ra F re u s lo c re o F p to .S w w w

m o

Initial certification occurs within MCCS or the Document Certification Application.

Fannie Mae –

Initial Certification Procedures

Document Custodian Procedures: Form 2005 – Schedule of Mortgages

Lender transmits schedule electronically to both Custodian and Fannie Mae simultaneously.

Custodian compares the Schedule of Mortgages to the documents:

c should review the The document custodian re mortgages in the pool o documents for the individual to ascertain: F p to .S w w w
Conformity to Fannie Mae's documentation requirements Properly executed Complete, and sufficient on their face.

To ensure the presence of required documents and Information on the documents corresponds to that on the Schedule.

s lo

r u

r F e

u a

.c d

m o

Fannie Mae –

Initial Certification Procedures

u Document custodian electronically ra F transmits its certification to Fannie Mae re u through the MORNET Custodian s Certification System lo the Document cor Certification Application. re o F p to .S w w w

.c d

m o

Fannie Mae - Document Requirements
Original Note Riders, Addendums, etc. Modifications, Assumptions, etc.

Complete Endorsement Chain (Originator to blank)

r o F Power of Attorney p to .S w w w

Original unrecorded Assignment to Fannie Mae (MERS – no assignment)

c e

s lo

r u

r F e

u a

.c d

m o

Fannie Mae - Allonge Requirements

.c Comply with State, County and Federal law d u ra Affixed (Stapled) F re u References the Note s lo c e rAcceptable Facsimile Signatures o F p to .S w w w
Preferred but not required Loan Amount Borrower or Address of Secured Property

m o

Requires Corporate Resolution – Held by Custodian Corporate Resolution must include the Officer’s Name(s) who facsimile signatures are authorized.

Fannie Mae – NY CEMA

.c d New York – Consolidation of Prior Notes u and Mortgages: ra F Fannie Mae requires: re u s lo c re o F are advanced: p If additional funds to .S w w w
Form 3172 Or an equivalent form that is Fannie Mae approved.

m o

A recorded (or certified copy) New York Consolidation, Extension and Modification Agreement

An assignment to Fannie Mae (unrecorded, but in recordable form) New Note and Mortgage

Fannie Mae -

Cooperative Share Loan Documentation

Co-Op Loans:

Lenders should contact their lead Fannie Mae regional office to determine specific cooperative share loan documentation requirements for cooperative projects located in most states.

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Fannie Mae –

NY Co-Op Loan Documentation

For share loans from cooperative projects located in New York:
Documentation required for initial certification:
Original recorded UCC-1 Original UCC-3 - Assignment of the UCC financing statement to Fannie Mae, in a recordable form but not filed Certificate of Stock, shares, membership certificate, or other contractual agreement evidencing ownership Original Co-op Recognition Agreement

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Fannie Mae –

NY Co-Op Loan Documentation

r F Required Documentation for Collateral File: re u s lo c re o F p to .S w w w

For share loans from cooperative projects located in New York:
Executed Blanket Assignment of the Co-op Recognition Agreement’s to Fannie Mae (Fannie Mae approved form) Original recorded Intervening Assignment of the UCC financing statement (UCC-3) (if applicable) Executed blank Stock Power Original Security Agreement Original Proprietary Lease or Occupancy Agreement Original Assignment of the Proprietary Lease or Occupancy Agreement, (if applicable) Original recorded Continuation Statement(s), (if applicable).

u a

.c d

m o

Fannie Mae - Data Verification
Property Address – City, State, Zip Original Loan Amount First Payment Date Original Note Rate

s Principal and Interest (P&I) lo c Amortization Type (if e applicable) r o Mortgage Loan Type Fmonths) Original Term p (in oDate (if applicable) t Balloon ‘Call’ .S w w w

r u

r F e

u a

.c d

m o

Fannie Mae - Arm Data Verification

.c All of the Fixed Rate Fields plus: d u ra Original Index Value (If First Interest Rate F Change Date applicable) re First Payment u Mortgage Margin s Change Date lo Interest Rate Ceiling c Lookback (May 2007) re Rounding (May 2007) Interest Rate Floor o ARM Plan Number, if F p present to .S w w w

m o

Fannie Mae - Interest Only Requirements

u applicable) All ARM Fields or Fixed Fields (as ra F Interest Only End Date re u s lo c re o F p to .S w w w

.c d

m o

Fannie Mae - Electronic Documents

Custodial Requirements:

w

r F Execute an Amendment to their Custodian e Agreement with Fannie Mae r u for s Training – certification guidelines lo eMortgage Notes through a consultation c process with Fannie Mae. re o F p to .S w w

u a

.c d

m o

Fannie Mae - Collateral Review

Data elements should match exactly what is printed on the Schedule of Mortgages.

r data delivered to Custodian must assure that u s the Fannie Mae is the same lo that was certified c data by the custodian. re o F p to .S w w w

r F e

u a

.c d

m o

Fannie Mae – Collateral Review Tips:

.c Custodial and Issuer Collateral Review Tips: d u ra F re u s lo c re o F p to .S w w w
Exception: Quality Control:

m o

Key Points per Required Documents – Custodians should have:
Clear policies and procedures. Understand Fannie Mae certification and custody guidelines. Documented policy and procedures for tracking and resolving exceptions. Issuers should work with custodians to clear exceptions quickly. Custodian must have a quality control program that addresses at the very least, certification, custody and release.

r Freddie Mac u c e s lo

r F e

u a

.c d

m o

w w

r oCertification F Initial p to .S w

Freddie Mac - Form Requirements
Selling System

Our primary delivery and certification tool 1034E: Selling System Schedule Or Note Delivery Cover Sheet

MIDANET® Deliveries

Used primarily for negotiated bulk deals 1034: Fixed-Rate Schedule 1034A: ARM Schedule 1034S: Custodian Certification Summary 1034SM: Custodian Certification Schedule for Multiple Contracts

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Freddie Mac - Form Requirements
Freddie Mac Form 1034E from the Selling System

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Freddie Mac - Initial Certification Process

.c Selling System Deliveries Certified by Custodian d u ra F Freddie Selling System Deliveries certified by re u Mac’s DCS s lo c re o F p to .S w w w

m o

Certification Status must be updated in the system no later than 8:00 p.m. eastern time.

Form 1034E and the notes must be delivered to DCS no later than 12:30 p.m. eastern time on the final delivery date and certification must be entered in the system no later than 8:00 p.m. eastern time.

Freddie Mac – Initial Certification Process

When is Initial Certification due to Freddie Mac by the Custodian? All loan data and documentation is complete

Certification by approved Custodian or Freddie Mac Freddie Mac has taken possession of all data, documentation and/or information required for submission Midanet® Deliveries
Form 1034S or 1034SM delivered to Freddie Mac by 12:30 p.m. eastern time on the final delivery day for the Guarantor; on the prior day to be requested funding for Cash

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Freddie Mac - Initial Certification Process
Custodian must verify the following requirements have been met:
Loan Data:

Note = Data in the Selling System or MIDANET® and Forms 1034E, 1034 and 1034A. The Custodian is not required to verify the Seller/Servicer Loan Number.

Freddie Mac Acceptable Endorsements

w w

to .S w

Custodian must verify that the chain of endorsements is proper and complete from the original payee on the Note to the Seller delivering the Note to Freddie Mac and that the final endorsement is the blank endorsement from the Seller to Freddie Mac.

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Freddie Mac – Initial Certification Process

.c d Custodian must verify the following requirements u have been met: ra F re u s lo c re o F p to .S w w w
Note Endorsed Using a Facsimile Signature Stamp:
Custodian may certify. Seller is required to maintain an opinion of counsel that use of a facsimile signature constitutes a valid signature for an endorsement on each Note so endorsed.

m o

Assignments of Security Instruments from original Mortgagee to Seller/Servicer or to MERS prepared, executed and recorded where required.

Seller/Servicer provides Custodian with any documentation necessary to determine whether the Seller/Servicer has elected to hold all assignments for Mortgages registered with MERS in the Mortgage files.

Freddie Mac - Document Requirements

Original Note Complete Endorsement Chain (Originator through Seller to Blank) Complete Assignment Chain (Originator to Seller/Servicer or MERS) MERS MOM Loans – No Assignments Power of Attorney Assumptions Original Riders, Addendums, etc.

Name Affidavit – Only If borrower signature is not consistent with the typed name below the signature line.

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Freddie Mac - Allonge Requirements

.c are d An Allonge may used if the following conditions u met: ra F re u s lo c re o F p to .S w w w

m o

Permanently affixed to the Note. References the borrower’s name, property address, original principal balance. The form of the allonge and its use applies with all applicable laws. Does not impair Freddie Mac’s status as a “holder in due course” or any of Freddie Mac’s rights under the Purchase Documents.

Freddie Mac - NY CEM Loans

.c The Original Consolidated Note for Fixed Rate, d u Adjustable Rate and Balloons must have the a rof the following verbiage inserted at the top F document: re u s lo c re copy and the Seller NY CEMA may be a certified o a true and correct copy of the F warrants the copy is p for recording. original delivered to .S w w w

m o

This notes amends and restates in their entirety, and is given in substitution for, the Notes described in Exhibit A of the New York Consolidation, Extension and Modification Agreement dated the same date as this note.

Freddie Mac – NY CEM Loans:
Exhibit A –Obligations Being Consolidated, Modified and Extended.

All notes, security instruments, assignments, consolidations agreements and related agreements that modify, consolidate or extend prior underlying obligations and which predate the current NY CEMA must be listed separately in Exhibit A.

Exhibit B – Property Description
Copy of Schedule A to the New York Mortgage may be used but should be marked as Exhibit B to identify it as a NY CEMA exhibit.

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Freddie Mac – NY CEM Loans:

Exhibit C –Consolidated Note Copy

s Exhibit D – Form 3033 (NY Single-Family Uniform lo Security Instrument) ec r o F p to .S w w w
All blanks completed and any applicable riders attached. Borrower signatures are not required. May be a copy.

Complete with any applicable addenda, with fixed-rate, adjustable-rate or Balloon Note language inserted at the top of the first page. Borrower signatures are not required.

r u

r F e

u a

.c d

m o

Freddie Mac – Co-Ops

r F Mortgages secured by re cooperatives u sale to s are not eligible for lo c Mac. Freddie re o F p to .S w w w

u a

.c d

m o

Freddie Mac - Data Verification

Freddie Mac Loan Number Borrower Name Co-borrower Name Property Address, City, State, Zip Original Note Date

Interest Rate

First P&I Date

Original Loan Amount

w w

to .S w

r o F p

c e

s lo

Maturity Date Principal and Interest Amount (P&I) Modification Date

r u

r F e

u a

.c d

m o

Freddie Mac - ARM Data Verification

All of the Fixed Rate Fields plus: First Interest Rate Adjustment Mortgage Margin Percent Rounded Periodic Cap Life Rate Cap

Convertibility Index

w w

to .S w

r o F p

c e

s lo

First Adjustment Minimum Rate Rate Lookback Period First Adjustment Maximum

r u

r F e

u a

.c d

m o

Freddie Mac – Initial Interest Requirements

r Monthly P&I Payment must be the F Interest e first r Only payment as stated in the Note. u s must be the first Modification/Conversion Date lo stated in the note or c amortizing payment date as re by adding the number of months of interest only o period to the due date for the 1st monthly payment F p as stated on the note. to .S w w w

Date of 1st P&I Payment must be the date of the 1st Interest Only Payment as stated in the Note.

u a

.c d

m o

Freddie Mac – Electronic Documents

eNote

w

r on a F eNotes are currently purchased only re negotiated basis and requirements are being u refined. s lo c re o F p to .S w w

u a

.c d

m o

Freddie Mac – Collateral Review

.c d Custodial and Issuer Collateral Review Tips: u Key Points per Required Documents: ra F re u s lo c re o F p to .S w w w

m o

Uniform instruments are required unless the loan has been modified. Exception: Exceptions to Guide requirements are allowed only if expressly permitted in writing from Freddie Mac. Quality Control: Seller should review deliveries before forwarding for certification to ensure all documentation is present and data matches the note.

Freddie Mac – Initial Certification Tips

u to What can Custodians and Issuers do ra F improve the Initial Certification Process? re be reviewed Data and Documentation should u accurate. s before delivery to ensure it is lo be familiar with Issuer and Custodianc should e requirements andr contact Freddie Mac as soon as o possible if there is any question concerning a F p requirement. to .S w w w

.c d

m o

u Mortgage Partnership ra F Finance® Program re u s (MPF Program®) lo .S w
Initial Certification to

.c d

m o

r o F p

c e

“Mortgage Partnership Finance” , “MPF” and the Mortgage Partnership Finance logo are trademarks of the Federal Home Loan Bank of Chicago

w w

MPF Program - Form Requirements

No forms required

All information is handled electronically

r Notification ofo certification is after F funding p to .S w w w

c e

s lo

r u

r F e

u a

.c d

m o

MPF Program – Initial Certification Process

.c PFI sells or receives the funds for the loan. d u ra Custodian is notified via e-mail that a funding file is F available for download. re u Custodian retrieves funding file from eMPF website s lo and imports into their system and either awaits the c Collateral File or oncee receives the Collateral File, r it it compares the Fo to the schedule information data p used to complete the original initial certification to review. S . w w w

m o

MPF Program – Initial Certification Process

u must After receipt of the funding file, the Custodian ra upload data files to the eMPF website: F re u s lo c files into the Loan MPF Custody imports e these rreacts accordingly based on the o Custody System and F p information provided. to .S w w w
Collateral Files that have not been received by Custodian Loans that have initial document exceptions Loans that have obtained initial certification

.c d

m o

MPF Program - Document Requirements
Promissory Note:

r Chain (Originator Endorsement – Complete Endorsement u s through PFI to blank) lo c Intervening Assignments: re o F p – Original, unrecorded Assignment Investor Assignment to from PFI to ‘Blank’ .S w w w

Original Note Or Lost Note Affidavit/Lost Instrument Bond with a certified copy of the fully executed-Original Note

r F e

u a

.c d

m o

Certified Copy of Intervening Assignments sent for recording Complete Assignment Chain (Originator to PFI or to MERS)

MPF Program - Document Requirements

r Power of Attorney – Certified F Copy re Modification – Certified Copy u s lo Addendums and Riders – Original c re (If applicable) – Land Trust Agreement o F Certified Copy p to .S w w w

MOM Loans – No Assignment Required

u a

.c d

m o

MPF Program –

Allonge and Facsimile Signature Requirements

Allonges: 2 Accurate References to the Note Needs to state “without recourse” Does not need to be affixed to the Note Note does not need to reference allonge Facsimile Signatures Require: PFI holds MPF Bank Harmless Corporate Resolution Certification of Facsimile Signature Approval of MPF Provider

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

MPF Program - NY CEMA

u New York Consolidation and Modification ra F Agreement: re 3172 Original or Certified Copy of form u Exhibits A, B, C and D os lNote endorsed in blank c Original Consolidated e without recourse r o F p to .S w w w

.c d

m o

MPF Program - Data Verification Fixed Rate Product Only...
Borrower Name Address – City, State and Zip Loan Amount Interest Rate First Payment Date Maturity Date P&I Label-Program Custodian Only
PFI Name Master Commitment Number PFI Loan Number MPF Loan Number, if applicable

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

MPF Program – Electronic Documents

r of At this time, we do not allow the F delivery re eNotes. u of MISMO. s The MPF Provider is a member lo technology needed to We continually assess the c fundings. address these types of re o F p to .S w w w
eNote:

u a

.c d

m o

FISH! Philosophy – Choose Your Attitude

u Acquire new knowledge whilst ra thinking F over the old, and you may become a re u teacher of others. s lo c re Keller Helen o F p to .S w w w

.c d

m o

Initial Certification Summary:

Ginnie Mae

Fannie Mae

Freddie Mac

Schedule Form Number

11706

Unique Note Data Elements

w w

to .S w

r o F p

2005

c e

s lo

r u

r F e

u a

.c d

m o

MPF

Program

Appropriate 1034

Electronic Data File

No Zip

Term

Co-Borrower Name Freddie Mac Number

Loan Type

Labels

Initial Certification Summary

Ginnie Mae

Fannie Mae

Unique ARM Data Elements

Interest Rate Cap Structure

ARM Plan,

Final

Assignment

w w

to .S w

No – chain ends w/ Issuer

r o F p

Pmt. Change Date.

c e
1st

s lo

r u

r F e
Mac
Max,

Freddie

u a

.c d

m o

MPF

Program

Convertibility, 1st Adj. Min, Mod Date Yes – PFI or Approved Servicer to Blank NO ARM Data

Yes – Servicer to Fannie Mae

No – chain ends w/ Servicer

Initial Certification
Ginnie Mae Fannie Mae Freddie

Allonge Requirements

Affixed & references the Note

Preferred Affixed – but

Facsimile

Signature Requirements

w w

to .S w

Corporate

Resolution

r o F p

c e

not required & specified references

s lo

r u

Affixed &

r F e

Mac

u a

Program

.c d
MPF

m o

Not required to be affixed to Note & at least 2 references

specified references

Corporate Resolution, Affidavit & Attorney Opinion Retained by the Seller Corporate Resolution, Certification & MPF Provider Approval

Corporate Resolution – retained by the Custodian

w

s RECERTIFICATION lo c re o F p to .S w w

r u

r F e

u a

.c d

m o

r Fannie Mae u c e s lo

r F e

u a

.c d

m o

w w

r o F Recertification p to .S w

Fannie Mae –

Recertification Timing & Frequency

Required for:

Change in Document Custodian Change in Servicer Fannie Mae or the Seller/Servicer request recertification

Recertify within:

6 Months of File Receipt OR 6 Months of Transfer Effective Date (Servicing Transfers)

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Fannie Mae –

Initiating the Recertification Process

Servicer or Fannie Mae Initiates Service must provide:
Trial Balance or Schedule (Form 2005)

r o Inventory recommended within 30 Days of F transfer. op t .S w w w

c e

s lo

r u

r F e

u a

.c d

m o

Fannie Mae –

Recertification Differences From Initial Certification

Same Documentation Requirements Limited Note Elements
Lender Loan ID Borrower Names Property Address (No Zip)

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Fannie Mae - Recertification Process Change of Issuer

Custodian – no change:

w

r For schedule. Custodian must obtain manifest re address etc. on u Verify borrower names, property s or schedule. Note to information on manifest lo from the new c Assignment to Fannie Mae re servicer is present. o F Complete the recertification form when all p document have been reviewed and exceptions to cleared. .S w w

u a

.c d

m o

Fannie Mae –

.c d To complete the recertification, Custodian sends u Servicer: ra F re u s lo c re o Custodian Keeps: F p to .S w w w
Copy of Form 2002 Trial Balance or Schedule (Form 2005)

Recertification Ongoing Record-Keeping

m o

Form 2002 (Recertification Form) Copy of Trial Balance Or the annotated Schedule of Mortgages (Form 2005) that reflects the composition of the MBS pool on the date of the transfer and identifies the mortgages for which documents were transferred.

Fannie Mae - Recertification Tips

u For a successful recertification: a r the F Review and recertify as soon as all of re documents are available. u immediately. s Communicate any issue noted lo the same rigor as Approach recertification with c the initial certification. re o F p to .S w w w

.c d

m o

Ginnie s Mae

w w

Recertification to .S w

re o F p

lo c

r u

r F e

u a

.c d

m o

Ginnie Mae –

Recertification Timing & Frequency

Required for:
Change in Document Custodian Change in Issuer

Recertify within:
12 Months

Note: Ginnie Mae ‘at its discretion’ reserves the right to require reviews to protect the assets pledged in the Ginnie Mae MBS Securities program. As such, an Issuer can request a recertification from the document custodian should they feel the need to initiate one.

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Ginnie Mae –

Recertification Initiating the Process

u Issuer Pursues Ginnie Mae Approval ra F re Request and u Ginnie Mae Reviews Transfer s lo HUD11715 c re o via GinnieNET Approval Distributed F p to .S w w w

.c d

m o

Ginnie Mae – Initiating the Recertification Process

u Issuer provides the Custodian the ra F following forms and all collateral files: re Copy of Ginnie Mae approval letter u s HUD 11708 (Releases) lo c HUD 11706 (Schedule) re Trial Balance Documents o F Original Legal Opinions or Updates p to .S w w w

.c d

m o

Ginnie Mae - Recertification

Standard

Streamlined: Limited Reconciliation & Data Elements

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Ginnie Mae –

Recertification Ongoing Record-Keeping

Issuer & Custodian
Copy of Completed Recertification

Pool Master File

HUD11708 (Releases) HUD11706 (Schedule) signed and dated by the document custodian Trial Balance Documents Original Legal Opinions or Updates GNMA Approval Letter

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Ginnie Mae -

.c that d Organize files in pool and loan number order u match the 11706. ra F re noted on Have copies of the form HUDu 11708 sdocuments released HUD 11706 for any loanso l or c at time of review. re o F Ginnie Mae approval letter Have evidence of p to transfer. authorizing the .S w w w

Tips for Successful Recertification

m o

w w

r FreddiesMac u lo c re o F p Recertification to .S w

r F e

u a

.c d

m o

Freddie Mac – Recertification Timing and Frequency
Recertification required for:
Transfer of Servicing w/change of custodian Transfer of Custody Termination of Custodian

c 30 Days of Transfer Date re Recertify withino F 180 days p transfer date of to system for Recertification No electronic .S w w w
Move files within

s lo

r u

r F e

u a

.c d

m o

Freddie Mac – Initiating the Recertification Process Transferee Servicer Initiates

Transferor provides the Custodian the following forms and collateral files:
Form 1034T Note Assignments, if applicable

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Freddie Mac - Recertification On-Going Record Keeping

r Mac & Paper Form 1034T& Loan List to Freddie F Servicer re (1034T copy, u Keep any related correspondence s statement, data transfer notices, error resolution lo c corrections…etc) re o F Transferor Custodian: p Form 1035 Keep Transferees’ to .S w w w
Transferee Custodian:

u a

.c d

m o

Freddie Mac – Tips for Successful Recertification

u to Identify all issues as early as possible ra allow time for resolution. eF r u s Contact Freddie Mac lo concerning issues for c clear or when there which answers are not re seems to be noo F possible resolution p to .S w w w

.c d

m o

w w

r F MPF Program re u s lo c re o F Recertification p to .S w

u a

.c d

m o

MPF Program –Recertification Timing & Frequency Recertification Required for:

Files Returned to Custodian after Release Files transferred to new Custodians Requests by MPF Provider

Recertify within:

w w

to .S w

Returned Files – Same day Custodian Transfers – 60 days MPF Requests – Same day

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

MPF Program – Initiating the Recertification Process

No Forms for Initiating Recertification Initiated by…

r the Collateral PFI – The action of the PFI returning u s File to the Custodian for reinstatement. lo c MPF - Transfer of Custodian re Provider MPF - Requests byo F MPF p to .S w w w

r F e

u a

.c d

m o

MPF Program - Recertification Process Same Review as Initial Certification

r Electronic Data File Provided u s To Custodian by MPF Provider lo c Using the eMPF website re data to obtain schedule Custodian downloads o information F p to .S w w w

r F e

u a

.c d

m o

MPF Program –Tips for Successful Recertification

u All communication - include the MPF ra F Provider. re u Ensure proper staff resources in place to s lo on time. complete the recertification c reis disseminated to MPF Ensure proper data o F Provider. p to .S w w w

.c d

m o

Recertification Summary:
Ginnie Mae Fannie Mae Freddie Mac

GO FISH!

Recert Timeframe

1 Year

6 Months

Initiating Event(s)

w w

to .S w

Change of Issuer or Custodian

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

MPF

Program

Returns: 1 Day, Transfer: 2 Months Return of Released Collateral File, Custody Transfer, or Special Request

6 Months

Change of Custodian or Fannie Mae or Servicer Request

Change of Custodian Only

Recertification Summary:

Ginnie Mae

Fannie Mae

Freddie

Party Who Initiates With New Custodian
Issuer

Servicer or

Initiating Forms

w w

to .S w

11706 & Trial Balance

r o F p

Fannie Mae

c e

s lo

r u

r F e
Mac
Servicer

u a

.c d

m o

MPF

Program

Transferee

MPF Provider

2002 &

Trial Balance

1034T

Electronic Transmission

Recertification Summary:
Ginnie Mae
Variations from Initial Cert?

Fannie Mae

Freddie

YES: Standard Streamlined

YES:

Streamlined

Certified

What Custodians Keep...

w w

to .S w

11706,11708s, Trial Balance,

Trial Balance or Legal Opinion, & 2005 (Sch.) Ginnie Mae Approval Ltr.

r o F p

c e

s lo

r u

YES:

FM Ln ID

r F e

Mac

u a

.c d
NO:

MPF

m o

Program

Borrowers Address

Same as Initial

1034T, All Relevant Info & Correspondence Reproducible Release Requests

Form 2002 &

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Determine that the thing can and shall be done, and then we shall find the way!

w w

r o Abraham Lincoln F p to .S w

c e

s lo

r u

r F e

u a

.c d

m o

Document Custody General Training Session

w w

r F COFFEE BREAK TIME! re u s lo c re o F p to .S w
PLEASE RETURN FOR IN 25 MINUTES TURN FOR

u a

.c d

m o

Q & Ac Session re

s lo

r u

r F e

u a

.c d

m o

w w

to .S w

o F p

w w

s TRANSFERS lo c re o F p to .S w

r u

r F e

u a

.c d

m o

r Fannie Mae u to .S w r o F pTransfers c e s lo

r F e

u a

.c d

m o

w w

Fannie Mae - Transfer Types Servicing Transfers:

During Sale to Fannie Mae (Concurrent) After Sale to Fannie Mae

Custodian Transfers:
Servicing Transfer Requested Transfer

r o F Partial Pool Transfers Acceptable p to Concurrent Transfers Acceptable .S w w w

c e

s lo

r u

r F e

u a

.c d

m o

Fannie Mae -Transfer Notification

Lenders Initiate Transfers:
Trial Balance OR Form 2005 (Schedule)

r o F New Transferee Servicer/Custodian Relationship p to .S w w w
2003 If:

c e

s lo

r u

r F e

u a

.c d

m o

Fannie Mae - Transfer Processing

r F Ongoing Relationship with Servicer re u Seller to Blank Endorsement Chain Ends: s lo Servicer to c Assignment Chain Ends: re Fannie Mae o F MERS Information Lender to op Provide t .S w w w
System Tracking:

u a

.c d

m o

Fannie Mae – Ongoing Record-Keeping

u Record of Completion (Transferor): ra 2009 (Release Request) F re Written Notice of Release to Servicer u s lo Tracking/Storage: c re (Schedule) Trial Balance or o 2005 F 2002 (Recertification), if applicable. p to .S w w w

.c d

m o

w w

r F Ginnie Mae re u s lo c re Transfers o F p to .S w

u a

.c d

m o

Ginnie Mae - Transfer Types

u Transfer of Issuer Responsibilitiesa r F Transfer of Custodian Responsibilities re u Multiple Sites Transfer s lo or storage Change in Custodial location c re Only Pool Level Transfers o F p Concurrent Transfers to .S w w w

.c d

m o

Ginnie Mae - Transfer Notification

Issuers Initiate Transfers:
Ginnie Mae Approval Required 11706 to Custodian Must Use GinnieNet

11715 needed if:

New Issuer/Custodial relationships New Ginnie Mae Custodian New Custodial site

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Ginnie Mae - Transfer Processing

System Tracking:
Issuer of Record & Pool

rChains: Endorsement & Assignment u s Same as Initial Certification lo cif Transfer of Issuer Record Assignments re o F p to .S w w w

r F e

u a

.c d

m o

Ginnie Mae – Ongoing Record-Keeping

u 11706 to PPA (Pool Processing Agent) ra F re Tracking/Storage: u s Ginnie Mae Approval Letter lo HUD11708s (Releasec Requests) re HUD 11711A or HUD11711B (if applicable) o F HUD11706 (Schedule) p Trial Balance to LegalS . Opinions w w w
Record of Completion:

.c d

m o

Freddie Mac r u

w w

to .S w

r o F p

c Transfers e

s lo

r F e

u a

.c d

m o

Freddie Mac - Transfer Types

u Concurrent Transfer of Servicing ra F re Subsequent Transfer of Servicing u s lo c Transfer of Custody re o F p to .S w w w
After the mortgage is sold to Freddie Mac. Result of a transfer of servicing Servicer’s choice

.c d

m o

Occurs at the time the mortgage is sold to Freddie Mac.

Freddie Mac – Notification
Concurrent Transfers

u Approval Required. Notification via data transmission. ra Appropriate 1034 utilized. F Transferee custodian certifies. re u Subsequent Transfers s Seller/Servicer Initiates. lo c Form 1034T utilized.e r Transferee custodian delivers form 1034T to Freddie o Mac’s Document Custodial Services. F be retained for a minimum of 3 Form 1034Tp o must t months after recertification, or it can be imaged and destroyed immediately. .S w w w

.c d

m o

Freddie Mac – Transfer Processing
Form 1035, Tri-Party Agreement:

r with sale to Simultaneous Transfer of Servicing u s the investor and the Seller and Servicer are two lo c different parties: re o F p to .S w w w

Signed only once for each seller/servicer number. New 1035 if new transferee servicer/custodian relationship.

r F e

u a

.c d

m o

Endorsement chain should match up to the Seller of the loan to Freddie Mac. Last endorsement: Seller to blank. Assignment Chain: Ends with Servicer. Custodian should track loans based on the Servicer not the Seller.

Freddie Mac – Ongoing Record-Keeping

Record of Completion (Transferor): Concurrent: On-line in Selling System or 1034S for MIDANET® Subsequent: 1034T

Tracking/Storage:

Form 1034E or Note Cover Sheet may be destroyed once certification is entered in the Selling System Form 1034 and 1034A, or an image of Form 1034 or 1034A and Form 1034T must be retained for 3 months from certification date

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

u Mortgage Partnership ra F Finance® Program re u s (MPF Program®) lo c re o F pTransfers to .S w w w

.c d

m o

MPF Program -Transfer Types Transfer of Custodian

u Loans moved from one approved MPF Custodian ra to another F Loans must be certified by new e r Custodian u s Transfer of Servicing lo c Custody Agreement/ Does not require a new e rthe transfer of servicing Addendum unless o to a new Custodian includes the transfer F p to .S w w w

.c d

m o

MPF Program -Transfer Notification

u Transfers Coordinated by MPF ra Provider F Notification re Agreement Issues u s No Standard Forms lo c All information is handled electronically re electronic records for Custodian will maintain o behalf of MPF each loan held on F p to .S w w w

.c d

m o

MPF Program - Transfer Processing

u System Tracking: Seller and Servicer ra F ABC Bank – DEF Servicing Released re u Concurrent Transfers: s o lSale Simultaneous Servicing Transfer and c Endorsements = Seller to Servicer and Servicer to re o blank FSeller to Servicer and Servicer to p Assignments = o blank t .S w w w

.c d

m o

Transfers – Summary:

Ginnie Mae

Fannie Mae

Freddie

Concurrent Transfers of Servicing?

YES

Who

Initiates?

w w

to .S w

Issuer only

r o F p

c e

YES

s lo

r u

r F e
Mac

u a

.c d

m o

MPF

Program

YES

YES

Lender or Servicer

Servicer

MPF Provider

Transfers – Summary:

Ginnie Mae

Fannie Mae

Freddie

Standard Initiation Form/ Method?

11706 via GinnieNET

Trial Balance or 2005 (schedule)

Partial Pool Transfers?

w w

to .S w

r o F p

c e
YES

s lo

r u

r F e
Mac

u a

.c d

m o

MPF

Program

1034 Online or

Paper. 1034T via Email or Fax

No Standard Form

NO

YES – (Loan Level)

YES – (Loan Level)

Transfers – Summary:
Ginnie Mae Fannie Mae Freddie

Custodian Stores Agency Approval?

YES

Common Transfer Reasons

w w

to .S w

r o F p

c e

NO

s lo

r u

r F e
Mac
NO

u a

.c d

m o

MPF

Program

NO

Concurrent Transfer of Servicing (During Sale) Subsequent Transfer of Servicing (After Sale) Transfer of Custodian Responsibilities Multiple Sites Transfer

r Annual Or Recurring u s lo Reporting c re o Requirements F p to .S w w w

r F e

u a

.c d

m o

u Mortgage Partnership ra F Finance® Program re u s (MPF Program®) lo c re o F Annual or Recurring p to Reporting Requirements .S w w w

.c d

m o

MPF Program – Custodian Reporting
Annual Officer’s Certification
Attestation of Compliance Due April 15th Annually

Exhibit 2 in Custody Manual

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

MPF Program – Custodian Reporting Monthly Reports:
Loans initial certified Govt. Loans Final Certified Govt. Loans Not Final Certified Loan Releases

c 5 Business Day of Month re o F Specific File Format p to Fed to MPF Banks .S w w w
th

s lo

r u

r F e

u a

.c d

m o

MPF Program - Agreements
rd

.c Internal templates distinguish between 3 -party, d u affiliate and self-Custodians. ra F Customized service and agreements. re u s Custody Agreement between MPF Provider and lo Custodian. c re o Custodian Acknowledgement executed by F Custodian and PFI. p to Agreements cover all pool and all facilities. .S w w w

m o

MPF Program – Reporting Requirements

All re-occurring reports must be in the correct format Data on the reports must be consistent Data on the reports must be accurate

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Fannie MaeFr

cRecurring Annual or re o F Reporting p to SRequirements . w w w

s lo

re u

u a

.c d

m o

Fannie Mae - Custodian Reporting

u Annual Eligibility for Document Custodians: ra F Starting March 31, 2006 re u Audit Report Summaries s lo c re Administrative Changes o F p Bailee Letters to .S w w w

.c d

m o

Fannie Mae - Lender Reporting

.c Form 582 (Lender Record Information) d Reflects Status of Mortgage Operations u Fiscal at a year-end rFiscal YearF Due by Lender Within 90 Days of its End re uFinancial s Form 1002: Mtg. Bankers lo Reporting c Quarterly re Submitted Electronically o F Fidelity orop Insurance E&O t To Fannie Mae Within 30 Days .S w w w

m o

Fannie Mae - Report Significance
Annual Statement of Eligibility:

u Indicates Ability to Meet Eligibility and Operational ra Requirements F re Audit Report Summaries: u s Indicates Performance lo Eligibility Criteria forc Custodians and re Seller/Servicers: o Administrative F pChanges Ratings Net Worth o tand/or External .S w w w
Important to Match Entity With Ratings

.c d

m o

Fannie Mae - Reporting Requirements

u Annual Statement of Eligibility ra for F Document Custodians re Due March 31 of Each Year. u s Oversight and Sent Directly to the Custodian lo Mae. c Monitoring Group at Fannie re o F p to .S w w w
st

.c d

m o

w w

r F Ginnie Mae re u s lo Annual ec Recurring or r Requirements o Reporting F p to .S w

u a

.c d

m o

Ginnie Mae – Custodian Reporting
Non-Liquidation Inventory:

All HUD11708s for:
Code 6

s Monthly 90/180 Daylo Reports: cIssuer 90+ Days – Report e r toto Ginnie Mae o 180+ Days – Report F p to .S w w w

r u

r F e

u a

.c d

m o

Ginnie Mae Custodians:

Custodian/Issuer Reporting

Non-Liquidation Tracking (90/180 Day HUD11708 Reports) Annual Physical Inventory

Issuers:

s 11702 – Resolution of Board/Certificate of Authorized lo c Signatures re o Fof Security Interest 11711A – Release p to 11711B – Certification & Agreement .S w w w
Used to verify various HUD forms transmitted to Ginnie Mae and the Custodian

r u

r F e

u a

.c d

m o

11711A & 11711B – form used to release prior interest and certify ownership

Ginnie Mae - Custodian Reporting Annual Pool Inventory:

u Custodians Verify Physical Pools To: ra F Issuer Pool List re Master Pool Files u s o Reports to Issuers cl Major discrepancies noted and provided to re o Ginnie Mae F p Resolution Within 120 Days to Flexible Formats .S w w w

.c d

m o

Ginnie Mae - Issuer Reporting
11702 (Authorized Signatures):
Officers Required Updated Annually To Ginnie Mae & Custodian Custodian To Verify 11706s, 11708s, 11715s, Endorsements, etc.

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Ginnie Mae - Issuer Reporting

11711A & B (Security Interests):

s GinnieNET OR Hard Copy.o l c 11711A per pool, ifrapplicable. e o F p to .S w w w

11711B for every pool.

r u

r F e

u a

.c d

m o

Ginnie Mae - Report Significance

r for Assets Annual Pool Recon: Accounting u s lo 11702: Legitimate Signers c re Ownership 11711A&B: Enforceable o F p to .S w w w

Non-Liquidation Inventory: Accurate Release Reasons

r F e

u a

.c d

m o

w

r Freddie Mac F re u s o lRecurring c Annual or re o Reporting F p Requirements to .S w w

u a

.c d

m o

Freddie Mac Reporting
Due March 31 Faxed to Freddie Mac

Custodians: Annual Eligibility Certification Form

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Freddie Mac - Reporting
Seller/Servicers Report (Form 16SF):
Annual Eligibility Certification
Due 90 Days after FYE Completed On-Line

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Freddie Mac - Reporting
1107SF Report:
Seller/Servicers Only Submit As Needed Significant Organizational Changes

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Freddie Mac - Report Significance Annual Eligibility Certification Form – Certification of Compliance

r o Form 1107SF: Seller/Servicer Change F p Notification Form – Tracking Assets to .S w w w

Form 16SF: Annual Eligibility Certification Report – Notification/Awareness for Freddie Mac

c e

s lo

r u

r F e

u a

.c d

m o

Reporting Requirements - Summary

Ginnie Mae

Fannie Mae

Freddie

Required Annual Report? Annual Report Due?

YES– Pool Inventory & 11702

YES/

w w

to .S w

Resolution

Due w/i 120 Days

r o F p

Record Information

c e

Lender

s lo

r u

r F e
Mac
YES –

u a

.c d

m o

MPF

Program

YES– Annual Officer’s Certification

Eligibility Reports

FYE + 90 Days

Cust: March 31st, S/S: FYE + 90 April 15th

Reporting Requirements - Summary
Ginnie Mae Fannie Mae Freddie

Unique Agency Reports

NonLiquidation 90/180 Day Reports

Bailee Letter Notification

Common Report Reasons

w w

to .S w

r o F p

c e

s lo

r u

1107SF –

r F e
Mac

u a

.c d

m o

MPF

Program

Change Notification

Monthly Data Reports

Attestation of Compliance - Accountability Proof of Rightful Ownership Performance Monitoring Change & Asset Tracking

w w

p to .S w

r DOCUMENT u s lo CUSTODIAL c re RESPONSIBILITIES o F

r F e

u a

.c d

m o

r Ginnie Mae u c e s lo to .S w

r F e

u a

.c d

m o

r Document Custodial o F Responsibilities p

w w

Ginnie Mae –

Custodial Insurance Requirements

Document Custodians are required to maintain insurance coverage to indemnify Ginnie Mae against losses involving Ginnie Mae pool and loan documents in their custody.

Financial Institution Bond to include the following coverage's:
Fidelity Premises In Transit Forgery or Alteration

Financial Institution Bond must be underwritten by an insurance carrier with an A.M. Best’s rating of B+ or better Loss Payee endorsement must name Ginnie Mae as the loss payee Trust Operations Errors and Omissions

w w

In excess of $500 million in Ginnie Mae pool and loan documents

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Ginnie Mae – Fire Rating Requirements Document Custodial Facilities:
Effective January 1, 2007:

Facilities must provide a minimum of 2 hours of fire protection Attested by a written statement from:
Insurance company of the Document Custodian Fire Marshall of applicable jurisdiction or independent, qualified fire protection contractor.

Statement of compliance:

to Existing approved document custodial facilities .S w w w
Prior to January 1, 2007:
Minimum of 1-1/2 hours of fire protection.

Updated upon any significant change in facility and available for inspection by Ginnie Mae.

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Ginnie Mae –

.c d A Document Custodian must maintain secure, fire u resistant storage facilities with adequatea r access and controls to ensure the safety and security of pool F loan documents: re u in: s Access controls may be either lo c re o F p to .S w w w
Automated form Employees to use a security card access reader to gain entry to the vault. Electronic access record Manual Form
Requiring two employees to be present whenever the vault is entered. Written access long maintained.

Custodial Safekeeping Requirements

m o

Ginnie Mae – Custodial Responsibilities

u Ginnie Mae’s recommendation to Issuers ra and Document Custodians: F re should The issuers and document custodians u s subscribe to any and all updates made by Ginnie lo c Mae. re web site address: Please consult the o following F p www.ginniemae.gov to .S w w w

.c d

m o

Fannie Mae r u

w w

c Custodial Document re o Responsibilities F p to .S w

s lo

r F e

u a

.c d

m o

Fannie Mae –

Insurance Requirements for Custodian

u As of October 1, 2006, The Insurance a Coverage r for a Document Custodian Must Include: F re u s lo Coverage Limits: c re o F p to .S w w w
Fidelity Bond Errors and Omissions Insurance E & O:

.c d

m o

Must be not less than $1 million per claim and $10 million in the aggregate, on a claims-made basis.

Fannie Mae – Custodial Responsibilities

r Vault must be 2 hour fire rated. F re Master Pool Retention Requirements: u sfor 6 years after Electronic or paper record lo c last pool loan has liquidated. re o F p to .S w w w
Fire Rating Requirements:

u a

.c d

m o

Fannie Mae – Custodial Responsibilities

u For further information you may ra contact: F re u s lo c Or visit: re o F p to .S w w w
Debra Thompson Director of Custodian Oversight & Monitoring. [email protected] http://www.efanniemae.com or via AllRegs®

.c d

m o

w w

r F Freddie Mac re u s lo c Custodial Document re o F Responsibilities p to .S w

u a

.c d

m o

Freddie Mac – Custodial Insurance Requirements

.c a d Maintain the following insurance coverage's, at u minimum: ra F Financial institution bond, or equivalent insurance, re covering any loss resulting from: u s lo c re o F p to .S w w w

m o

Employee dishonesty Physical damage, destruction or loss of Notes and assignments while on custodian’s premises In transit (if Custodian contractually agreed to provide) between Custodian’s premises and anywhere Errors and omissions coverage including breach of duty, neglect, misstatement, misleading statement or other wrongful acts

Freddie Mac – Custodial Insurance Requirements

u The required insurance coverage's must: raa (A minus) Be underwritten by an insurer that has AFBest Company or better rating according to the re A.M. u Be maintained in amounts deemed adequate for the s held in custody and number of Notes and assignments lo business practice appropriate based on prudent c re(GAAP) net worth or $100,000, Have a deductible amount no more than the greater of o 5% of the Custodian’s F $10,000,00 but not greater than p to .S w w w

.c d

m o

Freddie Mac - Fire Rating Requirements Custodial Requirements:

u Be equipped with secure, fire-resistivea r storage safety F facilities with controls on access to ensure the and security of the Notes and assignments re u Facilities must meet fire resistive requirements set s If no requirements set by the Custodian's regulator. lo of two hours fire c by the regulator, a minimum protection. re o F p to .S w w w

.c d

m o

Freddie Mac - Custodial Safekeeping Requirements

.c to Maintain Notes and assignments in such a way as d u ensure security and confidentiality and prohibit ra unauthorized access to or use of information F contained in the Note and assignments. re u s Use employees who are knowledgeable in the lo and the functions handling of Notes andec assignments r and duties of a Custodian. o F p Access the electronic version of the Guide at: to .S http://www.freddiemac.com, or via AllRegs® w w w

m o

u Mortgage Partnership ra F Finance® Program re u s (MPF Program®) lo c re o F p Document Custodial to .S Responsibilities w w w

.c d

m o

MPF Program - Custodian Insurance Requirements

Fidelity Bond – The Custodian is responsible for the provision and maintenance, at all times, of fidelity insurance and mortgagee’s E&O insurance. The insurer must be rated B+ or better or affiliated with Lloyd’s of London. Type of Coverage – Based on the total dollars of loans held in Custody or Loans Serviced – whichever is greater

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

MPF Program - Custodian Insurance Requirements

Fidelity Bond:

w

r F Fidelity Insurance and Mortgagee’s E & O re Insurance u by the A.M. s Insurer must be rated b+ or better lo with Lloyd’s of Best Company or affiliated c London re o F p to .S w w

u a

.c d

m o

MPF Program - Custodian Insurance Requirements
Types of Coverage:

Based on total dollars of loans held in Custody or loan serviced, Whichever is greater:

<$100 million - $300,000 <$500 million - $300,000 plus 0.15% of base over $100 million <$1 billion - $300,000 plus 0.15% of $400 million plus 0.125% of base over $500 million >$1 billion - $300,000 plus 0.15% of $400 million plus 0.125% of base over $500 million plus 0.100% of base over $1 billion.

Deductibles:

w w

Fidelity- the greater of $100,000 or 5%. E & O – the greater of $100,000 or 5% per loss or occurrence.

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

MPF Program – Custodial Responsibilities

Fire Rating Requirements:

Minimum of 2 hours fire protection Attested by Custodian’s insurance company, local fire marshal or an independent, qualified fire protection contractor.

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

MPF Program – Custodial Safekeeping Requirements

.c To assure the safety and security of Collateral d u Files: ra F re u s Controlled either by: lo c re o F p to .S w w w
Secured facility with adequate controls of access Fire resistant storage facility An automated system to enter vault:
Use of a security card reader Electronic access records

m o

Or a manual system:

Requiring at least two employees to be present whenever the vault is entered Maintenance of a written access log

MPF Program - Responsibilities

.c For further information regarding the MPF program d u please contact: ra F re u s lo c re o F p to .S w w w
Kathleen Davidson - MPF Custody Manager Phone: 312-616-8049 E-mail Address: [email protected] Dawn Castell – Senior Custody Specialist Phone: 312-565-1234 E-mail Address: [email protected] Dan Melady – Custody Specialist Phone: 312-565-2605 E-mail Address: [email protected] General e-mail address: [email protected]
°

m o

Audit Tips s& Most lo c Common Findings re

r u

r F e

u a

.c d

m o

w w

to .S w

o F p

w w

r F Ginnie Mae re u s lo c & Most e Audit rTips o Findings F Common p to .S w

u a

.c d

m o

Ginnie Mae - Audit

r On-site Custodian & Issuer reviews F re Desk reviews only for RFP & risk assessment u s & desk Frequency varies forlo on-site c reviews. re o last 3 to 5 days. On-site Reviews F p to .S w w w
2 Types:

u a

.c d

m o

Ginnie Mae – Custodian Audit Tips Designate one audit contact.

r Ensure availability of requested documents. F re Keep current eligibility information. u s lo Prepare written explanations of extenuating c re factors. o d! F Be pare p Pre to .S w w w

u a

.c d

m o

Ginnie Mae – Issuer Audit Tips
Designate one audit contact.

r F Prepare written explanations ofe r extenuating u s factors. lo c List bank accounts in questionnaire. re & bank statements for Prepare reconciliations o F review. p to forms current & available. ConfirmS HUD all . w w w
Ensure availability of requested documents.

u a

.c d

m o

Ginnie Mae –

Common Custodian Findings

Fire-Resistance Attestation

r Fidelity Bond Coverage u s lo c Errors & Omissions Coverage re o F p to .S w w w

r F e

u a

.c d

m o

Ginnie Mae – Common Issuer Findings Recurring Findings:

Recurring Finding of Past Audits Errors on 11708s (Release Request) Errors on 11706s (Certification Schedule)

Tips to avoid repeating these items:
Prepare for the audit itself. Schedule time to make sure the supporting information is available to the review team. Make prior audit finding reports available to management team. Q.C. review certifications on a regular basis to avoid repeated errors.

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Ginnie Mae – Opportunities to Improve...

Custodians:

Continue to maintain Independence.

Issuers:

Shorten pool submission cycle. Strengthen data reporting controls.

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

w w

r F Fannie Mae re u s lo c & Most Audit Tips re o F Common Findings p to .S w

u a

.c d

m o

Fannie Mae - Custodial Audit
Onsite Review Frequency:
Large custodians – semi-annually Small to mid-size custodian – annually

Length of Review:
“Variable” 2 to 3 days

c On-Site Audits: Data Audits vs. Physical re o F p to .S w w w

s lo

r u

r F e

u a

.c d

m o

Fannie Mae does conduct data audits occasionally; however these review’s do not satisfy the requirements for a physical on-site review.

Fannie Mae – Custodian Audit Tips
Gather requested information in advance. Set aside 1st day to meet with reviewers.

Schedule daily meeting times.
Check status of open items

r oor system resources to provide: F Have available reports p to .S w w w
Print policies and procedures.
Pool listings Drill to loan level listings within selected pools.

Route open items to your team for follow-up.

c e

s lo

r u

r F e

u a

.c d

m o

Fannie Mae – Issuer Audit Tips
Gather requested information in advance 1st

u Set aside day to meet with reviewers. a r F Schedule daily meeting times. re u s lo c for reviewers. Print policies and procedures re o Be prepared to walk the reviewers through the process F p from Issuer to Custodian (e.g. shipping/delivery into tothe QC/Certification process). custodian S with . w w w
Check status of open items. Route open items to your team for follow-up.

.c d

m o

Fannie Mae – Common Custodian Audit Findings Access/Security

u Physical and/or Electronic Access, Security, ra F Business Recovery re Policies and Procedures u sMajor Areas, and Updated/Current, Covering lo c Followed. e rData Errors o Certification and F p to .S w w w

.c d

m o

Fannie Mae – Opportunities to Improve...

Documentation & Consistent Application of Policies & Procedures:
Certifications Exceptions (Deficiencies)

Tracking Systems:

Monitor Aged Outstanding & Missing Documents

to Annual or Periodic Inventory recommended .S w w w
Proactive Management:

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

w w

r F Freddie Mac re u s lo & Most c Audit Tips re o Common Findings F p to .S w

u a

.c d

m o

Freddie Mac - Audit
Seller/Servicer Review

r Document Custodian Review u s lo c re Length of Audit o F p to .S w w w

Frequency varies depending on risk and exposure to customer Range is generally 12-36 months

r F e

u a

.c d

m o

No set schedule, usually performed in conjunction with Seller/Servicer review.

Seller/Servicer – Varies usually 2-5 days depending on scope and number of locations Custodian – Between and 1 day.

Freddie Mac - Custodian Audit Tips

Designate one audit contact. Have “experts” available.

r documents. u Ensure availability of requested s o llargest risk. Prepare to discuss your c re Discuss “wish list” items. o F Address recent changes (custodians). p to strategy (seller/servicers). Discuss S business . w w w

r F e

u a

.c d

m o

Freddie Mac - Seller/Servicer Audit Tips
Designate one audit contact. Have ‘experts’ available.

s risk. Prepare to discuss yourlo largest c Discuss ‘wish list’ re items. o Address recent changes. F p strategy. Discuss business to .S w w w

Ensure availability of requested documents.

r u

r F e

u a

.c d

m o

d are p Pre & e abl l vai A

Freddie Mac – Common Custodian Findings

u Inadequate Policies and Procedures ra F re Planning Inadequate Business Continuity u s lo c Inadequate Note Tracking re o F p to .S w w w

.c d

m o

Freddie Mac – Common Seller/Servicer Findings

u Inadequate Quality Control Program ra F e rlending controls Inadequate anti-predatory u s lo c Funds custody reconciliation controls re o F p to .S w w w

.c d

m o

Freddie Mac – Opportunities to Improve…
Custodians:

u Keep policies and procedures updated with current ra practices. F Develop and test a proper Business Continuity Plan. re Institute a proper Note Tracking system. u s o Seller/Servicer: lsound QC Program. Implement and executec ea Implement a sound r lending program, oanti-predatoryFederal and State antiincluding an automated check of F hard stops for violations. predatory laws with p controls around custodial funds Implemento t proper management. .S w w w

.c d

m o

u Mortgage Partnership ra F Finance® Program re u s (MPF Program®) lo c re o F p & Most Common Auditto Tips .S Findings w w w

.c d

m o

MPF Program - Audit Two type of Audits
Custodian Site Review Collateral File Sample Review

r activation u Both occur within one year of s l=oPerformance based Ongoing Site Reviews c re = Annual File Sample Reviews o F 2 to 4 hours p Site Review last to .S w w w

r F e

u a

.c d

m o

MPF Program – Custodian Audit Tips Designate one audit contact

Ensure availability of requested documents

s# Mark copies with MPF lo loan c docs to MPF Forward trailing corrective re o Provider F p to .S w w w

Inform staff of visit

r u

r F e

u a

.c d

m o

MPF Program – Issuer Audit Tips

u to Exposure to Issuer arrangement ra limited F pilot program re u More to come as we explore off balance s lo MPF fundings sheet capabilities for future c re o F p to .S w w w
d are p Pre & e abl l vai A

.c d

m o

MPF Program – Common Custodian Findings Assignments

Incomplete Notary Sections Missing Signatures Missing True and Certified Copy Stamps

Living Trust Loans

r Construction Fo to Permanent Loans p PFI and Custodian Issue to .S w w w
PFI and Custodian Issue

c e

s lo

r u

r F e

u a

.c d

m o

MPF Program – Opportunities to Improve...

Training

Investor-specific Procedures

Excellent Quality Control Procedure

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

FISH! Philosophy

Never tell people how to do things. Tell them what to do and they will surprise you with their ingenuity.
George S. Patton, Jr.

r Play o F Make Their Day p t Be Thereo .S Choose Your Attitude w w w

FISH! Philosophy:

c e

s lo

r u

r F e

u a

.c d

m o

Audit - Summary

Ginnie Mae

Fannie Mae

Freddie Mac

Audit or Review Types
1. On-site 2. Desk

Frequency of On-site Reviews

w w

to .S w

Variable based on multiple factors

r o F p

1. On-site 2. Desk

c e

s lo

r u

r F e

u a

.c d

m o

MPF

Program

On-site

1. 2.

Site Sample

Variable TBD

Variable – 12 to 36 months

Variable – 12 to 36 months

Audit - Summary

Ginnie Mae

Fannie Mae

Freddie

On-Site Duration

3 to 5 Days

Unique Tips

Custodian

w w

to .S w

Prepare written explanation of extenuating factors

r o F p

2 to 3 Days

c e

Variable:

s lo

r u

r F e
Mac
day

u a

.c d

m o

MPF

Program

Seller/Servicer: 3 to 5 days 2 to 4 Hours

Custodian: 1 full or partial

Available Reports/ Systems Resources

Discuss Recent Changes

MPF # on Loan Copies

Audit - Summary
Ginnie Mae
Prepare

Fannie Mae
Prepare to

Freddie

Unique Issuer Reconciliations walk & statements reviewers thru Tips
for review

Shared General Opport. Improvement

w w

to .S w

r o F p

c e

processes

s lo

r u

r F e
Mac

u a

.c d

m o

MPF

Program

Prepare to N/A

discuss largest risk

Data Integrity/Reporting

Monitor aged outstanding & missing documents Policies & Procedures Quality Control Training

The 4 Ingredients of the FISH! Philosophy:
1. Play 2. Make Their Day 3. Be There 4. Choose Your Attitude

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

Be There PLAY
Having fun, enjoying yourself, being spontaneous & creative!

Being totally focused on the moment and on the person or task with which you are engaged!

Accepting full responsibility for all of our choices. A positive attitude is a decision we make, moment to moment!

s Choose Your lo c Attitude re to .S w o F p

r u

r F e

u a

.c d

m o

Make Their Day
Doing something special for your customers & coworkers!

w w

FISH! Philosophy - Play

FUN PAYS OFF:

At Southwest Airlines Co., the corporate culture makes the airline unique.
SWA feels this fun atmosphere builds a strong sense of community. It also counter-balances the stress of hard work and competition. SWA recognizes how humor enhances employee management, customer service and profits.
Elizabeth Pedrick Sartain, Vice President of the “People Department”

w w

to .S w

r o F p

c e

s lo

r u

r F e

u a

.c d

m o

w w

p to .S w

“There is always a d.c u choice about the way ra F you do your work; re u not a even if theresis lo the choiceec about r itself” o work F

m o

Document Custody General Training Session

Q & A ec Session r

s lo

r u

r F e

u a

.c d

m o

w w

to .S w

o F p

Sponsor Documents

Or use your account on DocShare.tips

Hide

Forgot your password?

Or register your new account on DocShare.tips

Hide

Lost your password? Please enter your email address. You will receive a link to create a new password.

Back to log-in

Close