mortgage bankers association document custodian general training session for gses

8/8/2019 Mortgage Bankers Association Document Custodian General Training Session for GSEs

http://slidepdf.com/reader/full/mortgage-bankers-association-document-custodian-general-training-session-for 1/209

Document Custody GeneralTraining Session

Presented by the Document Custody

Sub-committee Education Workgroup

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Catch the Energy!

Release Your Potential!

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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

General Training Session Objective

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Session Agenda

Initial Certification

Recertification

Transfer Requirements

Refreshment break

Q & A

Annual or Recurring Reporting Requirements

Custodial Responsibilities

Audit Tips and Most Common Findings

Q & A

A G E N D A

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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

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Document Custody General TrainingSession

Today’s Moderators Are:

Angee Nolan – JP Morgan Chase

Linda Gentry – Stewart Mortgage Information

Linda Rogers- GMAC Bank – Document Custodial

Division

Kelly Crunican- LaSalle Bank - Collateral Services

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Carol

Andrade

Debra

Thompson

Tom

Kumi

Speaker

Names

MPF

Program

Freddie

Mac

Fannie

Mae

Ginnie

Mae

Kathleen

Davidson

Sample “Go Fish” Question

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Q&A Sessions

End of Phase 1

End of Phase 2

Stick to questions related to topicsdiscussed

Q&A Cards Are for Submitting Questions

Pass them toward middle aisles

Leave Business Card – We’ll SendTranscript.

Q & A

CARD

Q & A Sessions

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TER-MI-NOL-O-GY

For today, ‘Agency’ = GSE, Investor, etc.

Related Terms:

Ginnie Mae: ‘Issuer’Fannie Mae: ‘Lender’

Freddie Mac: ‘Seller/Servicer’

MPF: ‘PFI’ (Participating Financial Institution)

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Ginnie Mae


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Ginnie Mae – Form Requirements

HUD11706 - Schedule of Pooled Mortgages

HUD11711A – Release of Security Interest

HUD11711B - Certification and Agreement

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Ginnie Mae – Initial Certification

Procedures Document Custodian Procedures:

Form HUD 11706:

Total number of loans reported = Collateral files receivedCompleted for both issuer and custodian.

Filed in related Pool Master File.

Form HUD 11711B:

Pool number = Ginnie Mae pool/loan package number onrelated form HUD 11706

Ensure one of the two boxes on the form has beenchecked.

Verify original executed form HUD 11711A for anymortgages with a second-party security interest.

Filed in related Pool Master File.

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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.

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Ginnie Mae – Document Requirements

Original Note

Complete Endorsement Chain (Originator throughpooling issuer to blank)

Complete Assignment Chain (Originator to current

Issuer or MERS)

MOM Loans – No Assignments

Assumptions

Addendums, Riders, etc.

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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 orinsurance company

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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)

Interest Rate (alpha and numeric)

P & I (alpha and numeric)

Term of the loan (first and last payment due dates)

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Ginnie Mae – Arm Data Verification

Interest Rate Change Date

Mortgage Margin

Interest Rate Cap Structure

Pool type suffix on Form HUD 11706 must

correlate to Interest rate cap structure on the

Note.

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Ginnie Mae – Note Endorsement

Complete chain of endorsements from the loan

originator to the pooling issuer.

Endorsement in blank and without recourse by an

authorized officer of the issuer

Facsimile signatures acceptable for endorsements:

Acceptable under the laws of the relevant jurisdiction inwhich the property is located.

Not prohibited under the issuer’s corporate charter and by-laws

Such signature authorized by Corporate Resolution

Such signature be notarized when required by law

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Ginnie Mae – Allonge Requirements

Allonges may be used:

Acceptable practice in the jurisdiction in which the

property is located.

Allonges must be:

Original

Affixed (Stapled) to the Note

And clearly reference the Note

Note may reference the Allonge but such

reference is not required.

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Ginnie Mae – Electronic Documents

Proposed Minimum Functional Requirements:

Registration

Transfer Interface

Identification

Prior to accepting an eNote

Formal application submitted to Ginnie Mae

Approval received to act as a Ginnie Mae approvedeCustodian

At the present time the only eRegistry that has beenevaluated by Ginnie Mae is the MERS® eRegistry

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Ginnie Mae – Collateral Review

Collateral Review:

Ensure presence, completeness, accuracy andcorrectness 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.

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Fannie Mae


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Fannie Mae - Form Requirements

Fannie Mae Form 2005 (Schedule of Mortgages)

Initial certification occurs within MCCS or the Document

Certification Application.

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Fannie Mae – Initial CertificationProcedures

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: To ensure the presence of required documents and

Information on the documents corresponds to that on theSchedule.

The document custodian should review thedocuments for the individual mortgages in the poolto ascertain:

Conformity to Fannie Mae's documentation requirements Properly executed

Complete, and sufficient on their face.

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Fannie Mae – Initial CertificationProcedures

Document custodian electronically

transmits its certification to Fannie Mae

through the MORNET Custodian

Certification System or the DocumentCertification Application.

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Fannie Mae - Document Requirements

Original Note

Riders, Addendums, etc.

Modifications, Assumptions, etc.

Complete Endorsement Chain (Originator to blank)

Original unrecorded Assignment to Fannie Mae

(MERS – no assignment)

Power of Attorney

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Fannie Mae - Allonge Requirements

Comply with State, County and Federal law

Affixed (Stapled) Preferred but not required

References the Note

Loan Amount

Borrower or Address of Secured Property

Facsimile Signatures Acceptable

Requires Corporate Resolution – Held by Custodian

Corporate Resolution must include the Officer’s Name(s)who facsimile signatures are authorized.

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Fannie Mae – NY CEMA

New York – Consolidation of Prior Notes

and Mortgages:

Fannie Mae requires:A recorded (or certified copy) New York Consolidation,

Extension and Modification Agreement

Form 3172

Or an equivalent form that is Fannie Mae approved.

An assignment to Fannie Mae (unrecorded, but inrecordable form)

If additional funds are advanced:New Note and Mortgage

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Fannie Mae - Cooperative Share LoanDocumentation

Co-Op Loans:

Lenders should contact their lead Fannie Maeregional office to determine specificcooperative share loan documentationrequirements for cooperative projects located

in most states.

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Fannie Mae – NY Co-Op LoanDocumentation

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 statementto Fannie Mae, in a recordable form but not filed

Certificate of Stock, shares, membership certificate, or othercontractual agreement evidencing ownership

Original Co-op Recognition Agreement

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Fannie Mae – NY Co-Op LoanDocumentation

For share loans from cooperative projects located

in New York:

Required Documentation for Collateral File:

Executed Blanket Assignment of the Co-op RecognitionAgreement’s to Fannie Mae (Fannie Mae approved form)

Original recorded Intervening Assignment of the UCCfinancing 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 OccupancyAgreement, (if applicable)

Original recorded Continuation Statement(s), (if applicable).

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Property Address – City, State, Zip

Original Loan Amount

First Payment Date

Original Note Rate

Principal and Interest (P&I)

Amortization Type (if applicable)

Mortgage Loan Type

Original Term (in months) Balloon ‘Call’ Date (if applicable)

Fannie Mae - Data Verification

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Fannie Mae - Arm Data Verification

First Interest RateChange Date

First PaymentChange Date

Interest Rate Ceiling

Interest Rate Floor

Original Index Value (If applicable)

Mortgage Margin

Lookback (May 2007)

Rounding (May 2007)

ARM Plan Number, if

present

All of the Fixed Rate Fields plus:

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Fannie Mae - Interest Only Requirements

All ARM Fields or Fixed Fields (as applicable)

Interest Only End Date

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Fannie Mae - Electronic Documents

Custodial Requirements:

Execute an Amendment to their CustodianAgreement with Fannie Mae

Training – certification guidelines for

eMortgage Notes through a consultationprocess with Fannie Mae.

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Fannie Mae - Collateral Review

Data elements should match exactly what is

printed on the Schedule of Mortgages.

Custodian must assure that the data delivered to

Fannie Mae is the same data that was certifiedby the custodian.

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Freddie Mac


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Freddie Mac - Form Requirements

Selling System

Our primary delivery and certification tool

1034E: Selling System Schedule Or Note Delivery CoverSheet

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

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Freddie Mac - Form Requirements

Freddie Mac Form 1034E from the Selling System

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Freddie Mac - Initial Certification Process

Selling System Deliveries Certified by Custodian

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

Selling System Deliveries certified by Freddie

Mac’s DCS

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

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Freddie Mac – Initial Certification



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

Freddie Mac Initial CertificationProcess

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Freddie Mac - Initial Certification




Custodian must verify the following

requirements have been met:

Loan Data:

Note = Data in the Selling System or MIDANET® and Forms1034E, 1034 and 1034A.

The Custodian is not required to verify the Seller/Servicer Loan

Number. Freddie Mac Acceptable Endorsements

Custodian must verify that the chain of endorsements isproper and complete from the original payee on the Note to

the Seller delivering the Note to Freddie Mac and that the finalendorsement is the blank endorsement from the Seller toFreddie Mac.

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Freddie Mac – Initial Certification




Custodian must verify the following requirements

have been met:

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. 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 documentationnecessary to determine whether the Seller/Servicer has electedto hold all assignments for Mortgages registered with MERS inthe Mortgage files.

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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.

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F ddi M All R i



Freddie Mac - Allonge Requirements

An Allonge may used if the following conditions are

met:

Permanently affixed to the Note.

References the borrower’s name, property address, originalprincipal 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 duecourse” or any of Freddie Mac’s rights under the PurchaseDocuments.

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F ddi M NY CEM L



Freddie Mac - NY CEM Loans

The Original Consolidated Note for Fixed Rate,Adjustable Rate and Balloons must have the

following verbiage inserted at the top of thedocument: This notes amends and restates in their entirety, and is given in

substitution for, the Notes described in Exhibit A of the New YorkConsolidation, Extension and Modification Agreement dated the

same date as this note.

NY CEMA may be a certified copy and the Sellerwarrants the copy is a true and correct copy of the

original delivered for recording.

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F ddi M NY CEM L



Freddie Mac – NY CEM Loans:

Exhibit A –Obligations Being Consolidated,

Modified and Extended.

All notes, security instruments, assignments, consolidationsagreements and related agreements that modify, consolidateor extend prior underlying obligations and which predate thecurrent NY CEMA must be listed separately in Exhibit A.

Exhibit B – Property Description

Copy of Schedule A to the New York Mortgage may be usedbut should be marked as Exhibit B to identify it as a NY CEMAexhibit.

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Freddie Mac – NY CEM Loans:

Exhibit C –Consolidated Note Copy

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

Exhibit D – Form 3033 (NY Single-Family Uniform

Security Instrument)

All blanks completed and any applicable riders attached.Borrower signatures are not required. May be a copy.

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F ddi M C O



Freddie Mac – Co-Ops

Mortgages secured by cooperatives

are not eligible for sale to

Freddie Mac.

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F ddi M D t V ifi ti



Freddie Mac - Data Verification

Freddie Mac Loan Number

Borrower Name Co-borrower Name

Property Address, City,

State, Zip

Original Note Date

Original Loan Amount

Interest Rate

First P&I Date Maturity Date

Principal and Interest

Amount (P&I)

Modification Date

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Freddie Mac ARM Data Verification



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 First Adjustment Minimum

Rate

First Adjustment Maximum

Rate

Lookback Period

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Freddie Mac – Initial Interest



Date of 1st P&I Payment must be the date of the1st Interest Only Payment as stated in the Note.

Monthly P&I Payment must be the first InterestOnly payment as stated in the Note.

Modification/Conversion Date must be the first

amortizing payment date as stated in the note orby adding the number of months of interest onlyperiod to the due date for the 1st monthly paymentas stated on the note.

Requirements

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Freddie Mac – Electronic Documents



Freddie Mac – Electronic Documents

eNote

eNotes are currently purchased only on anegotiated basis and requirements are beingrefined.

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Freddie Mac Collateral Review



Freddie Mac – Collateral Review

Custodial and Issuer Collateral Review Tips:

Key Points per Required Documents:

Uniform instruments are required unless the loan hasbeen 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 forcertification to ensure all documentation is present and

data matches the note.

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Freddie Mac Initial Certification Tips



Freddie Mac – Initial Certification Tips

What can Custodians and Issuers do to

improve the Initial Certification Process?Data and Documentation should be reviewed

before delivery to ensure it is accurate.

Issuer and Custodian should be familiar withrequirements and contact Freddie Mac as soon aspossible if there is any question concerning arequirement.

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MPF Program - Form Requirements



No forms required

All information is handled electronically

Notification of certification is after

funding

MPF Program Form Requirements

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MPF Program –Initial CertificationP



Process

PFI sells or receives the funds for the loan.

Custodian is notified via e-mail that a funding file is

available for download.

Custodian retrieves funding file from eMPF website

and imports into their system and either awaits the

Collateral File or once it receives the Collateral File,

it compares the data to the schedule information

used to complete the original initial certification

review.

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MPF Program –Initial CertificationProcess



Process

After receipt of the funding file, the Custodian must

upload data files to the eMPF website: Collateral Files that have not been received by Custodian

Loans that have initial document exceptions

Loans that have obtained initial certification

MPF Custody imports these files into the Loan

Custody System and reacts accordingly based on the

information provided.

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MPF Program - Document Requirements



Promissory Note:

Original Note

Or Lost Note Affidavit/Lost Instrument Bond with a certified

copy of the fully executed-Original Note

Endorsement – Complete Endorsement Chain (Originator

through PFI to blank)

Intervening Assignments: Certified Copy of Intervening Assignments sent for recording

Complete Assignment Chain (Originator to PFI or to MERS)

Investor Assignment – Original, unrecorded Assignmentfrom PFI to ‘Blank’

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MPF Program - Document Requirements



MOM Loans – No Assignment Required

Power of Attorney – Certified CopyModification – Certified Copy

Addendums and Riders – Original

Land Trust Agreement (If applicable) –

Certified Copy

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MPF Program – Allonge and FacsimileSignature 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

Signature Requirements

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MPF Program - NY CEMA



New York Consolidation and Modification

Agreement:Original or Certified Copy of form 3172

Exhibits A, B, C and D

Original Consolidated Note endorsed in blankwithout recourse

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MPF Program - Data Verification



Fixed Rate Product Only... Borrower Name Address – City, State and Zip

Loan Amount Interest Rate First Payment DateMaturity Date P&I Label-Program Custodian Only

PFI Name Master Commitment Number

PFI Loan Number MPF Loan Number, if applicable

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MPF Program – Electronic Documents



eNote:

At this time, we do not allow the delivery of eNotes.

The MPF Provider is a member of MISMO.

We continually assess the technology needed toaddress these types of fundings.

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Initial Certification Summary:



Labels

Co-Borrower

NameFreddie Mac

Number

TermLoan Type

No Zip

Unique Note

Data

Elements

Electronic

Data File

Appropriate

1034

11706

Schedule

Form

Number

MPF

Program

Freddie

Mac

Fannie

Mae

Ginnie

Mae

2005

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Fannie Mae

Recertification

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Fannie Mae – Recertification Timing &Frequency m



Required for:Change in Document Custodian

Change in ServicerFannie Mae or the Seller/Servicer request

recertification

Recertify within:6 Months of File Receipt OR

6 Months of Transfer Effective Date (ServicingTransfers)

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Fannie Mae – Recertification DifferencesFrom Initial Certification m



Same Documentation Requirements

Limited Note Elements

Lender Loan ID

Borrower Names

Property Address (No Zip)

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Fannie Mae - Recertification Process m



Change of Issuer

Custodian – no change:

Custodian must obtain manifest or schedule.

Verify borrower names, property address etc. onNote to information on manifest or schedule.

Assignment to Fannie Mae from the newservicer is present.

Complete the recertification form when all

document have been reviewed and exceptionscleared.

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Fannie Mae – Recertification OngoingRecord-Keeping m



To complete the recertification, Custodian sends

Servicer:

Form 2002 (Recertification Form) Copy of Trial Balance

Or the annotated Schedule of Mortgages (Form 2005) thatreflects the composition of the MBS pool on the date of thetransfer and identifies the mortgages for which documents

were transferred.

Custodian Keeps: Copy of Form 2002

Trial Balance or Schedule (Form 2005)

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Fannie Mae - Recertification Tips m



For a successful recertification:

Review and recertify as soon as all of thedocuments are available.

Communicate any issue noted immediately.

Approach recertification with the same rigor asthe initial certification.

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Ginnie Mae

Recertification

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Ginnie Mae – Recertification Timing &Frequency m



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.

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Ginnie Mae – Recertification Initiatingthe Process m



Issuer Pursues Ginnie Mae Approval

Ginnie Mae Reviews Transfer Request and

HUD11715

Approval Distributed via GinnieNET

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Ginnie Mae –Initiating the Recertification Process m



Issuer provides the Custodian the

following forms and all collateral files:Copy of Ginnie Mae approval letter

HUD 11708 (Releases)

HUD 11706 (Schedule) Trial Balance Documents

Original Legal Opinions or Updates

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Ginnie Mae - Recertificationm



Standard

Streamlined: Limited Reconciliation &

Data Elements

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Ginnie Mae – Recertification OngoingRecord-Keeping m



Issuer & Custodian

Copy of Completed Recertification

Pool Master File

HUD11708 (Releases)

HUD11706 (Schedule) signed and dated by thedocument custodian

Trial Balance Documents

Original Legal Opinions or Updates

GNMA Approval Letter

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Ginnie Mae - Tips for SuccessfulRecertification om



Organize files in pool and loan number order that

match the 11706.

Have copies of the form HUD 11708 noted on

HUD 11706 for any loans or documents released

at time of review.

Have evidence of Ginnie Mae approval letter

authorizing the transfer.

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Freddie Mac

Recertification

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Freddie Mac – Recertification Timingand Frequency om



Recertification required for:

Transfer of Servicing w/change of custodian

Transfer of Custody

Termination of Custodian

Move files within

30 Days of Transfer Date

Recertify within

180 days of transfer date

No electronic system for Recertification

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Freddie Mac – Initiating theRecertification Process om



Transferee Servicer Initiates

Transferor provides the Custodian the

following forms and collateral files:Form 1034T

Note

Assignments, if applicable

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Freddie Mac - Recertification On-GoingRecord Keeping om



Transferee Custodian:

Paper Form 1034T& Loan List to Freddie Mac &Servicer

Keep any related correspondence (1034T copy,transfer notices, error resolution statement, data

corrections…etc)

Transferor Custodian:

Keep Transferees’ Form 1035

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Freddie Mac – Tips for SuccessfulRecertification om



Identify all issues as early as possible to

allow time for resolution.

Contact Freddie Mac concerning issues for

which answers are not clear or when there

seems to be no possible resolution

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MPF Program

Recertification

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MPF Program –Recertification Timing &Frequency om



Recertification Required for:Files Returned to Custodian after Release

Files transferred to new CustodiansRequests by MPF Provider

Recertify within:Returned Files – Same day

Custodian Transfers – 60 days

MPF Requests – Same day

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MPF Program –Initiating theRecertification Process om



No Forms for Initiating Recertification

Initiated by… PFI – The action of the PFI returning the Collateral

File to the Custodian for reinstatement.

MPF - Transfer of Custodian

MPF - Requests by MPF Provider

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MPF Program - Recertification Process

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Same Review as Initial Certification

Electronic Data File Provided

To Custodian by MPF Provider

Using the eMPF websiteCustodian downloads data to obtain schedule

information

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Recertification Summary:om



Return of

Released

Collateral File,Custody Transfer,

or Special Request

Change of

Custodian Only

Change of

Custodian or

Fannie Mae orServicer

Request

Change of

Issuer orCustodian

Initiating

Event(s)

Returns:

1 Day,

Transfer:

2 Months

6 Months1 YearRecert

Timeframe

MPF

Program

Freddie

Mac

Fannie

Mae

Ginnie

MaeGO FISH!

6 Months

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Recertification Summary:om



ElectronicTransmission

1034T2002 &Trial Balance

11706 & TrialBalance

InitiatingForms

MPF ProviderTransferee

Servicer

Servicer or

Fannie Mae

Issuer

Party Who

Initiates

With NewCustodian

MPF

Program

Freddie

Mac

Fannie

Mae

Ginnie

Mae

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Recertification Summary:

MPFFreddieFannieGinnie

om



Reproducible

Release

Requests

1034T,

All Relevant

Info &

Correspond-

ence

Form 2002 &

Trial Balance or

2005 (Sch.)

Certified

11706,11708s,

Trial Balance,

Legal Opinion, &

Ginnie Mae

Approval Ltr.

What

Custodians

Keep...

NO:

Same as Initial

YES:

FM Ln ID

Borrowers

Address

YES:

Streamlined

YES:

Standard

Streamlined

Variationsfrom Initial

Cert?

MPF

Program

Freddie

Mac

Fannie

Mae

Ginnie

Mae

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Determine that the thing

can and shall be done,

and then we shall find

the way!

Abraham Lincoln

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om



COFFEE BREAK TIME!

PLEASE RETURN FOR IN 25 MINUTESTURN F IN

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Q & A Session

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TRANSFERS

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Fannie Mae

Transfers

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Fannie Mae - Transfer Types

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Servicing Transfers:

During Sale to Fannie Mae (Concurrent)

After Sale to Fannie Mae

Custodian Transfers:

Servicing Transfer

Requested Transfer

Partial Pool Transfers Acceptable

Concurrent Transfers Acceptable

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Fannie Mae -Transfer Notificationom



Lenders Initiate Transfers:

Trial Balance OR

Form 2005 (Schedule)

2003 If:

New Transferee Servicer/Custodian Relationship

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Fannie Mae - Transfer Processing

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System Tracking:

Ongoing Relationship with Servicer

Endorsement Chain Ends: Seller to Blank

Assignment Chain Ends: Servicer toFannie Mae

Lender to Provide MERS Information

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Ginnie Mae

Transfers

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Ginnie Mae - Transfer Types

om



Transfer of Issuer Responsibilities

Transfer of Custodian Responsibilities

Multiple Sites Transfer

Change in Custodial location or storage

Pool Level Transfers Only

Concurrent Transfers

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Ginnie Mae - Transfer Notificationom



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

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Ginnie Mae - Transfer Processingom



System Tracking:

Issuer of Record & Pool

Endorsement & Assignment Chains:

Same as Initial Certification

Record Assignments if Transfer of Issuer

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Record of Completion:

Ginnie Mae – Ongoing Record-Keepingom



p

11706 to PPA (Pool Processing Agent)

Tracking/Storage:

Ginnie Mae Approval Letter

HUD11708s (Release Requests)

HUD 11711A or HUD11711B (if applicable)

HUD11706 (Schedule)

Trial Balance

Legal Opinions

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Freddie Mac

Transfers

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Freddie Mac - Transfer Typesom



Concurrent Transfer of Servicing Occurs at the time the mortgage is sold to Freddie Mac.

Subsequent Transfer of Servicing After the mortgage is sold to Freddie Mac.

Transfer of Custody Result of a transfer of servicing

Servicer’s choice

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Freddie Mac – Notification

Concurrent Transfers

om



Approval Required. Notification via data transmission.

Appropriate 1034 utilized.

Transferee custodian certifies.

Subsequent Transfers Seller/Servicer Initiates.

Form 1034T utilized. Transferee custodian delivers form 1034T to Freddie

Mac’s Document Custodial Services.

Form 1034T must be retained for a minimum of 3

months after recertification, or it can be imaged anddestroyed immediately.

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Fraud.c

Freddie Mac – Transfer Processing

Form 1035, Tri-Party Agreement:

om



g Signed only once for each seller/servicer number.

New 1035 if new transferee servicer/custodian relationship.

Simultaneous Transfer of Servicing with sale to

the investor and the Seller and Servicer are two

different parties: 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 theSeller.

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Freddie Mac – Ongoing Record-Keeping

d f l ( f )

om



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 andForm 1034T must be retained for 3 months from certification date

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Mortgage Partnership

om




Finance® Program(MPF Program®)

Transfers ww

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MPF Program -Transfer Types

Transfer of Custodian

om



Loans moved from one approved MPF Custodianto another

Loans must be certified by new Custodian

Transfer of Servicing

Does not require a new Custody Agreement/Addendum unless the transfer of servicingincludes the transfer to a new Custodian

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MPF Program -Transfer Notification

d.com



Transfers Coordinated by MPF ProviderNotificationAgreement Issues

No Standard Forms

All information is handled electronicallyCustodian will maintain electronic records for

each loan held on behalf of MPF

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Frau

MPF Program - Transfer Processing

System Tracking: Seller and Servicerud.com



System Tracking: Seller and Servicer

ABC Bank – DEF Servicing Released

Concurrent Transfers:

Servicing Transfer and Sale Simultaneous

Endorsements = Seller to Servicer and Servicer toblank

Assignments = Seller to Servicer and Servicer to

blank

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Fra

Transfers – Summary:

MPFFreddieFannieGinnie ud.com



MPF ProviderServicerLender or

Servicer

Issuer onlyWho

Initiates?

Concurrent

Transfers of

Servicing?

ProgramMacMaeMae

YES YES YES YES

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MPFFreddieFannieGinnie ud.com



YES – (LoanLevel)

YES – (LoanLevel)

YESNOPartial PoolTransfers?

No Standard

Form

1034 Online or

Paper. 1034T via

Email or Fax

Trial Balance

or 2005

(schedule)

11706 via

GinnieNET

Standard

Initiation

Form/Method?

MPF

Program

Freddie

Mac

Fannie

Mae

Ginnie

Mae

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MPFFreddie

M

Fannie

M

Ginnie ud.com



Concurrent Transfer of Servicing (During Sale)

Subsequent Transfer of Servicing (After Sale)

Transfer of Custodian Responsibilities

Multiple Sites Transfer

Common

TransferReasons

NONONOYES

Custodian

Stores Agency

Approval?

ProgramMacMaeMae

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Annual Or Recurring Reporting

Requirements

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Mortgage Partnershipud.com





Annual or Recurring

Reporting Requirements ww

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MPF Program – Custodian Reporting

Annual Officer’sCertification ud.c

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Attestation of

Compliance

Due April 15th

Annually

Exhibit 2 in

Custody Manual

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MPF Program – Custodian Reporting

Monthly Reports: ud.com



Loans initial certified

Govt. Loans Final CertifiedGovt. Loans Not Final Certified

Loan Releases

5th Business Day of Month

Specific File Format

Fed to MPF Banks

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Fra

MPF Program - Agreements

Internal templates distinguish between 3rd-party,affiliate and self-Custodians. ud.c

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Customized service and agreements.

Custody Agreement between MPF Provider andCustodian.

Custodian Acknowledgement executed byCustodian and PFI.

Agreements cover all pool and all facilities.

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Fra

MPF Program – Reporting Requirements

All re-occurring reports must be in the correctformat

ud.com



format

Data on the reports must be consistent

Data on the reports must be accurate

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Fra

Fannie Maeud.c

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Fannie Mae

Annual or Recurring Reporting

Requirements ww

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Fannie Mae - Custodian Reporting

Annual Eligibility for Document Custodians:

ud.c

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Annual Eligibility for Document Custodians:

Starting March 31, 2006

Audit Report Summaries

Administrative Changes

Bailee Letters

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Fra

Fannie Mae - Lender Reporting

Form 582 (Lender Record Information)Reflects Status of Mortgage Operations at Fiscal

year-endud.c

om



year endDue by Lender Within 90 Days of its Fiscal Year-

End

Form 1002: Mtg. Bankers FinancialReporting

QuarterlySubmitted Electronically

Fidelity or E&O Insurance

To Fannie Mae Within 30 Days

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Fra

Fannie Mae - Report Significance

Annual Statement of Eligibility:

Indicates Ability to Meet Eligibility and Operationalaud.c

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Requirements

Audit Report Summaries:

Indicates Performance

Eligibility Criteria for Custodians and

Seller/Servicers:

Administrative Changes

Net Worth and/or External Ratings

Important to Match Entity With Ratings

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Fr

Fannie Mae - Reporting Requirements

Annual Statement of Eligibility foraud.c

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g y

Document CustodiansDue March 31st of Each Year.

Sent Directly to the Custodian Oversight andMonitoring Group at Fannie Mae.

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Fr

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Ginnie Mae

Annual or Recurring Reporting Requirements

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Fr

Non-Liquidation Inventory:

All HUD11708s for:

Ginnie Mae – Custodian Reporting

aud.c

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Code 6

Monthly 90/180 Day Reports:

90+ Days – Report to Issuer180+ Days – Report to Ginnie Mae

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Fr

Custodians: Non-Liquidation Tracking (90/180 Day HUD11708

Reports)

Ginnie Mae - Custodian/IssuerReporting

aud.c

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p

Annual Physical Inventory

Issuers: 11702 – Resolution of Board/Certificate of Authorized

Signatures

Used to verify various HUD forms transmitted to GinnieMae and the Custodian

11711A – Release of Security Interest

11711B – Certification & Agreement11711A & 11711B – form used to release prior interest and

certify ownership

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Fr

Annual Pool Inventory:

Custodians Verify Physical Pools To:

Ginnie Mae - Custodian Reporting

aud.c

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Issuer Pool List

Master Pool Files

Reports to Issuers

Major discrepancies noted and provided toGinnie Mae

Resolution Within 120 Days

Flexible Formats

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Fr

Officers Required

U d t d A ll

Ginnie Mae - Issuer Reporting

11702 (Authorized Signatures):

aud.c

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Updated Annually

To Ginnie Mae &

Custodian

Custodian To Verify

11706s, 11708s, 11715s,Endorsements, etc.

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Fr

11711A & B (Security Interests):

Ginnie Mae - Issuer Reporting

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11711B for every pool.

GinnieNET OR Hard Copy.

11711A per pool, if applicable.

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Non-Liquidation Inventory: Accurate

R l R

Ginnie Mae - Report Significance

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Release Reasons

Annual Pool Recon: Accounting for Assets

11702: Legitimate Signers

11711A&B: Enforceable Ownership

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Freddie Macraud.c

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Freddie Mac

Annual or Recurring Reporting

Requirements

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Freddie Mac Reporting

Custodians: Annual Eligibility Certification FormDue March 31Faxed to Freddie Mac raud.c

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Freddie Mac - Reporting

Seller/Servicers Report (Form 16SF):Annual Eligibility CertificationDue 90 Days after FYECompleted On-Line raud.c

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Freddie Mac - Reporting

Seller/Servicers Only

1107SF Report:

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Submit As Needed

Significant

Organizational

Changes

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Freddie Mac - Report Significance

Annual Eligibility Certification Form –

Certification of Compliance raud.co

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p

Form 16SF: Annual Eligibility Certification

Report – Notification/Awareness for

Freddie MacForm 1107SF: Seller/Servicer Change

Notification Form – Tracking Assets

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Reporting Requirements - Summary

MPF

Program

Freddie

Mac

Fannie

Mae

Ginnie

Mae raud.co

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April 15th

Cust: March

31st, S/S:

FYE + 90

FYE + 90

Days

Resolution

Due w/i 120

Days

Annual

Report

Due?

YES –

Eligibility

Reports

YES/

Lender

Record

Information

YES– Pool

Inventory &

11702

Required

Annual

Report?

YES–

Annual

Officer’s

Certification

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Reporting Requirements - Summary

MPF

Program

Freddie

Mac

Fannie

Mae

Ginnie

Mae raud.co

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Attestation of Compliance - Accountability

Proof of Rightful Ownership

Performance MonitoringChange & Asset Tracking

Common

Report

Reasons

Monthly Data

Reports

1107SF –

Change

Notification

Bailee Letter

Notification

Non-

Liquidation

90/180 Day

Reports

Unique

Agency

Reports

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DOCUMENT CUSTODIAL

RESPONSIBILITIES

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Ginnie Mae

Document Custodial Responsibilities

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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 followingraud.co

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coverage's: Fidelity Premises In Transit Forgery or Alteration

Financial Institution Bond must be underwritten by aninsurance 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 In excess of $500 million in Ginnie Mae pool and loan documents

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Ginnie Mae – Fire Rating Requirements

Document Custodial Facilities:Effective January 1, 2007:

Facilities must provide a minimum of 2 hours of fireprotection

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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: Updated upon any significant change in facility and

available for inspection by Ginnie Mae.

Prior to January 1, 2007:

Existing approved document custodial facilities Minimum of 1-1/2 hours of fire protection.

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Ginnie Mae – Custodial SafekeepingRequirements

A Document Custodian must maintain secure, fire

resistant storage facilities with adequate accesscontrols to ensure the safety and security of pool andFr

aud.co

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loan documents:

Access controls may be either in: Automated form

Employees to use a security card access reader to gainentry to the vault.

Electronic access record Manual Form

Requiring two employees to be present whenever the vault is

entered.Written access long maintained.

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Ginnie Mae – Custodial Responsibilities

Ginnie Mae’s recommendation to Issuers

and Document Custodians: Fraud.

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and Document Custodians:

The issuers and document custodians should

subscribe to any and all updates made by Ginnie

Mae.

Please consult the following web site address:

www.ginniemae.gov

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Fannie Mae


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Fannie Mae – Insurance Requirementsfor Custodian

As of October 1, 2006, The Insurance Coverage

for a Document Custodian Must Include:Fraud.

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Fidelity Bond Errors and Omissions Insurance

Coverage Limits:

E & O:Must be not less than $1 million per claim and $10 million in

the aggregate, on a claims-made basis.

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Fannie Mae – Custodial Responsibilities

Fire Rating Requirements:

Vault must be 2 hour fire rated.Fraud.

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Master Pool Retention Requirements:

Electronic or paper record for 6 years afterlast pool loan has liquidated.

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Fannie Mae – Custodial Responsibilities

For further information you may contact: Debra Thompson Fr

aud.co

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Director of Custodian Oversight & [email protected]

Or visit:

http://www.efanniemae.com or via AllRegs®

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Freddie Mac


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Freddie Mac – Custodial InsuranceRequirements

Maintain the following insurance coverage's, at a

minimum:

Financial institution bond, or equivalent insurance,Fraud.

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, q ,

covering any loss resulting from:Employee dishonesty

Physical damage, destruction or loss of Notes andassignments 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

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Freddie Mac – Custodial InsuranceRequirements

The required insurance coverage's must:

Be underwritten by an insurer that has a A- (A minus)Fraud.

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or better rating according to the A.M. Best Company Be maintained in amounts deemed adequate for the

number of Notes and assignments held in custody andappropriate based on prudent business practice

Have a deductible amount no more than the greater of 5% of the Custodian’s (GAAP) net worth or $100,000,but not greater than $10,000,00

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Freddie Mac - Fire Rating Requirements

Custodial Requirements:Be equipped with secure, fire-resistive storage

facilities with controls on access to ensure the safetyFraud.

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and security of the Notes and assignmentsFacilities must meet fire resistive requirements set

by the Custodian's regulator. If no requirements setby the regulator, a minimum of two hours fire

protection.

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Freddie Mac - Custodial SafekeepingRequirements

Maintain Notes and assignments in such a way as toensure security and confidentiality and prohibit

unauthorized access to or use of informationFraud.

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contained in the Note and assignments.

Use employees who are knowledgeable in the

handling of Notes and assignments and the functions

and duties of a Custodian.

Access the electronic version of the Guide at:

http://www.freddiemac.com, or via AllRegs®

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Mortgage PartnershipFraud.

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Document Custodial

Responsibilities

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MPF Program - Custodian InsuranceRequirements

Fidelity Bond – The Custodian is responsible for

the provision and maintenance, at all times, of Fraud.

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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

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Fidelity Bond:

Fidelity Insurance and Mortgagee’s E & OFraud.

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Insurance

Insurer must be rated b+ or better by the A.M.Best Company or affiliated with Lloyd’s of

London

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Types of Coverage: Based on total dollars of loans held in Custody or loan

serviced,

Whichever is greater: Fraud.

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<$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 $1billion.

Deductibles:

Fidelity- the greater of $100,000 or 5%.

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

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MPF Program – Custodial Responsibilities

Fire Rating Requirements:

Minimum of 2 hours fire protection

d b C d ’ l l f

Fraud.

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Attested by Custodian’s insurance company, local firemarshal or an independent, qualified fire protectioncontractor.

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MPF Program –Custodial SafekeepingRequirements

To assure the safety and security of CollateralFiles:

Secured facility with adequate controls of access

Fire resistant storage facilityFraud.

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Controlled either by:

An automated system to enter vault:

Use of a security card reader Electronic access records

Or a manual system:

Requiring at least two employees to be present whenever thevault is entered

Maintenance of a written access log

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MPF Program - Responsibilities

For further information regarding the MPF programplease contact:

Kathleen Davidson - MPF Custody Manager

Ph 312 616 8049

Fraud.

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Phone: 312-616-8049E-mail Address: [email protected]

Dawn Castell – Senior Custody SpecialistPhone: 312-565-1234E-mail Address: [email protected]

Dan Melady – Custody SpecialistPhone: 312-565-2605E-mail Address: [email protected]

General e-mail address: [email protected]

°

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A di Ti & M

Fraud.

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Audit Tips & Most Common Findings

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Gi i M

Fraud.

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Ginnie Mae


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2 Types:

On-site Custodian & Issuer reviews

Desk reviews only for RFP & risk assessment

Ginnie Mae - Audit

Fraud.

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Desk reviews only for RFP & risk assessment

Frequency varies for on-site & desk

reviews.

On-site Reviews last 3 to 5 days.

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Designate one audit contact.

Ensure availability of requested documents.

Keep current eligibility information

Ginnie Mae – Custodian Audit Tips

Fraud.

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Keep current eligibility information.

Prepare written explanations of extenuating

factors.

BePre

pared!

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Prepare written explanations of extenuating

Ginnie Mae – Issuer Audit Tips

Fraud.

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Prepare written explanations of extenuatingfactors.

List bank accounts in questionnaire.

Prepare reconciliations & bank statements for

review.

Confirm all HUD forms current & available.

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Fire-Resistance Attestation

Fidelity Bond Coverage

Ginnie Mae – Common CustodianFindings

eFraud.

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Fidelity Bond Coverage

Errors & Omissions Coverage

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Recurring Findings: Recurring Finding of Past Audits

Errors on 11708s (Release Request)

Errors on 11706s (Certification Schedule)

Ginnie Mae – Common Issuer Findings

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Tips to avoid repeating these items: Prepare for the audit itself. Schedule time to make sure

the supporting information is available to the reviewteam.

Make prior audit finding reports available tomanagement team.

Q.C. review certifications on a regular basis to avoidrepeated errors.

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Custodians:

Continue to maintain Independence.

Ginnie Mae – Opportunities to Improve...

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Issuers:

Shorten pool submission cycle.

Strengthen data reporting controls.

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Fannie MaeeF

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Fannie Mae


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Fannie Mae - Custodial Audit

Onsite Review Frequency:Large custodians – semi-annually

Small to mid-size custodian – annually

Length of Review:eF

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Length of Review:“Variable” 2 to 3 days

Data Audits vs. Physical On-Site Audits:Fannie Mae does conduct data audits occasionally;

however these review’s do not satisfy the requirementsfor a physical on-site review.

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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

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Check status of open items

Route open items to your team for follow-up.

Print policies and procedures.

Have available reports or system resources to provide:

Pool listings

Drill to loan level listings within selected pools.

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Fannie Mae – Issuer Audit Tips

Gather requested information in advance Set aside 1st day to meet with reviewers.

Schedule daily meeting times.

Check status of open items.

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C ec status o ope te s

Route open items to your team for follow-up.

Print policies and procedures for reviewers.

Be prepared to walk the reviewers through the process

from Issuer to Custodian (e.g. shipping/delivery into

custodian with the QC/Certification process).

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Fannie Mae –Common Custodian Audit Findings

Access/SecurityPhysical and/or Electronic Access, Security,

Business Recovery

Policies and ProcedureseF

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Policies and Procedures

Updated/Current, Covering Major Areas, andFollowed.

Certification and Data Errors

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Fannie Mae – Opportunities to Improve...

Documentation & Consistent Application of

Policies & Procedures:

Certifications

Exceptions (Deficiencies)

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Exceptions (Deficiencies)

Tracking Systems:

Monitor Aged Outstanding & MissingDocuments

Proactive Management:

Annual or Periodic Inventory recommended

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Freddie MaceFraud

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Freddie Mac - Audit

Seller/Servicer Review Frequency varies depending on risk and exposure to

customer

Range is generally 12-36 months

Document Custodian Review

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

Length of Audit Seller/Servicer – Varies usually 2-5 days depending on scope

and number of locations

Custodian – Between and 1 day.

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Freddie Mac - Custodian Audit Tips


Have “experts” available.

Ensure availability of requested documents

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Prepare to discuss your largest risk.

Discuss “wish list” items.

Address recent changes (custodians).

Discuss business strategy (seller/servicers).

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Freddie Mac - Seller/Servicer Audit Tips


Have ‘experts’ available.

Ensure availability of requested documents.eF

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Prepare to discuss your largest risk.

Discuss ‘wish list’ items.

Address recent changes.

Discuss business strategy.

Prepar

ed

&

Availab

le

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Freddie Mac – Common CustodianFindings

Inadequate Policies and Procedures

Inadequate Business Continuity PlanningeF

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q y g

Inadequate Note Tracking

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Inadequate Quality Control Program

Inadequate anti-predatory lending controls

Freddie Mac – Common Seller/ServicerFindings

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Funds custody reconciliation controls

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Freddie Mac – Opportunities to Improve…

Custodians: Keep policies and procedures updated with current

practices.

Develop and test a proper Business Continuity Plan.

Institute a proper Note Tracking system.

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Seller/Servicer: Implement and execute a sound QC Program.

Implement a sound anti-predatory lending program,including an automated check of Federal and State anti-predatory laws with hard stops for violations.

Implement proper controls around custodial funds

management.

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Finance Program(MPF Program®)

Audit Tips & Most Common

Findings ww

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MPF Program - Audit

Two type of AuditsCustodian Site Review

Collateral File Sample Review

Both occur within one year of activation

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Ongoing Site Reviews = Performance based

File Sample Reviews = Annual

Site Review last 2 to 4 hours

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MPF Program – Custodian Audit Tips

Designate one audit contact

Ensure availability of requested documents

Inform staff of visitM k i i h MPF l #

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Mark copies with MPF loan #

Forward trailing corrective docs to MPFProvider

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MPF Program – Issuer Audit Tips

Exposure to Issuer arrangement limited to

pilot program

More to come as we explore off balance

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sheet capabilities for future MPF fundings

Prepared&

Availab

le

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MPF Program –Common CustodianFindings

Assignments Incomplete Notary Sections

Missing Signatures

Missing True and Certified Copy Stamps

Li i T t L

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Living Trust Loans

PFI and Custodian Issue

Construction to Permanent Loans

PFI and Custodian Issue

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MPF Program –Opportunitiesto Improve...

Training

Investor-specific ProcedureseF

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Excellent Quality Control Procedure

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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.

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George S. Patton, Jr.

FISH! Philosophy:

Play

Make Their Day

Be There

Choose Your Attitude

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Audit - Summary

Audit or

MPF

Program

Freddie

Mac

Fannie

Mae

Ginnie

Mae

eFraud

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Frequency

of On-site

Reviews

Review

Types

On-site1. On-site2. Desk

1. On-site2. Desk

1. Site2. Sample

Variablebased onmultiple

factors

Variable -TBD

Variable –12 to 36months

Variable –12 to 36months

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Audit - Summary

Seller/Servicer:

3 to 5 days

MPF

Program

Freddie

Mac

Fannie

Mae

Ginnie

Mae

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MPF # on Loan

Copies

Discuss Recent

Changes

Available

Reports/

Systems

Resources

Prepare written

explanation of

extenuating

factors

Unique

Custodian

Tips

2 to 4 Hours

3 to 5 days

Custodian:

1 full or partial

day

Variable:

2 to 3 Days3 to 5 Days

On-Site

Duration

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Audit - Summary

N/APrepare to

discuss

largest risk

Prepare to

walk

reviewers thru

Prepare

Reconciliations

& statements

Unique Issuer

Tips

MPFProgram

FreddieMac

FannieMae

GinnieMae

eFraud

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Data Integrity/Reporting

Monitor aged outstanding & missing documents

Policies & Procedures

Quality Control

Training

Shared

General

Improvement

Opport.

largest riskprocessesfor review

Tips

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The 4 Ingredients of the

FISH! Philosophy:1. Play

2. Make Their Day

3. Be There

4. Choose Your Attitude

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PLAYPLAYHaving fun,Having fun,

enjoying yourself,enjoying yourself,being spontaneousbeing spontaneous

& creative!& creative!

Be ThereBe ThereBeing totally focused onBeing totally focused onthe moment and on thethe moment and on the

person or task with whichperson or task with whichyou are engaged!you are engaged!

Choose YourChoose Your sureF

raud.com



Make Their DayMake Their DayDoing something special forDoing something special for

your customers & co-your customers & co-workers!workers!

AttitudeAttitudeAccepting fullAccepting fullresponsibility for all of ourresponsibility for all of ourchoices. A positivechoices. A positiveattitude is a decision weattitude is a decision we

make, moment to moment!make, moment to moment!

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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. sur

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It also counter-balances the stress of hard work andcompetition.

SWA recognizes how humor enhances employeemanagement, customer service and profits.

Elizabeth Pedrick Sartain, Vice President of the “People Department”

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“

There is always achoice about the wayyou do your work;

even if there is not ah i b h

sureF

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choice about the

work itself”

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Q & A Sessionsur

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Q & A Session

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