MPF Announcement 2021-61
Impact of COVID-19 on Originations of MPF Traditional (Conventional) Loans
Effective Date: Immediately (unless otherwise noted)
In a continuing effort to monitor the spread of COVID-19 and concerns about its potential impact on borrowers, businesses, and loan originations, the MPF Program is issuing this guidance on originating and delivering MPF program mortgage loans, which in some instances reminds PFIs of current or announced temporary policies, and in other instances creates new temporary policies. This guidance supersedes any conflicting current Guide provisions or recent COVID-19 announcements.
PFIs and Servicers originating, delivering or servicing:
- MPF Government loans and MPF Government MBS loans must follow relief policies and guidance issued by the applicable Government Agencies.
- MPF Xtra loans must follow relief policies and guidance issued by Fannie Mae.
- MPF Direct loans must follow relief policies and guidance issued by the product’s investor, Redwood Trust.
In addition, PFIs and Servicers are expected to abide by any/all federal or state laws or proclamations that may affect borrowers or loans affected by COVID-19.
Changes since MPF Announcement 2021-37:
- UPDATE: Removed the temporary verbal verifications of employment policies and appraisal accommodations that previously expired.
- UPDATE: Effective immediately, the age of documentation and market based asset policies that have been in place are retired.
The following temporary policies are covered in this announcement. New and updated policies are noted, other policies remain as originally issued:
- Eligibility requirements for purchase and refinance transactions (Issued June 9, 2020)
- Delivery of loans in loss mitigation plan and Early Payment Default (EPD) (Issued April 21, 2002, updated April 22, 2020, May 6, 2020, and September 29, 2020)
- Verification of self-employment (Issued April 6, 2020, updated May 6, 2020, June 17, 2020, July 22, 2020, and September 9, 2020 )
- Requirements for borrowers using self-employment income to qualify (Issued June 9, 2020, updated November 24, 2020)
- Income Analysis
- Business Income Calculation Adjustment
- Business Assets
- Continuity of income (Issued March 24, 2020, updated May 6, 2020, June 17, 2020, July 22, 2020, and September 9, 2020, September 29, 2020, October 27, 2020, November 24, 2020, December 23, 2020, January 27, 2021, February 24, 2021, April 5, 2021, and April 28, 2021)
- Unemployment benefits qualifying as income (Issued May 6, 2020)
- Furloughed Borrowers (Issued May 6, 2020)
- Age of documentation (Issued April 6, 2020, updated May 6, 2020, June 17, 2020, July 22, 2020, September 9, 2020, January 27, 2021, and August 27, 2021) (UPDATED)
- Market-based assets (Issued April 6, 2020, updated May 6, 2020, June 17, 2020, July 22, 2020, and September 9, 2020, and August 27, 2021) (UPDATED)
- Title insurance (Issued March 24, 2020)
- Powers of attorney (Issued April 6, 2020, updated May 6, 2020, June 17, 2020, July 22, 2020, September 9, 2020, September 29, 2020, October 27, 2020, November 24, 2020, December 23, 2020, January 27, 2021, February 24, 2021, April 5, 2021, and April 28, 2021)
- Notes, electronic records, and signatures (Issued March 24, 2020)
- Remote online notarization (Issued March 24, 2020, updated May 4, 2020)
- Automated Underwriting Systems (AUS) (Issued April 6, 2020)
- Business continuity (Issued March 24, 2020)
- Seasoned loans (Issued March 24, 2020)
- General resources
Eligibility requirements for purchase and refinance transactions
PFIs continue to have the obligation to review each borrower’s credit report to determine the status of all the borrower’s debts and liabilities, and apply due diligence for each mortgage loan on which a borrower is obligated, including co-signed mortgage loans and mortgage loans not related to the subject transaction, to determine whether the payments are current as of the note date of the new transaction. For the purposes of these requirements, “current” means all mortgage payments due in the month prior to the note date of the new loan transaction were made by no later than the last business day of that month. Other than MPF Xtra loans, the MPF Program is not providing any accommodations to the current MPF Guide provisions with regard to these requirements when a borrower is already obligated on a mortgage loan that is not current and where any payments were missed, even if the reason for the missed payments is COVID-19 related.
Effective: June 9, 2020
Delivery of loans in loss mitigation plan and Early Payment Default (EPD)
Other than MPF Xtra loans, the MPF Program only accepts loans that are current on Funding Date (i.e., the date the loan is sold into the Program), mortgage loans in a loss mitigation plan (such as forbearance plan, repayment plan or other such plan) or loans with material modifications, such as changes to the original loan amount, interest rate, final maturity, or product structure, are not eligible for delivery to into the MPF Program.
This includes loans under the Colonial Savings Servicing Released option for MPF Traditional. Colonial Savings will not purchase mortgage servicing for MPF Traditional loans in forbearance or on a forbearance plan. This includes loans that are committed to Colonial and are then placed on a forbearance plan prior to servicing file delivery to Colonial or are placed on forbearance beginning with the First Payment Due to Colonial Savings. In the event that a loan is placed on a forbearance plan within 60 days of delivery to Colonial, Colonial will continue to service the loan, but will pay zero SRP for the servicing and charge additional loan servicing administration fees.
Mortgage loans for which borrowers are granted relief due to COVID-19 related circumstances after Funding Date are exempt from the Early Payment Default QC reviews, provided that the following requirements are met:
- PFIs must keep records for all loans that were EPD but not reviewed so that, after they emerge from a COVID forbearance, an origination review can be conducted if appropriate; and
- PFIs must also review the population of EPD loans that received relief due to COVID-19 for payment irregularities, such as limited or no payments made, which may indicate presence of origination defects. Loans with payment irregularities must undergo an EPD origination QC review even if the loan is under a COVID-19 related forbearance plan.
MPF Xtra loans in forbearance due to COVID-19 may be delivered if they meet all requirement provided by Fannie Mae for such loans, including requirements detailed in Fannie Mae’s Lender Letter 2020-06, and any other applicable announcements.
Effective: April 22, 2020 for MPF Xtra Loans and April 21, 2020 for all other MPF products. (Updated on May 6, 2020 and September 29, 2020)
Verification of self-employment
When a borrower is using self-employment income to qualify, the Originator must verify the existence of the borrower’s business within 120 calendar days prior to the note date. Due to latency in system updates or re-certifications using annual licenses, certifications, or government systems of record, Originators must take additional steps to confirm that the borrower’s business is open and operating. Originators must confirm this within 10 business days of the note date (or after closing but prior to delivery).
Below are examples of methods Originators may use to confirm the borrower’s business is currently operating:
- evidence of current work (executed contracts or signed invoices that indicate the business is operating on the day the Originator verifies self-employment);
- evidence of current business receipts within 10 days of the note date (payment for services performed);
- Originator certification that the business is open and operating (Originator confirmed through a phone call or other means); or
- business website demonstrating activity supporting current business operations (timely appointments for estimates or service can be scheduled).
See MPF Traditional Selling Guide section 5.9.1 - Verbal Verification of Employment for current requirements.
Effective: PFIs were encouraged to apply these accommodations to existing loans in process as of April 6, 2020, and were required to apply them to loans with application dates on or after April 14, 2020 and is in place until further notice. (Updated May 6, 2020, June 17, 2020, July 22, 2020, and September 9, 2020)
Requirements for borrowers using self-employment income to qualify
1. Income Analysis
Self-employed income from a business that has been negatively impacted by changing conditions may be eligible for use in qualifying the borrower, if the Originator determines the borrower’s income is stable and has a reasonable expectation of continuance. Originators must obtain the following additional documentation to support the decision that the self-employment income meets MPF Program requirements:
- an audited year-to-date profit and loss statement reporting business revenue, expenses, and net income up to and including the most recent month preceding the loan application date; or
- an unaudited year-to-date profit and loss statement signed by the borrower reporting business revenue, expenses, and net income up to and including the most recent month preceding the loan application date, and three business depository account(s) statements no older than the latest three (3) months represented on the year-to-date profit and loss statement.
- For example, the business depository account statements can be no older than August, September, and October for a year-to-date profit and loss statement dated through October 31, 2020.
- If the three (3) most recent depository account statements conflict with the information presented in the current year-to-date profit and loss statement, the Originator must obtain additional statements or other documentation to support the information from the current year-to-date profit and loss statement.
NOTE: The year-to-date profit and loss statement must be no older than 60 days old as of the note date consistent with Age of Documentation requirements provided for below.
Originators must review the profit and loss statement, and business depository accounts if required, and other relevant factors to determine the extent to which a business has been impacted by COVID-19. The Originator can use the following guidance when performing the assessment of business operations and stability and must complete the business income assessment based on the minimum additional documentation above. In some instances, the Originator may find it necessary to obtain supplemental documentation listed in the examples below.
|
Assessing the Impact of COVID-19 |
|
|
Business Operations |
For example, obtain a written explanation from the business owner or confirmation that income is seasonal apart from the event timeline. |
|
Business Income |
The Originator must complete a business income assessment by comparing the year-to-date net business income from the year-to-date profit and loss statement to historical business income calculated using Income Analysis Form (Form 1084/Fannie Mae, Form 91/Freddie Mac) for a similar timeframe (such as monthly). This form must be included in the Mortgage Loan File.
Example: Historical monthly self-employment income calculated using Form 1084 = $2,000 Current level of stable monthly self-employment income as determined by the Originator using details from the year-to-date profit and loss statement and other supplemental documentation = $1,000 |
|
Business Stability |
A current balance sheet may be used to support the Originator’s determination of business stability, in conjunction with the profit loss statement. |
2. Business Income Calculation Adjustment
When the Originator determines current year net business income has been impacted by the COVID-19 pandemic and is:
- less than the historical monthly income calculated using Form 1084, but is stable at its current level, the Originator must reduce the amount of qualifying income calculated using Form 1084 to no more than the current level of stable income as determined by the Originator (see Business Income above).
- more than the historical income calculated using Form 1084, the Originator must use no more than the currently stable level of income calculated using Form 1084 to qualify the borrower.
In all cases, qualifying income must be supported by documentation, including any supplemental documentation obtained by the Originator.
3. Business Assets
We are clarifying that proceeds from the Small Business Administration PPP or any other similar COVID-19 related loans or grants are not considered business assets. Please see MPF Traditional Selling Guide- 5.20 Acceptable Sources of Assets.
Effective: PFIs are encouraged to apply these requirements to existing loans in process as of June 9, 2020; however, they must be applied to loans with application dates on or after June 11, 2020. The updated requirements to obtain three business depository account statements (increased from two statements) with an unaudited profit and loss statement and to review the depository account statements to support the level of business revenue reported in the current YTD profit and loss statement were effective for loan applications dated on and after December 14, 2020. All policies are effective until further notice. (Updated November 24, 2020)
Continuity of income
Only QM Safe Harbor loans that meet Ability to Repay are eligible for the MPF program. These requirements are not being waived in any way by this MPF Announcement, therefore PFIs selling loans into the MPF Program continue to have the responsibility of ensuring all loans meet these requirements.
To that end, Originators are expected to practice additional due diligence to ensure the most recent income information is obtained and are strongly encouraged to help ensure any disruption to borrowers’ employment (or self-employment) and/or income due to COVID-19 is not expected to negatively impact their ability to repay the loan.
As an example of additional due diligence for a self-employed borrower, Originators can verify the borrower’s business is operational closer to the note date rather than the current MPF Guide requirements (e.g., within 15 days instead of 120 days).
Effective: March 24, 2020 and is in place until further notice. (Updated May 6, 2020, June 17, 2020, July 22, 2020, September 9, 2020, September 29, 2020, October 27, 2020, November 24, 2020, December 23, 2020, January 27, 2021, February 24, 2021, April 5, 2021, and April 28, 2021)
Unemployment benefits qualifying as income
Originators must comply with the requirements provided for in the MPF Traditional Selling Guide Section 5.16.20 - Unemployment Income, pertaining to the use of unemployment benefits. Unemployment benefits can used to qualify a Borrower if the income has been documented for two (2) years and is expected to continue.
Many unemployed and furloughed individuals are eligible for unemployment benefits under the CARES Act; however, unemployment compensation is short-term in nature and is therefore not a reliable and predictable source of income for Borrowers.
Effective: May 6, 2020
Furloughed Borrowers
The COVID-19 pandemic has resulted in an increase in furloughed employees. A furlough is a suspension from active employment that does not typically guarantee restoration of an employee’s position when the furlough period ends. Until furloughed employees actually return to work, they are unable to provide evidence of a stable and reliable flow of employment-related income and are therefore ineligible. (See MPF Traditional Selling Guide Section 5.10 Income Analysis)
Effective: May 6, 2020
Age of documentation (UPDATED)
To ensure the most up-to-date information is being considered to support the borrower’s ability to repay, the MPF Program updated its age of documentation requirements for all loans (existing and new construction) as follows:
- Age of document requirements as provided for in MPF Traditional Selling Guide 5.1.3, is modified from four months (120 days) to two months (60 days) for most income and asset documentation. If an asset account is reported on a quarterly basis, the Originator must obtain the most recently issued quarterly statement.
- When an Originator receives employment and income verification directly from a third-party employment verification vendor, the information in the vendor’s database must be no more than 60 days old as of the Note date.
- No changes are being made to the age of documentation requirements for military income documented using a Leave and Earnings Statement, Social Security, retirement income, long-term disability, mortgage credit certificates, public assistance, foster care, or royalty payments, and the Originator can continue to apply standard age of document requirements as stated in the MPF Traditional Selling Guide.
All other requirements contained in the MPF Traditional Selling Guide related to allowable age of credit documents and Federal Income Tax Returns continue to apply.
Effective: PFIs were encouraged to apply these accommodations to existing loans in process on April 6, 2020, and were required to apply them to loans with application dates on or after April 14, 2020 and are no longer applicable as of August 27, 2021 is in place until further notice. (Updated May 6, 2020, June 17, 2020, July 22, 2020, September 9, 2020, January 27, 2021, and August 27, 2021)
Market-based assets (UPDATED)
In light of market volatility, the MPF Program is making the following updates when the borrower is using stocks, stock options, or mutual funds for assets:
- When used for down payment or closing costs, evidence of the borrower’s actual receipt of funds realized from the sale or liquidation must be documented in all cases.
- When used for reserves, only 70% of the value of the asset must be considered, and liquidation is not required.
See MPF Traditional Selling Guide section 5.20.7 - Stocks and Bonds for current requirements.
Effective: PFIs were encouraged to apply these accommodations to existing loans in process on April 6, 2020, and were required to apply them to loans with application dates on or after April 14, 2020 and is no longer in place as of August 27, 2021 in place until further notice. (Updated May 6, 2020, June 17, 2020, July 22, 2020, September 9, 2020, and August 27, 2021)
Title insurance
While closures of recording offices present challenges with compliance of MPF Program title requirements in MPF Traditional Selling Guide Section 9.3.3 ALTA Policy Form, Originators are reminded that the MPF Program permits lender’s policies of title insurance written on the 2006 ALTA loan title insurance form or a local equivalent. Covered Risk 14 in the 2006 ALTA form includes “gap coverage” for matters arising between the loan closing date and the mortgage recording date. This coverage is acceptable only if there is no exception for this coverage under Schedule B of the policy.
Effective: March 24, 2020
Powers of attorney
MPF Traditional Selling Guide section 10.2.6 - Power of Attorney contains requirements for powers of attorney. The following additional requirements for using a power of attorney apply and remains in place until further notice:
- All powers of attorney must include the address of the mortgaged property.
- The existing Guide conditions allowing persons “connected to the transaction” to serve as an attorney-in-fact or agent in refinance transactions will also now apply to purchase transactions as well as limited cash-out refinances.
- An individual who would otherwise be prohibited from serving as an attorney-in-fact or agent under the Guides, may execute the required loan documents on behalf of the borrower(s), provided all of the following conditions are met:
- The attorney-in-fact or agent is not an employee of the Originator.
- The power of attorney expressly states an intention to secure a loan not to exceed a stated amount from a named Originator on a specific property.
- The power of attorney expressly authorizes the attorney-in-fact or agent to execute the required loan documents on behalf of a borrower only if the borrower has, to the satisfaction of the attorney-in fact or agent in a recorded, interactive session conducted via the Internet, both:
- confirmed his or her identity; and
- reaffirmed, after an opportunity to review the required loan documents, his or her agreement to the terms and conditions of the required loan documents evidencing such transaction, and to the execution of such required loan by such attorney-in-fact or agent.
- PFI must produce at the request of its MPF Bank or the MPF Provider at any time during the term of the related loan, within a commercially reasonable time following such request and without additional expense to MPF Bank or MPF Provider, a recording and other documentary media memorializing the entirety of the interactive session.
- Unless a recorded Internet session described in the paragraph above is required, a power of attorney may only be used in a purchase transaction with a note date on or after April 7, 2020, if, after the Closing Disclosure or other closing statement, as applicable, has been delivered to the borrower before closing, an employee of the Originator or settlement agent explains the terms of the loan to the borrower(s) to confirm that each borrower understands them. This discussion must take place in person, telephonically or using a video conference system, and must be memorialized by an acknowledgment by the borrower(s) of his or her understanding of the terms of the loan. The acknowledgment may be in writing or in a recording of the telephonic or video discussion.
- Notwithstanding anything to the contrary in the Guides or this Announcement, for purchase transactions, the attorney-in-fact or agent may not be the property seller, any relative of the property seller, or any direct or indirect employee or agent of the property seller, unless in any such instance such person is also a relative of the borrower.
- Whenever an attorney-in-fact or agent is an employee of the insuring title insurer or is an employee of the policy-issuing agent of the insuring title insurer, such title insurer must have issued a closing protection letter (or similar contractual protection) for the transaction for such policy issuing agent.
- Whenever a power of attorney is used at closing, whether authorized under the Guide or under the standards in this Announcement, the borrower’s personal signature on the initial Form 1003 continues to be required if the initial Form 1003 can be signed personally (including through the United States Postal Service or commercial delivery service), or signed electronically as permitted by the Guides. If the initial Form 1003 cannot be timely signed by the borrower in these ways, then it must be signed by the holder of such power of attorney.
- Provided the power of attorney is not required to be notarized under applicable law (for example, the law governing the creation of the power of attorney, or the law of the location of the mortgaged property), the power of attorney is not required to be notarized if the transaction is a limited cash-out refinance unless:
- the attorney-in-fact or agent named in the power of attorney is employed by, or otherwise represents or is affiliated with, the title insurance company that will issue the Originator’s title insurance policy, and such title insurance company is affiliated with the Originator.
- If a power of attorney is required to be notarized, it may be remotely notarized in accordance with MPF Program Guide section 7.4.1 - Electronic Notarization (or Remote Notarization) (as revised by this Announcement) with the additional accommodation that it may be remotely notarized in all jurisdictions, even if not expressly permitted by the Guides, as long as the power of attorney is not required to be recorded. If the power of attorney is required to be recorded, it may be remotely notarized only in the jurisdictions where the laws and regulations of the state in which the mortgaged property is located either expressly permit the use of remote notarization (such as Virginia and Montana), or expressly accept remote notarizations performed out-of-state in accordance with the laws of the state in which the notarial act is performed (as revised by the table below).
- The limitations in MPF Traditional Selling Guide section 10.2.6 - Power of Attorney requiring at least one borrower signature of the note and security instrument are suspended.
The following existing policies remain in effect for loans using powers of attorney authorized by the Guides:
- PFIs may not deliver loans to the MPF Program that have unacceptable title impediments. Accordingly, the PFI must confirm that the title insurance policy does not take exception to the power of attorney, its manner of creation, the effectiveness of its notarization (if any) or to its use in relation to the transaction in accordance with MPF Traditional Selling Guide Section 9.6 Acceptable Title Exceptions.
- Originators must comply with all federal, state and local laws in accordance with MPF Program Guide Chapter 7. In addition, for Texas Section 50(a)(6) loans, PFIs should contact their MPF Bank.
- The current and revised provisions of MPF Traditional Selling Guide section 10.2.6 - Power of Attorney are always subject to the Originator’s determination that applicable law requires the acceptance of a power of attorney in particular circumstances.
- This remains in place, as does the requirement that the Originator document its determination in the loan file.
Effective: Unless otherwise noted above, these accommodations were effective for all loans in process as of April 6, 2020 and remain in place until further notice. (Updated May 6, 2020, June 17, 2020, July 22, 2020, September 9, 2020, September 29, 2020, October 27, 2020, November 24, 2020, December 23, 2020, January 27, 2021, February 24, 2021, April 5, 2021, and April 28, 2021)
Notes, electronic records, and signatures
Originators are reminded that the MPF Program Guide section 7.4 currently permits all borrower facing documents to be e-signed, with the exception of the promissory note and the security instrument, which must be wet signed. The MPF Program requires the original promissory note be in the possession of the custodian within seven (7) calendar days of the Funding Date by the MPF Bank. See MPF Traditional Selling Guide section 15.3 Initial Certification Review.
Effective: March 24, 2020
Remote online notarization
PFIs may sell loans with remotely notarized loan documents in the states listed in the table below, on the following terms and conditions:
- The notarization is performed in accordance with and is legally valid under the laws and regulations of the state in which the notarization is performed, at the time it was performed, and in compliance with the Uniform Electronic Transactions Act, as adopted in such state, and the Electronic Signatures in Global and National Commerce Act.
- The notary public is licensed and physically located in the state where the notarial act occurred and, where required by law or regulation, is specifically licensed to perform a remote online notarization.
- The loan is delivered with Special Feature Code 861 if the remotely notarized document is a security instrument or amendment to the security instrument.
- The loan is not a Texas Section 50(a)(6) loan.
- The system used for the remote notarization must meet the following minimum standards:
- at least two-factor identity authentication, including using a government-issued photo ID that has a signature, credential analysis and identity-proofing;
- tamper-sealed notarized documents and system security sufficient to (A) prevent interference with the authenticity, integrity, and security of the notarial ceremony or corruption or loss of the recording of the same, and (B) protect the communication technology, electronic record and backup record from unauthorized use;
- the remote online notary must keep a secure electronic journal of the notarial act including evidence of identity of the principal (a video and audio conference can be the basis for satisfactory evidence of identification) and maintain a backup of the electronic record; and
- recording of the notarial ceremony with storage for the minimum period required by applicable laws or if no period is specified in the applicable law, for seven years.
- The PFI must maintain the recording of the notarial ceremony for the life of the loan.
- If the loan document is required to be recorded, then the county recorder in the state and county where the property is located must accept the remotely notarized document for recording.
- The PFI makes all selling representations and warranties per the Guides, including representations and warranties related to:
- clear title and first lien enforceability;
- compliance with laws and responsible lending practices; and
- requirements regarding title insurance. If the notarized document is a security instrument or an amendment to a security instrument, the remote notarization must comply with the following title requirements and the title insurance company may not take any exception for the remotely notarized loan:
- an affirmative endorsement to the title insurance policy must be obtained regarding Exclusion 3(b) in the standard ALTA terms and conditions; or
- the title insurer has not taken an exception for the remote for the remotely notarized loan:
- an affirmative endorsement to the title insurance policy must be obtained regarding Exclusion 3(b) in the standard ALTA terms and conditions; or
- the title insurer has not taken an exception for the remote notarization in the title insurance policy and all related communications with the title insurer are kept in the mortgage loan file.
- Originators may not require a borrower to use remote notarization and must have other notary options for borrowers available.
|
LIST OF STATES PERMITTING REMOTE NOTARIZATION |
||
|
Alabama |
Kansas |
North Dakota |
|
Alaska |
Kentucky |
Ohio |
|
Arizona |
Louisiana |
Oklahoma |
|
Arkansas |
Maryland |
Oregon |
|
Colorado |
Massachusetts |
Pennsylvania |
|
Connecticut |
Michigan |
South Carolina |
|
Delaware |
Minnesota |
South Dakota |
|
District of Columbia |
Missouri |
Tennessee |
|
Montana |
Texas |
|
|
Florida |
Nebraska |
Utah |
|
Georgia |
Nevada |
Vermont |
|
Hawaii |
New Hampshire |
Virginia |
|
Idaho |
New Jersey |
Washington |
|
Illinois |
New Mexico |
Wisconsin |
|
Indiana |
New York |
Wyoming |
|
Iowa |
North Carolina |
|
If, after the publishing of this Announcement, a state not included in the above table expressly adopts a law that expressly permits the use of remote notarization or expressly accepts, (either through state law or through the application of an express federal law) remote notarizations performed out-of-state in accordance with the laws of the state in which the notarial act is performed, remotely notarized loan documents meeting the requirements above will be permitted.
Effective: April 6, 2020 (updated as of May 4, 2020, and remain in effect until further notice.)
Automated Underwriting Systems (AUS)
Pursuant to the MPF Traditional Selling Guide Section 4.2.1, MPF Traditional (Conventional) Mortgage Loans may be underwritten with either AUS (Fannie Mae’s Desktop Underwriter® (DU®) or Freddie Mac’s Loan Product Advisor®) and must follow the overall program requirements, underwriting requirements, and eligibility requirements of the applicable GSE for that Mortgage Loan. The MPF Guides provide certain MPF Program Requirements that supersede Fannie Mae/DU and Freddie Mac/Loan Product Advisor requirements, including the requirement that a there be a full Interior/Exterior Appraisal, or a DU eligible Appraisal Waiver if the MPF Program and any specific MPF Bank requirements for appraisal waivers are met.
The COVID-19 related appraisal accommodations provided for this Announcement supersedes the current full Interior/Exterior Appraisal requirement.
Effective: April 6, 2020
Business continuity
PFIs are reminded, that they must have a business continuity/disaster recovery program in place to support its ongoing ability to conduct business operations, among other things, in the event of an interruption to business operations and processes.
Effective: March 24, 2020
Seasoned Loans
As a reminder, closed mortgage loans where documentation at closing may not meet current MPF Program requirements, may still be eligible for sale into the MPF program as a seasoned loan pursuant to MPF Traditional Selling Guide Section 14.1 - Conventional Mortgage Loan Seasoning Requirements, if all issues with the loan documentation are cured prior to delivery.
Effective: March 24, 2020
General resources
The MPF Program is pleased to continue providing support to PFIs/Servicers in these difficult times. Please contact the MPF Service Center with any questions or concerns (877-FHLB-MPF).
- References:
- MPF Announcement 2021-61
