MPF Announcement 2022-65

MPF Program Announces 
Kick-Off of Annual Eligibility Certification and Forms OG1 and OG2

Effective Date: January 1, 2023

The MPF Program would like to remind PFIs and Servicers that the Annual Eligibility Certification (AEC) process will begin soon.

Forms OG1 and OG2

The Forms OG1 and OG2 for the 2022 certification will be available on the eMPF® website as of January 1, 2023, and PFIs and Servicers must submit their 2022 Forms OG1 and OG2 with any supporting documentation by January 31, 2023.

PFIs/Servicers should note the Form OG1 (Annual Eligibility Certification) will not be pre-populated with the prior year’s submitted responses. The only information that will be pre-populated in the updated Form is the PFIs/Servicers contact information in the top portion the Form.

The Form OG2 (MPF Fidelity and Errors & Omissions Insurance Worksheet) will also not be pre-populated. PFIs and Servicers are required to complete the Form with the most current insurance information, prior to submitting.

The Forms must be submitted electronically via the eMPF® website by an employee of the PFI or Servicer who has delegated authority per the Delegation of Authority (DOA) on file or an officer authorized to execute agreements and amendments.

PFIs or Servicers deemed to be noncompliant with MPF Program requirements, including the requirement to submit timely Forms OG1 and OG2, may be subject to the following:

• Disqualification;
• Suspension; and/or
• Compensatory Fees

Updates to AEC Forms

• PFIs and Servicers may now access their prior year AEC submission via eMPF:

• All questions on the OG1 and OG2 are required and must be completed in order to submit the Forms. To avoid delays, PFIs must ensure all fields are completed/checked.
• To simplify, the PFIs or Servicers status on OG1 will be indicated as “Seller and/or Servicer” or "Inactive“.
• Servicers are required to list all sub-servicers on the OG1.
• A new question was added to the OG1, with regard to credit reporting, if PFIs/Servicers select “NO” that they are not reporting to all four credit bureaus, they must document in the text box why.
• When completing the OG1, if a PFI indicates they do not report HMDA data or do not use APL software, in order to submit the Form, PFIs must check the box in Section B and must upload documentation explaining why they do not report to HMDA or follow APL.
• When completing the OG2, if a PFI does not meet the minimum E&O coverage requirements, in order to submit the Form, PFIs must give a brief description in Section 3 of the Form as to why they don’t meet the requirements.

Available Resources

PFIs may access instructions for completing the Forms OG1 and OG2 on the MPF Website or by clicking one of the following:

• Form OG1: Instructions on Completing the OG1
• Form OG2: Instructions on Completing the OG2

To provide assistance enclosed is additional information regarding AEC Process.

Webinars

The MPF Program is offering a webinar to review the online completion process for Forms OG1 and OG2. Instructions for completing the Forms, review of content and a demonstration of the upload functionality will be provided. The webinar is recommended for the staff and managers responsible for completion of the certifications contained in Forms OG1 and OG2.

The webinar will be held on the following dates:

• January 5, 2023 (1:00 - 2:00 PM CST)

To register for the webinar, please click here.  

AEC Additional Information

The following information provides additional assistance to PFIs completing their AEC.

Points of Interest

• The Forms OG1, Form OG2, and supporting documentation are completed and submitted electronically through the eMPF website.
• Information for the Form OG1 is being collected based on 2022 activity.
• After you submit the completed Forms with the supporting documentation, your FHLBank will review your submission and will either approve or reject. Typically, a Form is rejected if the required supporting documentation is missing.

Authorized Signers

The AEC must be completed and submitted on behalf of a PFI/Servicer by an individual who is:

• An officer of the PFI/Servicer, authorized to execute agreements, and amendments under the MPF Resolution, or
• An employee of the PFI/Servicer who has been delegated the authority as is typically granted to an officer authorized to execute agreements under the MPF Resolution.

eMPF Website Access

The person completing and submitting the AEC will need access to the eMPF website. Follow one of the two options if access to the eMPF website is needed: 

• Contact your local FHLBank to obtain a Delegation of Authority Supplemental form. The form will need to be signed by individuals on your MPF Resolution to authorize the additional person. This process may take a few business days to complete.
• Electronic Delegation of Authority using a Security Administrator within the eMPF website.

Supporting Documentation

To help prepare for the upcoming AEC process we have outlined some supporting documentation that may be needed:

• Fidelity Bond – Certificates of Insurance (COI) in effect as of December 31, 2022.
• Errors & Omission – Certificates of Insurance (COI) in effect as of December 31, 2022.
• Most recent monthly QC Summary Report provided to senior management for both pre-closing and post-closing reviews, including detailed information on the most severe defects, trend analysis, and target defect rate compared to actual defect rate (post-closing). Including the corrective action.
• QC Policy – if updates have been made to the QC policy in the last 12 months.
• Any exam or audit of your mortgage operations with any of the following, including origination or servicing related non-compliance or deficiency findings and summary of how the findings were addressed and corrected:
  • State or Federal Regulator
  • Government Agency (including VA, HUD, FHA, or RHS)
  • Fannie Mae and Freddie Mac
  • Other mortgage loan Investors
• For any ‘No’ responses in Section A of the Form OG1, provide a document outlining the reason for the ‘No’ response. If applicable, include supporting documentation.
• Any other document or information specifically requested by your FHLBank.