SEC and Other Loan Data Delivery Requirements
May 22, 2012
Loan Origination and Appraiser License/Certification Number Field Enforcement
In 2009, Fannie Mae and Freddie Mac (the GSEs) communicated to lenders that beginning July 1, 2010, lenders would be required to deliver four new data elements: the appraiser's state license number, supervisory appraiser's state license number, loan origination company identifier, and loan originator identifier.
The following are the corresponding Uniform Loan Delivery Dataset (ULDD) Sort IDs:
- Sort ID 525 – AppraiserLicenseIdentifier (Appraiser's state license or certification number)
- Sort ID 534 – AppraiserLicenseIdentifier (Supervisory Appraiser's License or Certification Number)
- Sort ID 627 – PartyRoleIdentifier (Loan Origination Company)
- Sort ID 634 – PartyRoleIdentifier (Loan Originator)
On November 26, 2012, each GSE's delivery system will begin delivering a fatal or critical edit when the data is not delivered for Sort ID 525 (appraiser's state license), Sort ID 627 (loan origination company), and Sort ID 634 (loan originator).
Please note, the submission of appraisal data files with the appraiser state license or certification number and supervisory appraiser's state license or certification number to the Uniform Collateral Data Portal® (UCDP®) does not replace the requirement to provide this information at loan delivery. Lenders must review the Frequently Asked Questions, which include instructions for unique scenarios, such as when data is not available.
SEC-required Data Point Reminder
As part of the Dodd-Frank Wall Street Reform and Consumer Protection Act, the Securities and Exchange Commission (SEC) issued SEC Rule 15Ga-1Mi, which requires all securitizers, including the GSEs, to publicly disclose information regarding ABS loan repurchase requests. One of the requirements of this SEC Rule is to disclose the identity of the entity funding the applicable mortgage, as recorded on the note.
As a reminder, in accordance with the SEC rule, the GSEs are requiring lenders to deliver the following new ULDD data points beginning November 26, 2012, for mortgage applications received on or after August 1, 2012:
- Sort ID 641.2 - PartyRoleType="NotePayTo", and
- Sort ID 641.1 - FullName, enter the name of the entity funding the applicable mortgage, as recorded on the note.
The GSEs' loan delivery systems will enforce the delivery of these data points beginning November 26, 2012. Each GSE will provide a timeline for updates to its loan delivery applications to facilitate the collection of these data points.
On April 23, the Freddie Mac selling system was updated for the ULDD, a key milestone for this industry effort. Freddie Mac would like to thank you, your teams, and vendors who worked so hard to make this possible.
We'd also like to thank you for your patience. The selling system update was a major implementation, and though successful, it created some short-term issues for some of you. We worked quickly to resolve the problems. We're happy to report that you and your fellow lenders are successfully delivering loans, and customer call volume has returned to normal.
Submitting Post-Settlement Corrections for Selling System Delivered Data
Please note that we have updated our Post-Settlement Correction Forms to align with our new ULDD data requirements; the previous versions will no longer be accepted. To ensure that you always have the most recent version, we recommend that you download the form every time you use it.
Next Up: July 23, 2012
We are now in the ULDD transition period, which ends on July 23, 2012 when the ULDD requirements for Phase I become effective for loan deliveries that have application received dates on or after December 1, 2011.
We strongly encourage you to fully transition to the Phase I ULDD requirements as soon as you are operationally ready. As part of the transition, you should enter the application received date and submit all the required data for the Phase I ULDD implementation. When you fully transition to the ULDD, you will receive expanded purchase edits in some cases. By making the ULDD requirements a part of your business process now, you'll be better prepared for the July 23rd ULDD implementation. (Remember, you can still use the customer test environment to test new functionality and experience the end-to-end process.)
Please make sure that data entered into the selling system for loans with application received dates on or after December 1, 2011 matches the appraisal data entered into the UCDP. Soon, the selling system will automatically compare a limited set of data points in the UCDP against the data provided in the selling system based on the Appraisal Identifier that you entered in the selling system. The Appraisal Identifier is the Document File Identifier or Doc File I.D. that you receive from the UCDP.
Tools and Resources
Selling and Delivery Training and Education Resources: A complete list of educational resources available to support your sell and deliver process.
Thank you again for all your work to support the ULDD.
This communication relates to the Uniform Mortgage Data Program, an effort undertaken jointly by Freddie Mac and Fannie Mae at the direction of their regulator, the Federal Housing Finance Agency.
i 76 Fed. Reg. 4489 (January 26, 2011) (to be codified at 17 CFR §240.15Ga-1)