GSEs Publish ULDD Phase 3 Preview Specification
October 29, 2013
Fannie Mae and Freddie Mac (the GSEs) are publishing a joint Uniform Loan Delivery Dataset (ULDD) Phase 3 'preview' specification to provide lenders and technology vendors with additional time to prepare for their implementation.
Joint ULDD Phase 3 Preview
At the direction of the Federal Housing Finance Agency (FHFA), the GSEs have worked together to identify and align on certain data delivery requirements to support the Consumer Financial Protection Bureau’s (CFPB) rule implementing the “ability to repay” (ATR) provisions of the Truth-in-Lending Act, as amended by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). The ULDD Phase 3 preview specification contains the new data points that will be required at delivery to support loans subject to the ATR rule.
We are publishing this preview, draft specification now to provide the industry with as much advance notice as possible to enable lenders and vendors to prepare for the upcoming ULDD Phase 3 requirements. A final version of the ULDD Phase 3 specification will be published at a later date and may include minor modifications.
At this time, the GSEs are planning to implement Phase 3 in 4Q 2015.The GSEs will provide more information on the final Phase 3 implementation dates by the end of 1Q 2014.
The joint Phase 3 preview specification contains a total of 15 net new data points:
- 13 data points related to the new ATR rule; the data points will be required by both GSEs
- Two data points not related to ATR that were deferred from Phase 2
Please note that most of the Phase 3 data points will require the use of extension containers to the MISMO Version 3.0 Reference Model (V3.0 Reference Model). At a later date, the GSEs will publish an updated ULDD Appendix E to specify the use of extension containers for the data points that are not contained within the V3.0 Reference Model.
The GSEs encourage all lenders, whether data is entered into the GSE delivery systems manually or through an import file, to begin their analysis and planning phase now to determine which of the Phase 3 data points are currently collected in their systems. As many lenders discovered during Phase 1, this initial analysis exercise is critical to the success of their implementation planning efforts. Many lenders may need to update or refine their systems and/or processes to ensure that they are able to capture the new ULDD Phase 3 data points. As with prior ULDD phases, the GSEs will work closely with vendors to ensure they can support lenders with this implementation.
While the GSEs are establishing new eligibility requirements in response to the ATR rule, we will not make a determination on whether a mortgage meets the CFPB final rule, whether the designation of a mortgage's status under the CFPB final rule is correct, or whether a lender’s interpretation of the data points is accurate. The determinations of compliance with the CFPB final rule and other applicable laws are the lender’s responsibility.
To obtain additional guidance on compliance with the CFPB final rule, the following resources are available: