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FAQs on the Delivery of Loan-level Origination Data Required by FHFA

These frequently asked questions (FAQs) are provided to answer questions about the loan-originator and appraiser identifiers the Federal Housing Finance Agency (FHFA) has required us to collect for all mortgages we purchase. Use this resource for additional guidance on the delivery of these required data elements. The FAQs combine new content with material from previously issued bulletins and announcements including:

General

  1. What is the purpose of the Nationwide Mortgage Licensing System (NMLS)?
  2. What is the S.A.F.E. Act?
  3. What unique identifiers are Sellers required to collect?
  4. Are Sellers required to provide the loan originator and appraiser identifiers for government-insured or -guaranteed loans delivered to Freddie Mac?

Loan Originator and Loan Origination Company Identifier Requirements

  1. What is the definition of loan originator?
  2. How do Sellers determine whether they are required to register with the NMLS?
  3. Who should Sellers contact with system questions regarding the NMLS?
  4. Is the state-issued loan originator’s license number required to be delivered to Freddie Mac?
  5. If the Seller is a federally regulated institution, when will delivery of the loan originator and loan origination companyIdentifiers be required?
  6. If a loan originator works for or in a branch office of a company, should the Seller deliver the branch identification (ID) or the company ID assigned by the NMLS for the loan origination company identifier?
  7. What loan originator data should be delivered when Seller A originates and closes a loan and then sells that loan to Seller B?
  8. What loan originator data should be delivered when Seller A originates a loan, but the loan closes in Seller B’s name?
  9. What loan originator data should be delivered when Seller A takes a loan application to Seller B, who underwrites and closes the loan?
  10. If a Seller delivers mortgage loans without the loan originator and appraiser identifiers, will the selling system return an error or warning message?
  11. What should be entered in the loan originator identifier data field if a loan originator has received an exemption from obtaining or is not required to obtain a loan originator identifier?
  12. Delaware, Maine, and Missouri do not currently require loan origination companies to obtain identifiers through the NMLS. What should be entered in the loan origination company identifier field if the company is located in one of these states?

Appraiser Identifier Requirements

  1. When a review appraisal is performed on a loan, which appraiser license number is required to be delivered?
  2. What information should the Seller provide to Freddie Mac if two appraisals are performed for a particular loan?
  3. What information should the Seller enter in the selling system’s appraiser state license number and supervisory appraiser state license number fields when a Loan Prospector Condition and Marketability Report (Form 2070) or a Desktop Underwriter Property Inspection Report (Form 2075) is completed (and no appraisal is performed)?
  4. If a loan is eligible to be delivered with a Property Inspection Alternative (PIA) or Relief Refinance property fieldwork waiver and no appraisal was performed, what should be entered in the selling system’s appraiser state license number and supervisory appraiser state license number fields?

General

  1. What is the purpose of the Nationwide Mortgage Licensing System (NMLS)?

    The NMLS, which was created by Congress as part of the Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (S.A.F.E. Act), is the legal system of record for licensing mortgage loan originators in all participating states, the District of Columbia, and U.S. Territories and for registering mortgage loan originators employed by financial institutions regulated by the federal banking regulators, the Farm Credit Administration, and the National Credit Union Administration. It is designed to streamline the licensing process, improve supervision, and increase transparency in the mortgage industry.

    In participating jurisdictions, the NMLS is the official and sole system for companies and individuals seeking to apply for, amend, renew, and surrender licenses managed in the NMLS on behalf of the jurisdiction’s governmental agencies. The NMLS contains a single record for each mortgage lender, broker, branch, and loan originator. NMLS itself does not grant or deny license authority.

    For more information on the NMLS, please see http://www.stateregulatoryregistry.org/NMLS/.

  2. What is the S.A.F.E. Act?

    The S.A.F.E. Act is a federal law that was enacted to protect consumers from unfair, deceptive, and fraudulent practices on the part of mortgage loan originators during the mortgage lending process. The S.A.F.E. Act was adopted by Congress as Title V of the Housing and Economic Recovery Act of 2008.

  3. What unique identifiers are Sellers required to collect?

    Sellers are required to collect the following unique identifiers for mortgages delivered to Freddie Mac:
    • Loan originator identifier – The loan originator's unique identifier as assigned by the NMLS and required based on the S.A.F.E. Act.
    • Loan origination company identifier – The loan origination company's identifier as assigned by the NMLS. The loan origination company is the company the loan originator is employed by or is representing as an independent contractor.
    • Appraiser's state license number – The field appraiser's state license number (or state certification number in the absence of a license number) issued by the state in which the subject property is located.
    • Supervisory appraiser's state license number – The supervisory appraiser's state license number (or state certification number in the absence of a license number) issued by the state in which the subject property is located.

  4. Are Sellers required to provide the loan originator and appraiser identifiers for government-insured or -guaranteed loans delivered to Freddie Mac?

    No. Sellers are not required to provide the data for government-insured or -guaranteed loans.

Loan Originator and Loan Origination Company Identifier Requirements

  1. What is the definition of loan originator?

    The S.A.F.E. Act defines a loan originator as an individual who takes a residential mortgage loan application and offers or negotiates terms of a residential mortgage loan for compensation or gain.

  2. How do Sellers determine whether they are required to register with the NMLS?

    Each company is responsible for making its own determination regarding applicability of the S.A.F.E. Act registration requirements to its business. For more information and resources, refer to the State Regulatory Registry (SRR) Web site and the NMLS Resource Center (or call the NMLS call center at 240-386-4444). Federally regulated institutions should contact their federal regulator.
  3. Who should Sellers contact with system questions regarding the NMLS?

    The NMLS call center is available at 240-386-4444 to answer system questions.
  4. Is the state-issued loan originator’s license number required to be delivered to Freddie Mac?

    No. If the loan originator has a state-issued license number separate from the unique identifier provided by the NMLS, Freddie Mac only requires the delivery of the numeric unique identifier provided by the NMLS.
  5. If the Seller is a federally regulated institution, when will delivery of the loan originator and loan origination company Identifiers be required?

    Loan originator and loan origination company identifiers are required for loan applications on or after July 29, 2011.
  6. If a loan originator works for or in a branch office of a company, should the Seller deliver the branch identification (ID) or the company ID assigned by the NMLS for the loan origination company identifier?

    Sellers are required to deliver the loan origination company ID assigned by the NMLS. The Seller is not required to deliver the branch ID.
  7. What loan originator data should be delivered when Seller A originates and closes a loan and then sells that loan to Seller B?

    Seller A’s loan originator ID and loan origination company ID should be delivered. The loan originator ID and loan originator company ID that is delivered should be the loan originator that signed the application.
  8. What loan originator data should be delivered when Seller A originates a loan, but the loan closes in Seller B’s name?

    The loan originator ID and the loan origination company ID for Seller A should be delivered.
  9. What loan originator data should be delivered when Seller A takes a loan application to Seller B, who underwrites and closes the loan?

    The loan originator ID and loan origination company ID for Seller B should be delivered.
  10. If a Seller delivers mortgage loans without the loan originator and appraiser identifiers, will the selling system return an error or warning message?

    Effective January 1, 2011, Sellers began receiving warning edits at loan delivery if the appraiser identifier was not provided. Effective October 3, 2011, if the loan originator or loan origination company identifiers are not delivered, Sellers will receive a warning message.
  11. What should be entered in the loan originator identifier data field if a loan originator has received an exemption from obtaining or is not required to obtain a loan originator identifier?

    Freddie Mac recognizes that in limited instances a loan originator may be exempt from obtaining or is not required to obtain a loan originator identifier through the NMLS. If the loan originator is exempt from obtaining or is not required to obtain an identifier, the Seller should populate the data field with a value of "1000."
  12. Delaware, Maine, and Missouri do not currently require loan origination companies to obtain identifiers through the NMLS. What should be entered in the loan origination company identifier field if the company is located in one of these states?

    If a state regulated loan origination company does not have a NMLS ID because they operate solely in Delaware, Maine, or Missouri, the loan originator company identifier should be populated with the values below for the corresponding state.
    • Delaware = 1001
    • Maine = 1002
    • Missouri = 1003

    NOTE: The state of Maine is now requiring company registration through the NMLS. Therefore, for loans with Application Received Dates on or after August 1, 2013, lenders must begin delivering the loan originator ID and may not use “1002” in the data field.

Appraiser Identifier Requirements

  1. When a review appraisal is performed on a loan, which appraiser license number is required to be delivered?

    The license number of the appraiser whose appraisal was used to make an underwriting decision and approve the loan should be delivered.

  2. What information should the Seller provide to Freddie Mac if two appraisals are performed for a particular loan?

    The Seller should provide the license or certification number of the appraiser whose appraisal report and value conclusions were used to underwrite the loan and make the lending decision.
  3. What information should the Seller enter in the selling system’s appraiser state license number and supervisory appraiser state license number fields when a Loan Prospector Condition and Marketability Report (Form 2070) or a Desktop Underwriter Property Inspection Report (Form 2075) is completed (and no appraisal is performed)?

    Based on our current data requirements, the lender should enter the license or certification number of the appraiser who performed the inspection. For loans delivered on or after
    July 23, 2012, with application received dates on and after December 1, 2011, the lender must follow the conditionality requirements of the Uniform Loan Delivery Dataset (ULDD).
  4. If a loan is eligible to be delivered with a Property Inspection Alternative (PIA) or Relief Refinance property fieldwork waiver and no appraisal was performed, what should be entered in the selling system’s appraiser state license number and supervisory appraiser state license number fields?

    Based on our current data requirements, the term “Other” should be entered in the Appraiser State License Number and Supervisory Appraiser State License Number fields if the Seller is delivering a loan that was eligible to be delivered with a Property Inspection Alternative (PIA) or if the loan is a Freddie Mac Relief RefinanceSM Mortgage - Same Servicer and no appraisal was performed. 

    For loans delivered on or after July 23, 2012, with application received dates on and after December 1, 2011, the lender must follow the conditionality requirements of the ULDD.

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