Uniform Closing Dataset Q&As
Updated on June 30, 2015
- What is the UCD?
- What are the benefits of the UCD?
- Why are the GSEs collecting the UCD data?
- What resources are available to help me implement the UCD?
- Do I need to build the UCD now?
- Do Appendix B and Appendix I provide mapping only for data that is required on CFPB's Closing Disclosure?
- Are Appendix B and Appendix I identical for both Freddie Mac and Fannie Mae?
- Did the GSEs develop a dataset for the CFPB's Loan Estimate?
- Does Appendix B provide all the information I need to create the XML file that the GSEs will require at delivery?
- When will the GSEs begin collecting the UCD?
- Will the GSEs implement their separate collection solutions at the same time?
- Will the UCD Delivery Specification continue to be the same for both GSEs?
- The UCD contains a dozen or so Ability-to-Repay (ATR) data points marked as "GSE Requirement" in Appendix B. Will these data points need to be included in the UCD delivery file?
- Will a copy of the signed Closing Disclosure be required by the GSEs in addition to the UCD XML file?
- Why do the GSEs need a copy of the Closing Disclosure?
- If there were two separate Closing Disclosure documents presented at settlement, one for the Borrower and one for the Seller, do I include both in the XML file?
- Why do you need the Seller Closing Disclosure documents?
- There is no place for the Seller's signature on the Closing Disclosure form. Will the GSEs still require the Seller's signature?
- If subsequent to the closing, the lender discovers an issue that requires a new Closing Disclosure to be issued to the Borrower, (e.g., redisclosure), will the GSEs require redelivery of the UCD and Closing Disclosure?
- On refinance transactions, will the GSEs require the use of the "alternate" form – Form H-25(E) – published by the CFPB? (Refer to Federal Register vol. 78, No. 251 on p. 80187).
- If the transaction involves a simultaneous second (e.g., an 80/10/10 transaction), will the GSEs require delivery of the Closing Disclosure for the simultaneous second even if they are not purchasing the second lien?
- Will the GSEs provide a testing environment as vendors and lenders build to the UCD?
- Will the GSEs provide validation that a lender or vendor's XML file formation is correct?
- How can I ensure that my vendors and business partners have all the information they need to implement the UCD?
The UCD is a common industry dataset that allows information on the Consumer Financial Protection Bureau's (CFPB's) Closing Disclosure to be communicated electronically. The GSEs have developed the UCD at the direction of the Federal Housing Finance Agency as part of the Uniform Mortgage Data Program® (UMDP), an ongoing initiative to enhance loan quality and consistency through uniform loan data standards for the single-family loans the GSEs purchase.
The GSEs developed the UCD to improve the accuracy of how the Closing Disclosure information is communicated. Standardizing the underlying data through the use of the UCD will help promote accuracy, consistency, and clarity around the loan transaction.
Over time, the UCD will provide the following benefits:
- Greater data consistency by promoting better and more efficient data integration and exchange across business partners.
- A common understanding, as all parties use a consistent approach and language to describe the information on the Closing Disclosure.
- Improved data accuracy because the UCD will eliminate the need for proprietary formats that can be costly to maintain and can lead to misinterpretation of the data.
The GSEs are collecting UCD data because it:
- Helps enhance credit risk management with more data and better quality data.
- Provides important information to help increase our ability to detect fraud and misrepresentation at loan delivery.
- Provides additional transparency into the mortgage loan transaction file to help assess whether the loan, as closed, meets the GSEs' eligibility requirements.
The GSEs have published a number of implementation materials and artifacts on their Fanniemae.com and Freddiemac.com websites to assist you with your UCD implementation. These materials include:
- Appendix A: Closing Disclosure Mapping to the MISMO v3.3 Reference Model
- Appendix B: Closing Disclosure Mapping to the MISMO v3.3 Reference Model
- Appendix C: Closing Disclosure with Reference Numbers
- Appendix D: UCD Cardinality – Retired and included as a tab in the UCD Delivery Specification
- Appendix E: UCD Implementation Guide
- Appendix F: UCD Sample Use Cases
- Appendix G: UCD Sample XML Files – Coming soon
- Appendix H: UCD Delivery Specification
- Appendix I: UCD Delivery Specification
- UCD Tutorial
The GSEs strongly recommend that lenders begin working with their vendors and service providers now to implement and use the UCD for data exchange. We have published the UCD mapping document, Appendix B: Closing Disclosure Mapping to the MISMO v3.3 Reference Model, to help the industry understand the MISMO data that supports the Closing Disclosure. The GSEs also have published a GSE delivery specification for the UCD, Appendix I: UCD Delivery Specification to assist the industry with correctly forming a UCD delivery file. In 2016, the GSEs will expect lenders to begin using the UCD in their internal processes.
No. Appendix B also contains a limited number of additional data points that the GSEs will require over and above the fields on the CFPB's Closing Disclosure, as well as data points required to properly form the XML file. The remaining UCD data maps directly to the Closing Disclosure.
Yes. Using CFPB's Integrated Mortgage Disclosures regulation, the GSEs developed a single dataset and UCD delivery specification to support the information captured on the Closing Disclosure. The UCD XML file will be identical whether it is submitted to Freddie Mac or to Fannie Mae.
No. However, there is a corresponding dataset for the CFPB's Loan Estimate form that the MISMO Origination Workgroup developed. The GSEs' goal is for the UCD and Loan Estimate dataset to align on common information needed for both forms, and for both to leverage the MISMO v3.3 Reference Model. To access the Loan Estimate dataset, visit the MISMO website and sign up for the Origination Workgroup.
No. Appendix I: UCD Delivery Specification includes additional details necessary to create the XML file for delivery to the GSEs. Appendix I is also presented in XML file order and provides greater clarity regarding the data that must be delivered according to transaction type (e.g., Purchase vs. Non-seller/refinance).
The GSEs will implement separate collection solutions for lenders to start delivering the UCD no later than the 4th quarter of 2016 and will mandate the delivery of the UCD beginning in the 2nd quarter of 2017 for all loans acquired by Fannie Mae or Freddie Mac.
Additional information on the UCD implementation timeline and milestones will be provided by the end of 2015. The GSEs are providing this high-level timeline now so lenders and technology vendors can begin project planning and budgeting for the implementation of UCD in 2016.
Each GSE will have different system implementation and testing timelines for its collection solution. In addition, each GSE will provide separate training and support materials designed for its collection solution.
Yes. Even though the GSEs will be implementing separate UCD collection solutions, the GSEs will adhere to the guiding principles established under the UMDP, which include alignment on the following items:
- Each GSE is using the identical UCD Delivery Specification; there are no Freddie Mac- or Fannie Mae-specific data requirements.
- The UCD XML file contains the same data points, enumerations, and conditionality.
- The UCD timelines are identical. The GSEs will implement separate collection solutions no later than the 4th quarter of 2016 and will mandate the delivery of the UCD in the 2nd quarter of 2017.
- The GSEs will provide adequate time for testing, and will support lenders and vendors implementing the UCD with resources and training.
Yes, the data points designated as "GSE Requirement" in both Appendix B and Appendix I must be included in the XML file. This requirement will be enforced for all loan types whether the loan is for a primary residence, second home, or investment property.
At present, the GSEs do not intend to require signatures on the Closing Disclosure or any associated addendum. Lenders may wish to continue current industry practices of obtaining seller and other interested party signatures in accordance with the requirements of the CFPB rule.
The GSEs will require that a PDF copy of the final Closing Disclosure that was presented to the borrower and seller at settlement, including any associated addendums to the Closing Disclosure, be embedded in the UCD XML file.
The Closing Disclosure is the definitive record of the fees, charges, and adjustments that occurred in the loan transaction. As such, it is used to validate that the information in the UCD is accurate and correct.
Yes. Both the Borrower and Seller Closing Disclosure documents must be included in the UCD XML delivery file if there were two separate documents provided at closing. Note: The XML delivery file must contain both the Borrower-only and Seller-only PDF documents as well as the corresponding UCD dataset for each document.
The GSEs will need the Seller Closing Disclosure document to help verify the information that appears on the Borrower Closing Disclosure document is accurate and that there are no discrepancies.
At present, the GSEs do not intend to require the Seller’s or any other party's, signature on the Closing Disclosure or any associated addendum; however, lenders may wish to continue current industry practices of obtaining seller and other interested party signatures as they deem necessary.
If subsequent to the closing, the lender discovers an issue that requires a new Closing Disclosure to be issued to the Borrower, (e.g., redisclosure), will the GSEs require redelivery of the UCD and Closing Disclosure?
The GSEs are reviewing their policies to identify specific changes that would require redelivery. We will communicate more about these requirements at a later date.
Yes. The GSEs will require use of form H25-(E) for all refinance transactions on the loans they acquire.
If the transaction involves a simultaneous second (e.g., an 80/10/10 transaction), will the GSEs require delivery of the Closing Disclosure for the simultaneous second even if they are not purchasing the second lien?
No. At this time, neither GSE will collect the separate Closing Disclosure for any simultaneous second that is part of the transaction. The GSEs will require delivery of the Closing Disclosure for only the loan being purchased.
Yes, the GSEs will provide a testing environment. We will share the details at a later date.
Yes, the GSEs will validate the UCD XML file formation against the MISMO v3.3.0 Reference Model schema upon delivery. The GSEs will provide the industry with sufficient notice regarding the implementation and enforcement of any business rule messaging.
Encourage your closing vendors to visit Fannie Mae's UCD Web page or Freddie Mac's UCD Web page. They can view current information, including Appendix B: Closing Disclosure Mapping to the MISMO v3.3 Reference Model, and the accompanying Appendix I: UCD Delivery Specification and register to receive ongoing news and information to support their UCD implementations.