Uniform Closing Dataset Q&As
Updated on February 24, 2015
- What is the primary goal of the UCD initiative?
- What resources are available to help me implement the UCD?
- Do I need to build the UCD now?
- Does Appendix B provide mapping only for data that is required on CFPB’s Closing Disclosure?
- Is Appendix B 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?
- Is Appendix I identical for both Freddie Mac and Fannie Mae?
- When will the GSEs begin collecting the UCD?
- 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?
- 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?
- 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?
- For loans that require a new Closing Disclosure to be issued to the Borrower after settlement (e.g., redisclosure), will the GSEs require new Borrower and Seller signatures?
- On refinance transactions, will the GSEs require the use of the ‘alternate’ form – Form H25-(E) – published by the CFPB? (Refer to Federal Register vol. 78, No. 251 on p. 80203).
- 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?
- How will I deliver the UCD?
- 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 goal of the UCD is to develop an industry-wide standardized dataset to communicate the Consumer Financial Protection Bureau’s (CFPB) Closing Disclosure information. This dataset will facilitate data exchanges between vendors, lenders, investors and other parties. The UCD is intended to improve data quality, transmission efficiency, and reduce risk for all parties.
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
Yes. The GSEs recommend that lenders begin working with their vendors and services 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 have also 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 to support the information captured on the Closing Disclosure.
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. The GSEs have provided Appendix I: UCD Delivery Specification, which 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).
Yes. The GSEs developed a single delivery specification for the UCD. The UCD XML file will be identical whether it is submitted to Fannie Mae or to Freddie Mac.
While the CFPB will require lenders to use the Closing Disclosure for applications received on or after August 1, 2015, the GSEs will provide the industry with additional time to implement the corresponding UCD and will not require delivery of the UCD in 2015. More information about the GSEs’ mandated delivery date will be provided in future communications.
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.
Yes, the GSEs will require that a PDF copy of the signed Closing Disclosure be embedded in UCD XML file. The GSEs will require both Borrower and Seller signatures on the Closing Disclosure.
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. Each Closing Disclosure must be signed by the Borrower(s) and Seller(s). 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.
Yes. While the Closing Disclosure does not contain a line for the Seller’s signature, per the Regulation, lenders are permitted to use a separate page (i.e., an addendum) for Seller signatures. Lenders will be required to submit this separate addendum containing the Seller’s signature along with the Borrower-signed Closing Disclosure when they deliver the UCD to the GSEs.
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.
No. The GSEs will not require signatures on any post-closing redisclosures.
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.
The GSEs are evaluating the best delivery mechanism for the UCD and will provide more information in Q1 2015.
Yes, the GSEs will provide a testing environment. We will share the details at a later date.
Yes, the GSEs will provide XML file formation validation upon delivery of the UCD. The GSEs will provide the industry with sufficient notice regarding the implementation and enforcement of validations or 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.