Freddie Mac issued Bulletin 2019-21 (Bulletin), extending the implementation date of Servicing Gateway and the mandatory adoption of the Servicing Data Corrections Tool. Per the Bulletin, the implementation and mandatory adoption date is now December 9, 2019 (rather than November 25, 2019).
Freddie Mac also amended document custody requirements. As outlined in the Bulletin, Freddie Mac is substantially rewriting Chapter 8107 of the Seller/Servicer Guide to provide more information and specificity regarding the release of Notes and documents by, and their return to, document custodians.
In addition, Freddie Mac:
- Amended requirements with respect to transfers of custody and subsequent transfers of servicing;
- Revised the process for settling charge-offs via Workout Prospector;
- Updated requirements relating to Freddie Mac’s access to mortgage records held by third parties;
- Clarified that borrowers who reach the applicable delinquency threshold (60 days delinquent for a Step-Rate mortgage, or 90 days delinquent for all other mortgages) remain eligible for a streamlined Flex Modification even if one or more payments subsequently results in the borrower becoming less delinquent than the eligibility delinquency threshold;
- Clarified that coupling a partial reinstatement with a repayment plan is considered a best practice, but is not mandatory;
- Revised Section 9401.3 to more closely align with the bankruptcy cramdown requirements announced in Bulletin 2019-18.
Revisions with respect to transfer of custody, subsequent transfers of servicing requirements and certain document custodian requirements are effective January 2, 2020. All other revisions are effective immediately.
