source:
  type: guide
  id: fhlmc-9501.3
  authority: Freddie Mac Single-Family Seller/Servicer Guide Section 9501.3 — Firm
    selection and retention
  description: Freddie Mac Single-Family Seller/Servicer Guide Section 9501.3 — Firm
    selection and retention.
  coverage_tier: operative
obligations:
- id: fhlmc-9501.3-full
  canonical_id: fhlmc-9501.3-full
  section: Freddie Mac Single-Family Seller/Servicer Guide Section 9501.3 — Firm selection
    and retention
  type: do
  tags:
  - regulator-direct
  - fhlmc
  - freddie-guide
  - corpus-expansion
  - tier-operative
  primary_source:
    tier: 1
    authority: Freddie Mac Single-Family Seller/Servicer Guide Section 9501.3 — Firm
      selection and retention
    source_class: fhlmc-guide
    source_url: https://guide.freddiemac.com/ci-guide
    snapshot_id: 5869ee9e606cd4ae
    fetched_at: '2026-05-23T00:27:40Z'
    content_hash: sha256:9a1b23e5024bb369e7a59d36b3702383c11ace68b5d209fdef791bc8f955c637
    paragraph_quote: '9501.3: Firm selection and retention (09/10/25) This section
      contains requirements related to: ■ Selection of firm ■ Retention of firm (a)
      Selection of firm (i) Servicer selects firm If the Servicer determines that
      a firm meets the Firm Minimum Requirements specified in Section 9501.2 and all
      other Guide requirements, then the Servicer must complete and submit a Servicer
      Selection Form to Freddie Mac via https://www.freddiemacsats.com/Security/Login
      and receive Freddie Mac’s “no objection” determination before entering into
      an agreement with a firm to handle Freddie Mac Default Legal Matters. If Freddie
      Mac requests additional information from the Servicer as part of this process,
      the Servicer must provide the requested information within the time frame requested
      by Freddie Mac. Servicers may not rely upon a previous submission of a Servicer
      Selection Form by another Servicer with respect to a firm that received a “no
      objection” determination. Each Servicer must: ■ Conduct its own due diligence
      ■ Submit a Servicer Selection Form; and Freddie Mac Single-Family Seller/Servicer
      Guide Chapter 9501 As of 09/10/25 Page 9501-15 ■ Receive a “no objection” determination
      for each firm that the Servicer wishes to retain to handle Freddie Mac Default
      Legal Matters If a firm practices in multiple jurisdictions, the Servicer must
      submit a Servicer Selection Form for each jurisdiction for which the Servicer
      wishes to retain the firm. (ii) Servicer Attorney Tracking System (SATS) registration
      Servicers must use SATS, an online process, to submit a Servicer Selection Form
      to Freddie Mac for each law firm selected to handle Freddie Mac Default Legal
      Matters. To establish access to SATS, Servicers must first register to create
      a user ID and password at https://www.freddiemacsats.com/Security/Login. After
      completing the registration process, SATS will allow users to submit the information
      required in the Servicer Selection Form to Freddie Mac for review. SATS will
      also allow Servicers to respond to Freddie Mac’s requests for additional information,
      as necessary, and will allow Servicers to track each submission’s status during
      the review process. Freddie Mac will not review any Servicer Selection Form
      completed and submitted to any Freddie Mac e-mail address. Servicers must complete
      and submit the Servicer Selection Form via https://www.freddiemacsats.com/Security/Login.
      (iii)Freddie Mac review of Servicer Selection Form After Freddie Mac receives
      the Servicer Selection Form, Freddie Mac will notify the Servicer via the Servicer’s
      registered e-mail address with SATS whether Freddie Mac: ■ Objects to the Servicer’s
      retention of the firm to handle Freddie Mac Default Legal Matters ■ Has no objection
      to Servicer’s retention of the firm to handle Freddie Mac Default Legal Matters;
      or ■ Needs additional information or documentation or due diligence to be conducted
      before deciding whether the firm may be retained. If requested, the Servicer
      must provide any additional information or documentation to Freddie Mac via
      https://www.freddiemacsats.com/Security/Login and must conduct any further due
      diligence requested by Freddie Mac within the time period stated in Freddie
      Mac’s request. Freddie Mac Single-Family Seller/Servicer Guide Chapter 9501
      As of 09/10/25 Page 9501-16 (iv) Freddie Mac’s response to Servicer firm selection
      (A) Freddie Mac provides a “no objection” response The Servicer must enter into
      a contract with the firm (if a contract does not already exist) as further specified
      in Section 9501.3(b) to handle Freddie Mac Default Legal Matters. (B) Freddie
      Mac provides an “objection” response If the Servicer determines not to retain
      a particular firm or if Freddie Mac objects to the retention of a particular
      firm, the Servicer must notify the firm that the firm cannot be hired for Freddie
      Mac Default Legal Matters. (v) The Servicer decides not to retain firm The Servicer
      is not obligated to inform Freddie Mac: ■ If the Servicer determines that a
      firm does not meet the Firm Minimum Requirements; or ■ If the Servicer decides
      not to retain a firm (vi) Diversity Servicers are reminded that they must be
      aware of and comply with Freddie Mac’s requirements in Sections 1201.10 and
      1301.2. The Servicer must commit to practice the principles of equal employment
      opportunity and non-discrimination in all its business activities, including
      the retention and hiring of firms retained pursuant to this section. (b) Retention
      of firm (i) Servicer contract with firm If the Servicer has not already entered
      into a contract with a selected firm and Freddie Mac has provided a “no objection”
      determination, then the Servicer must: ■ Enter into a contract with the firm
      ■ Notify Freddie Mac when the contract has been executed by updating SATS via
      https://www.freddiemacsats.com/Security/Login, and ■ Provide a copy of the contract
      to Freddie Mac, upon request (ii) Freddie Mac limited retention agreement with
      firm Freddie Mac Single-Family Seller/Servicer Guide Chapter 9501 As of 09/10/25
      Page 9501-17 Freddie Mac will enter into a limited retention agreement that
      sets forth certain key retention provisions with each selected firm for each
      jurisdiction in which the firm has received a “no objection” determination.
      (iii)Conflict between Servicer’s contract and limited retention agreements;
      Servicer’s respective consent The Servicer acknowledges that the limited retention
      agreement recognizes and reflects a joint attorney-client relationship between
      the law firm, Freddie Mac and the Servicer, and the Servicer consents to such
      joint representation. The Servicer consents, in advance, to the selected firm’s
      representation of Freddie Mac in any Freddie Mac Default Legal Matter that is
      or might be adverse to the Servicer, and the Servicer further agrees that the
      firm can use in such representation any information the firm gained in the course
      of jointly representing the Servicer and Freddie Mac. In the event of any inconsistency
      or conflict between the terms and conditions of the Servicer’s contract with
      the selected firm and the terms and conditions of Freddie Mac’s limited retention
      agreement with the firm, Freddie Mac’s limited retention agreement shall control.
      9501.4: Firm training requirements, referrals and prohibitions related to Freddie
      Mac default legal matters (09/10/25) This section contains requirements related
      to: ■ Training of firms ■ Referral of Freddie Mac Default Legal Matters to firm
      ■ Prohibitions related to Freddie Mac Default Legal Matters (a) Training of
      firms (i) Training prior to referral The Servicer must not refer any Freddie
      Mac Default Legal Matters to a firm until the Servicer verifies that the firm
      has executed a limited retention agreement with Freddie Mac and has completed
      Freddie Mac’s new firm training. A firm is only required to attend Freddie Mac’s
      new firm training once, regardless of the number of Servicers that select and
      retain the firm. Freddie Mac Single-Family Seller/Servicer Guide Chapter 9501
      As of 09/10/25 Page 9501-18 (ii) Ongoing training The Servicer must ensure that
      each firm obtains appropriate training to keep the firm apprised of updated
      Freddie Mac requirements. If the Servicer provides its own standard training
      and/or other communication materials to a firm, the Servicer must include information
      regarding Freddie Mac’s requirements. (b) Referral of Freddie Mac Default Legal
      Matters to firm (i) Requirements prior to referral Prior to referring a Freddie
      Mac Default Legal Matter to a firm, the Servicer must confirm that the firm
      is eligible to receive a referral by ensuring that: ■ The firm meets the Firm
      Minimum Requirements, as specified in Section 9501.2 ■ Freddie Mac has provided
      a “no objection” determination, as specified in Section 9501.3(a) ■ The firm
      has executed a contract with the Servicer requiring the firm to comply with
      all applicable Freddie Mac requirements, as specified in Section 9501.3(b) ■
      The firm has executed a limited retention agreement with Freddie Mac, as specified
      in Section 9501.3(b) ■ The firm has completed Freddie Mac training and any additional
      Servicer training, as specified in Section 9501.4(a); and ■ There are no conflicts
      of interest with respect to the retention of the firm and referral of Freddie
      Mac Default Legal Matters to the firm (ii) Diversification of referrals The
      Servicer must diversify its referrals of Freddie Mac Default Legal Matters to
      an appropriate number of firms in each jurisdiction to protect the interests
      of Freddie Mac and to mitigate the risks related to a high concentration of
      Freddie Mac files. In selecting firms for referrals, the Servicer must consider
      firm capacity and management of staff to file ratios. (iii)Bankruptcy and foreclosure
      matters The Servicer must not refer foreclosure matters directly to trustees
      listed on the deeds of trust. Note: Refer to Section 9401.3(b) for additional
      referral requirements. Freddie Mac Single-Family Seller/Servicer Guide Chapter
      9501 As of 09/10/25 Page 9501-19 (iv) Providing documentation to firm The Servicer
      must identify a file as a Freddie Mac Default Legal Matter when sending the
      file to a firm. When referring a file to a firm, the Servicer must provide all
      documentation required to initiate a foreclosure. If the firm requests any additional
      information and/or documentation at any time, the Servicer must provide such
      requested information and/or documents within three Business Days after receipt
      of the request or within such earlier time frame, if necessary, to comply with
      timing requirements under applicable law or court orders and procedures. For
      any Mortgage that the Servicer refers for foreclosure that is subsequently repurchased
      by the Servicer, whether voluntarily or involuntarily, the Servicer must notify
      foreclosure and/or bankruptcy counsel within two Business Days of the completed
      repurchase. Note: See Chapter 3602 for additional information about repurchases.
      (v) Contingency plan All Servicers must have a contingency plan in place, either
      in the form of a standalone document or incorporated into policies and procedures,
      to redirect new foreclosure and bankruptcy referrals. (c) Prohibitions related
      to Freddie Mac Default Legal Matters Servicers must not require the firm to
      perform any foreclosure or bankruptcy-related services on any Freddie Mac Default
      Legal Matter without compensation. (i) Prohibition against charging for, contracting
      for or making arrangements to receive benefits for Servicing obligations A Servicer,
      whether acting directly or through an affiliate, service provider, vendor or
      outsourcing company, must not directly or indirectly: ■ Charge Freddie Mac or
      the firm for any foreclosure or bankruptcy-related Servicing obligations, including
      expenses covered by the Servicing Spread; or ■ Contract or make any arrangements
      with the firm whereby the Servicer (or its affiliate, service provider, vendor
      or outsourcing company) receives, directly or indirectly, any financial or other
      benefits (including, but not limited to, payments, the provision of employees
      or free or discounted services or products) from the firm in connection with
      any Freddie Mac Default Legal Matter or Freddie Mac-owned or guaranteed Mortgage
      Note: Refer to Section 8103.2(b) for additional information on Servicing obligations.
      Freddie Mac Single-Family Seller/Servicer Guide Chapter 9501 As of 09/10/25
      Page 9501-20 (ii) Prohibitions with respect to use of specific vendors, services
      and/or products The Servicer, and not a service provider, vendor or outsourcing
      company assisting the Servicer in Servicing defaulted Mortgages, must select
      the firm to handle Freddie Mac Default Legal Matters, and Servicers must not
      permit service providers, vendors, outsourcing companies or others to participate
      in or influence, in any way, the Servicer’s referral process. A Servicer must
      not, whether acting directly or through an affiliate, service provider, vendor
      or outsourcing company: ■ Require the firm to contract with or use a particular
      service provider, vendor or outsourcing company or to use or pay for a particular
      service or product ■ Refuse to refer a file to the firm because the firm chooses
      not to contract with or use a particular service provider, vendor or outsourcing
      company or chooses not to use or pay for a particular service or product; or
      ■ Charge the firm for any aspect of the file referral or management process,
      including, but not limited to, the use of connectivity or invoice processing
      systems (e.g., licensing or subscription fees, “click” charges or any other
      payment) in order for the firm to provide services necessary to handle Freddie
      Mac Default Legal Matters (e.g., to prosecute the foreclosure or bankruptcy
      case) However, a Servicer may require the firm to use certain connectivity or
      invoice processing systems, provided that the firm is not required to pay for
      the use of or access to such systems. Note: Refer to Section 9501.5(a) for information
      about use of and reimbursement for connectivity and invoice processing systems.'
  judgment: false
