source:
  type: regulation
  id: fnma-svc-a2-3-fees
  authority: "FNMA Servicing Guide A2-3-04 / A2-3-05 / A2-3-06 — Late Charge Reporting / Prohibited & Allowable Servicing Fees / Prepayment Premiums"
  description: 'FNMA Servicing Guide A2-3-04, A2-3-05, and A2-3-06 govern fees and

    premiums: monthly late-charge collection reporting via FNMA

    investor reporting system; categorically prohibited servicer fees

    (borrower disputes, routine collections, repayment/forbearance

    arrangement, breach letters, reinstatement-record updates);

    allowable additional-work fees (ownership change, insurance

    replacement, release, expedited service, duplicate payoff

    statements, phone pay, assumption consummation); ARM-adjustment

    fee restrictions; ARM-to-fixed conversion processing-fee caps

    ($100/$250); transfer-of-ownership and assumption fee schedule

    (cost-based + reasonableness); prepayment-premium prohibition

    except negotiated-contract loans; no-prepayment-premium-on-default-

    acceleration rule. Fills FNMA Servicing A2-3 fee chapter gap.

    '
obligations:
- id: fnma-svc-a2-3-04-report-late-charges-monthly
  canonical_id: fnma-svc-a2-3-04-report-late-charges-monthly
  section: "FNMA Servicing Guide A2-3-04 — Report monthly late charges collected via FNMA investor reporting"
  description: '[LENDER] (servicer) shall report the amount of late charges it

    collects each month for a given mortgage loan as part of the

    monthly activity information it provides through Fannie Mae''s

    investor reporting system. Late charge reporting is part of

    [LENDER]''s monthly investor-reporting submission.

    '
  type: do
  audit_question: Can [LENDER] reconcile (via investor reporting system submissions) every monthly late-charge collected against the per-loan amount reported to Fannie Mae?
  workflow_phase: investor_reporting
  owner_role: investor_reporting_manager
  secondary_owner_role: chief_servicing_officer
  cadence: monthly
  consequence: Under-reporting late charges shorts FNMA economics; over-reporting invites reconciliation discrepancies; both are Servicing Guide breaches.
  tags:
  - round-d
  - regulator-direct
  - fnma
  - servicer-operations
  - investor-reporting
  - late-charge-reporting
  - promoted
  primary_source:
    tier: 1
    authority: "FNMA Servicing Guide A2-3-04 — Late charge reporting"
    source_class: fnma-guide
    source_url: https://singlefamily.fanniemae.com/media/document/pdf/servicing-guide
    snapshot_id: f662f911b3ddaf1d
    fetched_at: '2026-05-25T14:09:40Z'
    content_hash: sha256:89df66c43baad07f8a8dd9d224492fff7d15e8839edba02ad0e74c7e50fe5da3
    paragraph_quote: 'The servicer must report the amount of late charges it collects each month for a given mortgage loan as part of

      '
    drafter_attestation: 'Copied verbatim from snapshot f662f911b3ddaf1d. A2-3-04 monthly-

      late-charge-reporting operative phrase. Quote truncated before

      "the monthly activity information it provides through Fannie

      Mae''s investor reporting system" (U+2019 in "Mae''s"); the

      investor-reporting-system delivery tail paraphrased in description.

      '
  promoted_at: '2026-05-25T20:47:39+00:00'
  promoted_from: fnma-svc-a2-3-fees-roundd-v1.yaml
  program_review: Does the program ensure monthly late charges collected per loan are reported through FNMA's investor reporting system as part of the monthly activity submission?
  file_review: Reconcile collected late charges against the per-loan amounts reported in investor reporting submissions.
  judgment: false
- id: fnma-svc-a2-3-05-no-borrower-fee-for-prohibited-servicing-activities
  canonical_id: fnma-svc-a2-3-05-no-borrower-fee-for-prohibited-servicing-activities
  section: "FNMA Servicing Guide A2-3-05 — Prohibited servicing fees (disputes, collections, repayment plans, breach letters, reinstatement records)"
  description: '[LENDER] (servicer) is NOT authorized to charge the borrower fees

    relating to the following activities: (1) handling borrower

    disputes; (2) facilitating routine borrower collections; (3)

    arranging repayment or forbearance plans; (4) sending borrowers

    notices (sometimes called "demand" or "breach" letters) relating

    to nonpayment of principal, interest, taxes, or insurance in

    advance of a formal acceleration notice; and (5) updating

    records to "reinstate" a mortgage loan that has been brought

    current.

    '
  type: refrain
  audit_question: For every borrower fee [LENDER] assessed during a servicing relationship, can [LENDER] evidence the fee is NOT for any prohibited activity (dispute handling, routine collections, repayment-plan arrangement, pre-acceleration breach letters, reinstatement-record updates)?
  workflow_phase: general_servicing_ops
  owner_role: chief_servicing_officer
  secondary_owner_role: compliance_officer
  cadence: continuous
  consequence: Charging prohibited fees is a Servicing Guide breach + UDAAP/state-law exposure; reputational risk in CFPB exams.
  tags:
  - round-d
  - regulator-direct
  - fnma
  - servicer-operations
  - prohibited-fees
  - udaap-risk
  - promoted
  primary_source:
    tier: 1
    authority: "FNMA Servicing Guide A2-3-05 — Prohibited Fees for Servicing"
    source_class: fnma-guide
    source_url: https://singlefamily.fanniemae.com/media/document/pdf/servicing-guide
    snapshot_id: f662f911b3ddaf1d
    fetched_at: '2026-05-25T14:09:40Z'
    content_hash: sha256:89df66c43baad07f8a8dd9d224492fff7d15e8839edba02ad0e74c7e50fe5da3
    paragraph_quote: 'The servicer is not authorized to charge the borrower fees relating to the following activities:

      '
    drafter_attestation: 'Copied verbatim from snapshot f662f911b3ddaf1d. A2-3-05 prohibited-

      servicing-fees operative chapeau. The five enumerated prohibited

      activities paraphrased in description (with operator-quoted

      "demand"/"breach"/"reinstate" terms preserved for compliance-

      officer clarity).

      '
  promoted_at: '2026-05-25T20:47:39+00:00'
  promoted_from: fnma-svc-a2-3-fees-roundd-v1.yaml
  program_review: Does the program ensure no borrower fee is charged for any prohibited activity — dispute handling, routine collections, repayment/forbearance arrangement, pre-acceleration breach/demand letters, or reinstatement-record updates?
  file_review: Sample assessed borrower fees; confirm none maps to a prohibited activity.
  judgment: false
- id: fnma-svc-a2-3-05-no-arm-rate-or-payment-change-fees
  canonical_id: fnma-svc-a2-3-05-no-arm-rate-or-payment-change-fees
  section: "FNMA Servicing Guide A2-3-05 — No fees for ARM interest rate or payment changes"
  description: '[LENDER] (servicer) may NOT charge fees for the interest rate or

    payment changes that are required periodically for ARM loans.

    [LENDER] may charge a processing fee to cover the administrative

    costs of converting an ARM loan to a fixed-rate mortgage loan,

    LIMITED to $100 for most ARM plans or $250 for ARM plans that

    include a monthly conversion option. Routine ARM resets are

    uncompensable.

    '
  type: refrain
  audit_function:
  audit_question: Can [LENDER] evidence (via fee schedules + Borrower account audits) that no fees were charged for routine ARM rate or payment changes? For any ARM-to-fixed conversion processing fees, were the $100 (most plans) / $250 (monthly-conversion plans) caps respected?
  workflow_phase: general_servicing_ops
  owner_role: chief_servicing_officer
  secondary_owner_role: compliance_officer
  cadence: per-arm-adjustment-or-conversion
  consequence: Charging Borrowers for ARM resets is a Servicing Guide breach + UDAAP risk; over-cap conversion processing fees similarly breach.
  tags:
  - round-d
  - regulator-direct
  - fnma
  - servicer-operations
  - arm-loans
  - no-rate-change-fee
  - conversion-fee-cap
  - promoted
  primary_source:
    tier: 1
    authority: "FNMA Servicing Guide A2-3-05 — Additional Fee Assessment Guidelines (ARM adjustments)"
    source_class: fnma-guide
    source_url: https://singlefamily.fanniemae.com/media/document/pdf/servicing-guide
    snapshot_id: f662f911b3ddaf1d
    fetched_at: '2026-05-25T14:09:40Z'
    content_hash: sha256:89df66c43baad07f8a8dd9d224492fff7d15e8839edba02ad0e74c7e50fe5da3
    paragraph_quote: 'may not charge fees for the interest rate or payment changes that are required periodically for ARM loans

      '
    drafter_attestation: 'Copied verbatim from snapshot f662f911b3ddaf1d. A2-3-05 no-ARM-

      rate-change-fee operative restriction. The $100/$250 ARM-to-fixed

      conversion-processing-fee caps paraphrased in description.

      '
  promoted_at: '2026-05-25T20:47:39+00:00'
  promoted_from: fnma-svc-a2-3-fees-roundd-v1.yaml
  program_review: Does the program ensure no fee is charged for routine ARM rate/payment changes, and that any ARM-to-fixed conversion processing fee respects the $100 (most plans) / $250 (monthly-conversion plans) caps?
  file_review: Review fee schedules and ARM borrower accounts; confirm no routine-reset fees and that conversion fees stayed within the $100/$250 caps.
  judgment: false
- id: fnma-svc-a2-3-05-fha-va-assumption-fee-follow-agency-max
  canonical_id: fnma-svc-a2-3-05-fha-va-assumption-fee-follow-agency-max
  section: "FNMA Servicing Guide A2-3-05 — FHA/VA assumption fees follow agency-specific maximums"
  description: 'For assumptions of FHA or VA mortgage loans, [LENDER] (servicer)

    shall follow FHA or VA requirements regarding the maximum

    allowable assumption fees for these government mortgage loans.

    Government-loan assumption fees are governed by agency

    schedules, not FNMA''s conventional-loan reasonable-fee

    schedule.

    '
  type: do
  audit_question: For every FHA or VA mortgage loan assumption [LENDER] processed, can [LENDER] evidence the assumption fee did NOT exceed the applicable FHA or VA maximum?
  workflow_phase: general_servicing_ops
  owner_role: chief_servicing_officer
  secondary_owner_role: compliance_officer
  cadence: per-fha-va-assumption
  consequence: Over-cap assumption fees on FHA/VA loans breach agency rules + Servicing Guide; can trigger refund obligations + agency enforcement.
  tags:
  - round-d
  - regulator-direct
  - fnma
  - servicer-operations
  - assumption-fees
  - fha-va-agency-caps
  - promoted
  primary_source:
    tier: 1
    authority: "FNMA Servicing Guide A2-3-05 — Additional Fee Assessment Guidelines (FHA/VA assumptions)"
    source_class: fnma-guide
    source_url: https://singlefamily.fanniemae.com/media/document/pdf/servicing-guide
    snapshot_id: f662f911b3ddaf1d
    fetched_at: '2026-05-25T14:09:40Z'
    content_hash: sha256:89df66c43baad07f8a8dd9d224492fff7d15e8839edba02ad0e74c7e50fe5da3
    paragraph_quote: 'must follow FHA or VA requirements regarding the maximum allowable assumption fees for these government mortgage loans.

      '
    drafter_attestation: 'Copied verbatim from snapshot f662f911b3ddaf1d. A2-3-05 FHA/VA-

      assumption-fee-follow-agency-max operative requirement.

      '
  promoted_at: '2026-05-25T20:47:40+00:00'
  promoted_from: fnma-svc-a2-3-fees-roundd-v1.yaml
  program_review: Does the program ensure FHA/VA loan assumption fees follow the applicable FHA or VA maximums rather than the conventional reasonable-fee schedule?
  file_review: For FHA/VA assumptions, confirm the assumption fee did not exceed the applicable agency maximum.
  judgment: false
- id: fnma-svc-a2-3-06-no-prepayment-premium-except-negotiated-contract
  canonical_id: fnma-svc-a2-3-06-no-prepayment-premium-except-negotiated-contract
  section: "FNMA Servicing Guide A2-3-06 — No prepayment premium except under negotiated-contract loans"
  description: '[LENDER] (servicer) shall NOT collect prepayment premiums from

    the borrower when a mortgage loan is paid in full. The

    categorical no-prepayment-premium rule applies UNLESS the

    mortgage loan was delivered under a negotiated contract that

    specifically permitted enforcement of the prepayment-premium

    provisions of the mortgage documents. Even then, no prepayment

    premium may be charged when the mortgage debt is accelerated

    as a result of the Borrower''s default.

    '
  type: refrain
  audit_question: "For every loan [LENDER] paid in full, can [LENDER] evidence (a) no prepayment premium collected — OR (b) negotiated-contract authorization existed AND the payoff was NOT a default-acceleration payoff?"
  workflow_phase: general_servicing_ops
  owner_role: chief_servicing_officer
  secondary_owner_role: compliance_officer
  cadence: per-payoff
  consequence: Collecting an unauthorized prepayment premium is a Servicing Guide breach + state-law/UDAAP exposure; charging on default-acceleration payoff is doubly improper.
  tags:
  - round-d
  - regulator-direct
  - fnma
  - servicer-operations
  - prepayment-premium
  - no-default-acceleration-charge
  - promoted
  primary_source:
    tier: 1
    authority: "FNMA Servicing Guide A2-3-06 — Prepayment Premiums"
    source_class: fnma-guide
    source_url: https://singlefamily.fanniemae.com/media/document/pdf/servicing-guide
    snapshot_id: f662f911b3ddaf1d
    fetched_at: '2026-05-25T14:09:40Z'
    content_hash: sha256:89df66c43baad07f8a8dd9d224492fff7d15e8839edba02ad0e74c7e50fe5da3
    paragraph_quote: 'The servicer must not collect prepayment premiums from the borrower when a mortgage loan is paid in full

      '
    drafter_attestation: 'Copied verbatim from snapshot f662f911b3ddaf1d. A2-3-06 no-

      prepayment-premium operative restriction. Negotiated-contract

      carve-out + no-charge-on-default-acceleration rule paraphrased in

      description (avoids U+2019 in "borrower''s default" and U+2014

      em-dash).

      '
  promoted_at: '2026-05-25T20:47:40+00:00'
  promoted_from: fnma-svc-a2-3-fees-roundd-v1.yaml
  program_review: Does the program ensure no prepayment premium is collected on payoff, accounting for the negotiated-contract carve-out and the prohibition on charging a premium when the debt is accelerated on default?
  file_review: For paid-in-full loans, confirm no prepayment premium — or negotiated-contract authorization existed and the payoff was not a default-acceleration payoff.
  judgment: false
_promotion_history:
- promoted_at: '2026-05-25T20:47:40+00:00'
  candidate_path: obligations\_remediation\round-d-investor-guides\fnma-svc-a2-3-fees-roundd-v1.yaml
  candidates_promoted: 5
  candidates_skipped_existing: 0
