source:
  type: guide
  id: fnma-svc-a4-2.2-04
  authority: Fannie Mae Servicing Guide A4-2.2-04 — Law Firm Suspensions, Matter Transfers,
    and Terminations
  description: Fannie Mae Servicing Guide A4-2.2-04 — Law Firm Suspensions, Matter
    Transfers, and Terminations.
  coverage_tier: operative
obligations:
- id: fnma-svc-a4-2.2-04-full
  canonical_id: fnma-svc-a4-2.2-04-full
  section: Fannie Mae Servicing Guide A4-2.2-04 — Law Firm Suspensions, Matter Transfers,
    and Terminations
  type: do
  tags:
  - regulator-direct
  - fnma
  - servicing-guide
  - corpus-expansion
  - tier-operative
  primary_source:
    tier: 1
    authority: Fannie Mae Servicing Guide A4-2.2-04 — Law Firm Suspensions, Matter
      Transfers, and Terminations
    source_class: fnma-guide
    source_url: https://singlefamily.fanniemae.com/media/document/pdf/servicing-guide
    snapshot_id: cf63a82bbb4adfba
    fetched_at: '2026-05-22T23:53:19Z'
    content_hash: sha256:89df66c43baad07f8a8dd9d224492fff7d15e8839edba02ad0e74c7e50fe5da3
    paragraph_quote: 'A4-2.2-04, Law Firm Suspensions, Matter Transfers, and Terminations
      (08/15/2018) Introduction This topic contains the following: Servicer-Directed
      Suspensions Fannie Mae-Directed Suspensions Implementation of Suspensions Servicer-Directed
      Suspensions The following table provides instructions for the servicer regarding
      the suspension of referrals, law ﬁrm matter transfers, and termination of law
      ﬁrms. If… Then the servicer must… the servicer becomes aware of information
      regarding a law ﬁrm handling Fannie Mae default-related matters that might warrant
      a suspension of referrals, the transfer of matters to another law ﬁrm, and/or
      the termination of the law ﬁrm (for example, due to legal, reputational, or
      operational risk) • notify Fannie Mae within two business days or sooner if
      circumstances warrant as set forth in Escalations of Law Firm and Servicer Issues
      and Government and Media Inquiries in A4-2.2-02, Law Firm Management and Oversight,
      and • conduct due diligence with respect to the issue. Published May 13, 2026
      160 If… Then the servicer must… the servicer intends to suspend referrals and/or
      terminate a law ﬁrm • provide Fannie Mae with prior notice at least ﬁve business
      days before implementing the decision, • provide Fannie Mae with the implementation
      plan for the course of action chosen by the servicer, • inform the law ﬁrm of
      the decision, and • keep Fannie Mae periodically updated with respect to the
      status of implementation of the decision. the servicer is transferring matters
      to another law ﬁrm refer to Servicing Guide E-1.1-01, General Requirements for
      Referring a Mortgage Loan to a Law Firm for the requirements for notifying Fannie
      Mae of the transfer of default-related matters. The servicer must retain all
      information relating to its due diligence review, its decision, and all other
      information supporting its decision for the longer of any retention period applicable
      to the servicer, or seven years after the decision. The servicer must make such
      information available to Fannie Mae upon request. Fannie Mae-Directed Suspensions
      Fannie Mae reserves the right to direct the servicer to initiate an investigation
      of a law ﬁrm if it becomes aware of information that might warrant a suspension
      of referrals, the transfer of law ﬁrm matters, or termination of the law ﬁrm.
      Fannie Mae may itself conduct due diligence and investigations as necessary,
      and may instruct the servicer to suspend some or all new referrals, to transfer
      some or all of its matters, or to terminate law ﬁrms. In the event of a decision
      by Fannie Mae to suspend new referrals, transfer matters, or terminate a law
      ﬁrm, Fannie Mae will inform the servicer of the decision and provide direction
      regarding required servicer actions. Implementation of Suspensions The servicer
      is responsible for implementing any suspension, transfer of law ﬁrm matters,
      and/or termination unless otherwise directed by Fannie Mae. The servicer must
      consider all pertinent factors when determining the proper implementation strategy
      for any suspension, law ﬁrm matter transfers, and/or termination, including:
      the capacity of other eligible law ﬁrms in the jurisdiction to handle additional
      capacity and/or transferred Published May 13, 2026 161 matters, the proration
      of fees between the transferor and transferee law ﬁrms, avoiding duplicative
      fees and costs as a result of any transfer, and the continuing availability
      of adequate errors and omissions coverage for a law ﬁrm as to which some matters
      are left for resolution following a suspension of referrals or partial transfer
      of matters. With respect to any required matter transfer, the servicer must
      take all required steps to eﬀectuate, manage, and monitor the transfer and report
      periodically to Fannie Mae regarding the identity of each transferee law ﬁrm,
      the identiﬁcation and quantiﬁcation of the matters transferred to each transferee
      law ﬁrm, and the timing and status of the law ﬁrm matter transfer. The servicer
      must not charge Fannie Mae or the borrower for any fees or costs associated
      with transferring matters, and such amounts must not be added to the borrower’s
      total indebtedness. Fannie Mae reserves the right to manage any suspension,
      transfer of matters, and/or termination if it concludes that Fannie Mae''s management
      is necessary to manage legal, reputational, or operational risks. The servicer
      must follow all reasonable instructions given by Fannie Mae. Recent Related
      Announcements There are no recently issued Announcements related to this topic.
      Published May 13, 2026 162 Part B, Escrow, Taxes, Assessments, and Insurance
      Introduction This part describes how to administer an escrow account to manage
      taxes, assessments, and insurance requirements. Published May 13, 2026 163 Chapter
      B-1, Escrow Account Administration Introduction This chapter describes escrow
      account administration.'
  judgment: false
