source:
  type: regulation
  id: gnma-mbs-ch04
  authority: "Ginnie Mae MBS Guide Chapter 4 — Issuers and Subservicers: Responsibilities"
  description: "GNMA MBS Guide Chapter 4 — Issuer / subservicer responsibilities for each\npool or loan package: only one Issuer of record, subservicing framework,\nnondelegable-responsibility list, Issuer liability for subservicer acts.\n"
obligations:
- id: gnma-mbs-ch04-issuer-liable-for-subservicer
  canonical_id: gnma-mbs-ch04-issuer-liable-for-subservicer
  section: "Ginnie Mae MBS Guide Ch. 4, Part 2, Section B — Subservicing"
  description: '[ISSUER] remains fully responsible for the performance of any

    servicing functions that have been delegated to a subservicer.

    [ISSUER] is liable to Ginnie Mae for any representations or

    omissions submitted on its behalf by a subservicer, including those

    reflected on the Issuer''s monthly report of pool and loan data and

    on the Issuer''s Monthly Reporting Certification in RFS.

    '
  type: do
  audit_question: "For every servicing function [ISSUER] has delegated to a subservicer, can [ISSUER] evidence that it retained full responsibility for performance and accepted liability to Ginnie Mae for the subservicer’s representations and omissions on RFS Monthly Report of Pool and Loan Data and Monthly Reporting Certification?"
  workflow_phase: servicing
  owner_role: compliance_officer
  secondary_owner_role: default_servicing_analyst
  cadence: continuous
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - gnma
  - mbs-guide
  - ch04
  - subservicing
  - issuer-liability
  - promoted
  primary_source:
    tier: 1
    authority: "Ginnie Mae MBS Guide Chapter 4, Part 2, Section B — Subservicing"
    source_class: gnma-mbs-guide
    source_url: https://www.ginniemae.gov/issuers/program_guidelines/MBSGuideLib/Chapter_04.pdf
    snapshot_id: 997eb6a60a668b0b
    fetched_at: '2026-05-23T00:30:00Z'
    content_hash: sha256:ac32fb29be9891c64ad2e225aa3aba5a6267fead22a3324b32f9dd0ccda07f9b
    paragraph_quote: remains fully responsible for the performance of any servicing functions that have been
    drafter_attestation: Copied verbatim from GNMA MBS Guide Chapter 4 snapshot 997eb6a60a668b0b at 2026-05-23.
  promoted_at: '2026-05-23T01:32:22+00:00'
  promoted_from: gnma-mbs-ch04-roundb-v1.yaml
  program_review: Does the program's subservicer oversight reflect that the Issuer remains fully responsible for delegated servicing and liable to Ginnie Mae for the subservicer's representations/omissions, including on the RFS Monthly Report of Pool and Loan Data and Monthly Reporting Certification?
  file_review: Review the subservicer oversight program; the compliance person judges whether it is calibrated to full Issuer liability for the subservicer's RFS representations and omissions.
  judgment: true
- id: gnma-mbs-ch04-nondelegable-responsibilities
  canonical_id: gnma-mbs-ch04-nondelegable-responsibilities
  section: "Ginnie Mae MBS Guide Ch. 4, Part 2, Section C — Nondelegable Responsibilities"
  description: '[ISSUER] may not delegate or transfer to others (through a power of

    attorney or otherwise) its obligation or authority to perform the

    Chapter 4 Part 2 Section C functions, including withdrawing funds

    from a P&I custodial account, signing certifications to Ginnie Mae

    required by the Guide or Guaranty Agreement (with the limited

    monthly-certification exception), withdrawing mortgage documents

    from the document custodian, and the Ginnie Mae I / Ginnie Mae II

    program-specific functions enumerated.

    '
  type: dont
  audit_question: Can [ISSUER] evidence that none of the Chapter 4 Part 2 Section C nondelegable functions (P&I custodial withdrawals, signing certifications to Ginnie Mae, withdrawing mortgage documents from the custodian, and the enumerated Ginnie Mae I / II program functions) were delegated to a subservicer or other party (subject to the monthly-certification exception)?
  workflow_phase: servicing
  owner_role: compliance_officer
  secondary_owner_role: default_servicing_analyst
  cadence: continuous
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - gnma
  - mbs-guide
  - ch04
  - nondelegable
  - subservicing
  - promoted
  primary_source:
    tier: 1
    authority: "Ginnie Mae MBS Guide Chapter 4, Part 2, Section C — Nondelegable Responsibilities"
    source_class: gnma-mbs-guide
    source_url: https://www.ginniemae.gov/issuers/program_guidelines/MBSGuideLib/Chapter_04.pdf
    snapshot_id: 997eb6a60a668b0b
    fetched_at: '2026-05-23T00:30:00Z'
    content_hash: sha256:ac32fb29be9891c64ad2e225aa3aba5a6267fead22a3324b32f9dd0ccda07f9b
    paragraph_quote: 'The Issuer may not delegate or transfer to others (through a power of attorney or otherwise) its '
    drafter_attestation: Copied verbatim from GNMA MBS Guide Chapter 4 snapshot 997eb6a60a668b0b at 2026-05-23.
  promoted_at: '2026-05-23T01:32:22+00:00'
  promoted_from: gnma-mbs-ch04-roundb-v1.yaml
  program_review: Does the program ensure the Section C nondelegable functions (P&I custodial withdrawals, signing Ginnie Mae certifications, withdrawing mortgage documents from the custodian, the enumerated GM I/II functions) are not delegated, subject to the monthly-certification exception?
  file_review: Confirm none of the nondelegable functions were delegated to a subservicer or other party (subject to the monthly-certification exception).
  judgment: false
- id: gnma-mbs-ch04-prior-approval-of-subservicing
  canonical_id: gnma-mbs-ch04-prior-approval-of-subservicing
  section: "Ginnie Mae MBS Guide Ch. 4, Part 3, Section A — Permitted Subservicing Functions"
  description: 'Where [ISSUER] uses a subservicer to perform servicing functions on

    its behalf, the subservicer must be a Ginnie Mae-approved Issuer and

    the subservicing arrangement must have Ginnie Mae''s prior written

    approval. There may be only one subservicer for each pool or loan

    package.

    '
  type: do
  audit_question: "For every subservicing arrangement [ISSUER] has in place, can [ISSUER] evidence (i) the subservicer is a Ginnie Mae-approved Issuer, (ii) Ginnie Mae’s prior written approval, and (iii) only one subservicer per pool or loan package?"
  workflow_phase: servicing
  owner_role: compliance_officer
  secondary_owner_role: default_servicing_analyst
  cadence: per-subservicing-arrangement
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - gnma
  - mbs-guide
  - ch04
  - subservicing-approval
  - one-per-pool
  - promoted
  primary_source:
    tier: 1
    authority: "Ginnie Mae MBS Guide Chapter 4, Part 3, Section A — Permitted Subservicing Functions"
    source_class: gnma-mbs-guide
    source_url: https://www.ginniemae.gov/issuers/program_guidelines/MBSGuideLib/Chapter_04.pdf
    snapshot_id: 997eb6a60a668b0b
    fetched_at: '2026-05-23T00:30:00Z'
    content_hash: sha256:ac32fb29be9891c64ad2e225aa3aba5a6267fead22a3324b32f9dd0ccda07f9b
    paragraph_quote: To perform servicing functions for another Issuer, a subservicer must be a Ginnie Mae-
    drafter_attestation: Copied verbatim from GNMA MBS Guide Chapter 4 snapshot 997eb6a60a668b0b at 2026-05-23.
  promoted_at: '2026-05-23T01:32:22+00:00'
  promoted_from: gnma-mbs-ch04-roundb-v1.yaml
  program_review: Does the program ensure each subservicing arrangement uses a Ginnie Mae-approved Issuer with Ginnie Mae's prior written approval, and only one subservicer per pool/loan package?
  file_review: For each subservicing arrangement, confirm the subservicer is a GM-approved Issuer, prior written approval exists, and only one subservicer per pool/loan package.
  judgment: false
_promotion_history:
- promoted_at: '2026-05-23T01:31:37+00:00'
  candidate_path: obligations\_remediation\_round_b_drafts\gnma-mbs-ch04-roundb-v1.yaml
  candidates_promoted: 0
  candidates_skipped_existing: 0
- promoted_at: '2026-05-23T01:32:22+00:00'
  candidate_path: obligations\_remediation\_round_b_drafts\gnma-mbs-ch04-roundb-v1.yaml
  candidates_promoted: 3
  candidates_skipped_existing: 0
