source:
  type: regulation
  id: fnma-svc-a4-1-01
  authority: "FNMA Servicing Guide A4-1-01 — Staffing, Training, Procedures, and Quality Control Requirements"
  description: 'FNMA Servicing Guide A4-1-01 governs servicer operational

    foundations: staffing levels and training adequacy, HR-security

    background verifications and InfoSec awareness training, continuity-

    of-contact teams for delinquent borrowers, written policies covering

    all servicing aspects + outsourcing/third-party-vendor oversight,

    FHFA Suspended Counterparty Program screening, and quality-control

    procedures. Fills core FNMA Servicing A4 setup gap.

    '
obligations:
- id: fnma-svc-a4-1-01-sufficient-staffing-and-training
  canonical_id: fnma-svc-a4-1-01-sufficient-staffing-and-training
  section: "FNMA Servicing Guide A4-1-01 — Staffing Requirements: sufficient levels + trained staff"
  description: '[LENDER] (servicer) shall have sufficient staffing levels and

    properly trained staff (INCLUDING third-party providers of its

    outsourced servicing activities) to: (1) carry out all aspects of

    its servicing duties in accordance with the timing requirements of

    the Servicing Guide; (2) maintain acceptable performance standards;

    and (3) provide borrowers with assistance when it is requested.

    '
  type: do
  audit_question: "Can [LENDER] evidence (via FTE counts, training records, and timing-compliance metrics) that staffing levels and training adequacy meet FNMA A4-1-01 — including coverage of outsourced/third-party providers performing servicing activities on FNMA-owned loans?"
  workflow_phase: general_servicing_ops
  owner_role: chief_servicing_officer
  secondary_owner_role: vendor_management
  cadence: continuous
  consequence: Servicing-performance failures expose [LENDER] to FNMA enforcement and reps-and-warranties claims.
  tags:
  - round-d
  - regulator-direct
  - fnma
  - servicer-operations
  - staffing
  - training
  - promoted
  primary_source:
    tier: 1
    authority: "FNMA Servicing Guide A4-1-01 — Staffing Requirements"
    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: "levels and properly trained staﬀ (including third-party providers of its outsourced servicing activities) to\n"
    drafter_attestation: "Copied verbatim from snapshot f662f911b3ddaf1d. A4-1-01 staffing-\nrequirements operative phrase. Quote starts mid-sentence to avoid\nthe U+FB01 fi-ligature in \"suﬃcient/sufﬁcient\" and the U+FB04\nffi-ligature in \"staﬃng\" at the sentence start. Uses U+FB00 ff-\nligature in \"staﬀ\" matching the PDF extraction.\n"
  promoted_at: '2026-05-25T18:11:39+00:00'
  promoted_from: fnma-svc-a4-1-01-roundd-v1.yaml
  program_review: Do the P&Ps facilitate sufficient staffing and properly trained staff (including outsourced/third-party providers) to meet Servicing Guide timing requirements, performance standards, and borrower-assistance-on-request?
  file_review: Review FTE counts, training records, and timing-compliance metrics including third-party coverage; the compliance person judges whether staffing/training is sufficient.
  judgment: true
- id: fnma-svc-a4-1-01-continuity-of-contact-delinquent-borrowers
  canonical_id: fnma-svc-a4-1-01-continuity-of-contact-delinquent-borrowers
  section: "FNMA Servicing Guide A4-1-01 — Continuity of contact for delinquent borrowers"
  description: '[LENDER] (servicer) shall ensure its staff dedicated to delinquent

    borrowers provides continuity of contact with the borrower AND

    allows the borrower to contact one individual or a dedicated team

    of individuals in [LENDER]''s organization to obtain accurate

    information on the various workout options available. When using a

    team approach, [LENDER] shall provide the borrower with the ability

    to request and speak to, or leave a message for, a specific person

    from the assigned team.

    '
  type: do
  audit_question: For every delinquent FNMA-owned loan, can [LENDER] evidence the borrower's ability to reach one individual or a dedicated team (with the specific-person request/message option for team models), and that workout-option information provided was accurate?
  workflow_phase: default_collections
  owner_role: loss_mitigation_specialist
  secondary_owner_role: compliance_officer
  cadence: per-delinquent-loan
  consequence: "Continuity-of-contact gaps duplicate Reg X §1024.40 exposure plus FNMA reps-and-warranties claims."
  tags:
  - round-d
  - regulator-direct
  - fnma
  - servicer-operations
  - continuity-of-contact
  - loss-mitigation
  - promoted
  primary_source:
    tier: 1
    authority: "FNMA Servicing Guide A4-1-01 — Staffing Requirements (Delinquent Borrowers)"
    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: 'provides continuity of contact with the borrower, and

      '
    drafter_attestation: 'Copied verbatim from snapshot f662f911b3ddaf1d. A4-1-01 continuity-

      of-contact operative clause. The "one individual or dedicated team"

      + "specific person from assigned team" elaborations paraphrased in

      description.

      '
  promoted_at: '2026-05-25T18:11:39+00:00'
  promoted_from: fnma-svc-a4-1-01-roundd-v1.yaml
  program_review: Do the P&Ps facilitate continuity of contact — a delinquent borrower can reach one individual or a dedicated team (with the specific-person request/message option for team models) for accurate workout-option information?
  file_review: For delinquent loans, review for reachability and accuracy of workout-option information given; the compliance person judges whether continuity-of-contact and information accuracy were adequate.
  judgment: true
- id: fnma-svc-a4-1-01-training-program-design
  canonical_id: fnma-svc-a4-1-01-training-program-design
  section: "FNMA Servicing Guide A4-1-01 — Training program design requirements"
  description: '[LENDER] (servicer) shall design and implement a training program

    that includes: (1) the fundamentals of all Fannie Mae workout

    options programs; (2) familiarity with F-2-10 (Fannie Mae''s Workout

    Hierarchy); (3) annual training and as-training-needs-are-identified

    through quality assurance reviews; (4) continual training on policy

    changes communicated through Announcements, Lender Letters, and

    other Fannie Mae correspondence; and (5) training on compliance

    with applicable laws and regulations. Foreclosure and bankruptcy

    staff must additionally be knowledgeable about Fannie Mae''s workout

    options.

    '
  type: do
  audit_question: Can [LENDER] produce its training program documentation showing coverage of all 5 mandatory elements (workout options fundamentals, F-2-10 hierarchy familiarity, annual + QA-triggered cadence, Announcement/Lender Letter updates, applicable-laws compliance) and per-employee completion records?
  workflow_phase: general_servicing_ops
  owner_role: training_manager
  secondary_owner_role: compliance_officer
  cadence: annual-plus-continuous
  consequence: Untrained staff committing servicing errors expose [LENDER] to FNMA enforcement and reps-and-warranties claims.
  tags:
  - round-d
  - regulator-direct
  - fnma
  - servicer-operations
  - training-program
  - promoted
  primary_source:
    tier: 1
    authority: "FNMA Servicing Guide A4-1-01 — Training Requirements"
    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 design and implement a training program that includes:

      '
    drafter_attestation: 'Copied verbatim from snapshot f662f911b3ddaf1d. A4-1-01 training-

      program-design operative chapeau. The 5 enumerated training

      elements + foreclosure/bankruptcy-staff additional requirement

      paraphrased in description.

      '
  promoted_at: '2026-05-25T18:11:39+00:00'
  promoted_from: fnma-svc-a4-1-01-roundd-v1.yaml
  program_review: Does the program design/implement a training program covering all five mandatory elements (workout-option fundamentals, F-2-10 hierarchy familiarity, annual + QA-triggered cadence, Announcement/Lender Letter updates, applicable-laws compliance), with foreclosure/bankruptcy staff knowledgeable on workout options?
  file_review: Review the training program documentation and per-employee completion records against the five mandatory elements.
  judgment: false
- id: fnma-svc-a4-1-01-written-policies-procedures
  canonical_id: fnma-svc-a4-1-01-written-policies-procedures
  section: "FNMA Servicing Guide A4-1-01 — Written policies and procedures"
  description: '[LENDER] (servicer) shall have fully documented written policies

    and/or procedures that address all aspects of mortgage servicing

    to ensure its staff, and any outsourcing firms and third-party

    vendors used by [LENDER], consistently comply with Fannie Mae''s

    requirements. Required topics include (but are not limited to):

    oversight of outsourcing/third-party vendors, FHFA Suspended

    Counterparty Program list screening, controls for automated

    payment direct-debits, and other servicing-operations controls

    listed in the A4-1-01 written-policies table.

    '
  type: do
  audit_question: Can [LENDER] produce its written servicing policies-and-procedures library covering all aspects of mortgage servicing, including specific policies on (a) outsourcing/third-party vendor oversight, (b) FHFA Suspended Counterparty Program screening of every vendor, and (c) controls for automated payment processing?
  workflow_phase: general_servicing_ops
  owner_role: compliance_officer
  secondary_owner_role: vendor_management
  cadence: continuous
  consequence: Lack of written policies is a standalone FNMA Servicing Guide breach; surfaces in QC reviews and audits.
  tags:
  - round-d
  - regulator-direct
  - fnma
  - servicer-operations
  - written-policies
  - vendor-oversight
  - fhfa-suspended-counterparty
  - promoted
  primary_source:
    tier: 1
    authority: "FNMA Servicing Guide A4-1-01 — Establishing Written Policies or Procedures"
    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 have fully documented written policies and/or procedures that address all aspects of

      '
    drafter_attestation: 'Copied verbatim from snapshot f662f911b3ddaf1d. A4-1-01 written-

      policies operative chapeau. Quote truncated before "mortgage

      servicing" line break; the topics table (outsourcing, FHFA SCP,

      direct debit, etc.) paraphrased in description.

      '
  promoted_at: '2026-05-25T18:11:39+00:00'
  promoted_from: fnma-svc-a4-1-01-roundd-v1.yaml
  program_review: Does the program maintain fully documented written servicing P&Ps covering all aspects of servicing, including outsourcing/third-party vendor oversight, FHFA Suspended Counterparty Program screening, and automated payment direct-debit controls?
  file_review: Review the written P&P library for coverage of all servicing aspects, including the enumerated vendor-oversight, SCP-screening, and automated-payment-control topics.
  judgment: false
_promotion_history:
- promoted_at: '2026-05-25T18:11:39+00:00'
  candidate_path: obligations\_remediation\round-d-investor-guides\fnma-svc-a4-1-01-roundd-v1.yaml
  candidates_promoted: 4
  candidates_skipped_existing: 0
