source:
  type: regulation
  id: fnma-svc-a2-1-07
  authority: "FNMA Servicing Guide A2-1-07 — Subservicing (05/13/2026)"
  description: 'FNMA Servicing Guide A2-1-07 governs subservicing arrangements: when a

    Fannie Mae-approved master servicer uses another organization (the

    subservicer) to perform some or all of its servicing functions. Both

    master and subservicer must be Fannie Mae-approved servicers in good

    standing for new arrangements; written subservicing agreements must

    acknowledge Fannie Mae''s right to rescind recognition; custodial

    account forms (1013 / 1014) must be submitted; the master servicer

    remains fully liable to Fannie Mae regardless of subservicer

    performance; subservicing arrangements must be confirmed annually

    via Form 582 (Lender Record Information). Fills the A2/A3 subservicing

    gap previously identified in the CSH library coverage audit.

    '
obligations:
- id: fnma-svc-a2-1-07-both-parties-fnma-approved
  canonical_id: fnma-svc-a2-1-07-both-parties-fnma-approved
  section: "FNMA Servicing Guide A2-1-07 — Subservicing eligibility"
  description: '[LENDER], as master servicer, shall not enter into new subservicing

    arrangements or extend existing arrangements to cover newly originated

    mortgage loans unless BOTH [LENDER] and the subservicer are Fannie Mae-

    approved servicers in good standing AND both are able to perform the

    duties associated with the master servicer / subservicer arrangement.

    '
  type: refrain
  audit_question: For every new or extended subservicing arrangement covering newly originated FNMA-owned mortgage loans, can [LENDER] evidence that both the master servicer and the subservicer were Fannie Mae-approved servicers in good standing at the time the arrangement was entered or extended?
  workflow_phase: general_servicing_ops
  owner_role: vendor_management
  secondary_owner_role: compliance_officer
  cadence: per-subservicing-arrangement
  consequence: Fannie Mae may rescind subservicing-arrangement recognition; potential reps-and-warranties breach.
  tags:
  - round-d
  - regulator-direct
  - fnma
  - subservicing
  - vendor-management
  - promoted
  primary_source:
    tier: 1
    authority: "FNMA Servicing Guide A2-1-07 (05/13/2026) — Requirements for Subservicing Arrangements"
    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 master servicer may not enter into new subservicing arrangements or extend existing arrangements to include newly originated mortgage loans, unless both the master servicer and the subservicer are Fannie Mae- approved servicers in good standing who are able to perform the duties associated with the master servicer/subservicer arrangement.

      '
    drafter_attestation: 'Copied verbatim from snapshot f662f911b3ddaf1d (FNMA Servicing Guide

      May 13, 2026 edition) at 2026-05-25T14:15Z. A2-1-07 Requirements

      for Subservicing Arrangements paragraph.

      '
  promoted_at: '2026-05-25T14:27:10+00:00'
  promoted_from: fnma-svc-a2-1-07-roundd-v1.yaml
  program_review: Does the program ensure no new/extended subservicing arrangement covering newly originated loans is entered unless BOTH master servicer and subservicer are FNMA-approved servicers in good standing able to perform?
  file_review: For each subservicing arrangement, confirm both parties were FNMA-approved in good standing at entry/extension.
  judgment: false
- id: fnma-svc-a2-1-07-written-rescission-acknowledgment
  canonical_id: fnma-svc-a2-1-07-written-rescission-acknowledgment
  section: "FNMA Servicing Guide A2-1-07 — Written subservicing agreement rescission clause"
  description: '[LENDER], as master servicer, shall ensure that its written agreement

    with each subservicer acknowledges Fannie Mae''s right to rescind its

    recognition of the subservicing arrangement if Fannie Mae decides to

    transfer the master servicer''s portfolio for any reason.

    '
  type: do
  audit_question: For every active subservicing arrangement, can [LENDER] produce a written agreement with the subservicer that contains the Fannie Mae rescission-rights acknowledgment language required by A2-1-07?
  workflow_phase: general_servicing_ops
  owner_role: vendor_management
  secondary_owner_role: legal_counsel
  cadence: per-subservicing-arrangement
  consequence: Failure to include the rescission acknowledgment may invalidate FNMA recognition of the arrangement.
  tags:
  - round-d
  - regulator-direct
  - fnma
  - subservicing
  - written-agreement
  - promoted
  primary_source:
    tier: 1
    authority: "FNMA Servicing Guide A2-1-07 (05/13/2026) — Requirements for Subservicing Arrangements"
    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 ensure that its written agreement with the subservicer acknowledges Fannie Mae’s\n"
    drafter_attestation: "Copied verbatim from snapshot f662f911b3ddaf1d. A2-1-07 written-\nrescission-acknowledgment headline. Quote uses U+2019 curly\napostrophe matching the source PDF (extracted text preserves the\nligature/curly characters). Full rescission-rights clause continues\nthrough \"if Fannie Mae decides to transfer...\" — paraphrased in\ndescription to avoid additional curly-character matches.\n"
  promoted_at: '2026-05-25T14:27:10+00:00'
  promoted_from: fnma-svc-a2-1-07-roundd-v1.yaml
  program_review: Does the program ensure each written subservicing agreement acknowledges Fannie Mae's right to rescind recognition if FNMA transfers the master servicer's portfolio?
  file_review: For active subservicing arrangements, confirm the written agreement contains the FNMA rescission-rights acknowledgment language.
  judgment: false
- id: fnma-svc-a2-1-07-custodial-account-forms-1013-1014
  canonical_id: fnma-svc-a2-1-07-custodial-account-forms-1013-1014
  section: "FNMA Servicing Guide A2-1-07 — Custodial account Letter of Authorization forms"
  description: 'For a new subservicing arrangement, [LENDER] (as subservicer or master

    servicer arranging for the subservicer) shall submit electronically

    the applicable custodial account Letter of Authorization forms:

    Form 1013 for a P&I custodial account, and Form 1014 for a T&I

    custodial account. The completed forms must indicate the required

    custodial accounts have been established. Submission instructions

    are at Fannie Mae''s Custodial Bank Account Management webpage.

    '
  type: do
  audit_question: For every new subservicing arrangement, can [LENDER] evidence electronic submission of Form 1013 (P&I custodial account) and Form 1014 (T&I custodial account) Letters of Authorization confirming the required custodial accounts were established?
  workflow_phase: general_servicing_ops
  owner_role: vendor_management
  secondary_owner_role: compliance_officer
  cadence: per-new-subservicing-arrangement
  consequence: Arrangement may not be recognized by Fannie Mae until forms are received and processed.
  tags:
  - round-d
  - regulator-direct
  - fnma
  - subservicing
  - custodial-accounts
  - forms-submission
  - promoted
  primary_source:
    tier: 1
    authority: "FNMA Servicing Guide A2-1-07 (05/13/2026) — Requirements for Subservicing Arrangements"
    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 subservicer must submit the applicable custodial account form

      '
    drafter_attestation: 'Copied verbatim from snapshot f662f911b3ddaf1d. A2-1-07 custodial-

      account-forms submission chapeau; the specific forms (1013 / 1014)

      and electronic-submission requirement are paraphrased in description.

      '
  promoted_at: '2026-05-25T14:27:10+00:00'
  promoted_from: fnma-svc-a2-1-07-roundd-v1.yaml
  program_review: Does the program ensure new subservicing arrangements submit Form 1013 (P&I) and Form 1014 (T&I) custodial-account Letters of Authorization confirming the required accounts were established?
  file_review: For new subservicing arrangements, confirm electronic submission of Forms 1013 and 1014 indicating the custodial accounts were established.
  judgment: false
- id: fnma-svc-a2-1-07-master-servicer-remains-liable
  canonical_id: fnma-svc-a2-1-07-master-servicer-remains-liable
  section: "FNMA Servicing Guide A2-1-07 — Master servicer remains liable for subservicer breach"
  description: '[LENDER], as master servicer, remains FULLY LIABLE to Fannie Mae for

    the performance of all servicing obligations, regardless of whether a

    breach of those obligations was caused by [LENDER] or by the

    subservicer. Fannie Mae''s right to enforce remedies against the

    master servicer is not limited by Fannie Mae''s knowledge of, approval

    of, or consent to the subservicing arrangement, and Fannie Mae may

    ALSO enforce rights and remedies against the subservicer directly.

    '
  type: do
  audit_question: Does [LENDER]'s subservicing oversight program (including QC sampling, exception reporting, and contractual indemnification) reflect that [LENDER] remains fully liable to Fannie Mae for the subservicer's performance of all servicing obligations?
  workflow_phase: general_servicing_ops
  owner_role: vendor_management
  secondary_owner_role: compliance_officer
  cadence: continuous
  consequence: FNMA enforcement against the master servicer for ANY subservicer breach; reps-and-warranties exposure.
  tags:
  - round-d
  - regulator-direct
  - fnma
  - subservicing
  - liability
  - oversight
  - promoted
  primary_source:
    tier: 1
    authority: "FNMA Servicing Guide A2-1-07 (05/13/2026) — Requirements for Subservicing Arrangements"
    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 master servicer remains fully liable to Fannie Mae for the performance of all servicing obligations.

      '
    drafter_attestation: 'Copied verbatim from snapshot f662f911b3ddaf1d. A2-1-07 master-

      servicer-fully-liable clause.

      '
  promoted_at: '2026-05-25T14:27:10+00:00'
  promoted_from: fnma-svc-a2-1-07-roundd-v1.yaml
  program_review: Does the program's subservicing oversight (QC sampling, exception reporting, indemnification) reflect that the master servicer remains fully liable to Fannie Mae for the subservicer's performance regardless of cause, and that FNMA may also enforce against the subservicer directly?
  file_review: Review the subservicing oversight program; the compliance person judges whether it is calibrated to full master-servicer liability for the subservicer's performance.
  judgment: true
- id: fnma-svc-a2-1-07-annual-confirmation-form-582
  canonical_id: fnma-svc-a2-1-07-annual-confirmation-form-582
  section: "FNMA Servicing Guide A2-1-07 — Annual subservicing-arrangement confirmation via Form 582"
  description: '[LENDER], as master servicer, shall confirm its existing subservicing

    arrangements annually when submitting the Lender Record Information

    (Form 582) to Fannie Mae.

    '
  type: do
  audit_question: For each calendar year, can [LENDER] produce the completed Form 582 (Lender Record Information) confirming the then-current subservicing arrangements?
  workflow_phase: general_servicing_ops
  owner_role: vendor_management
  secondary_owner_role: compliance_officer
  cadence: annual
  consequence: Lapsed or omitted Form 582 confirmation puts subservicing-arrangement recognition at risk.
  tags:
  - round-d
  - regulator-direct
  - fnma
  - subservicing
  - annual-confirmation
  - form-582
  - promoted
  primary_source:
    tier: 1
    authority: "FNMA Servicing Guide A2-1-07 (05/13/2026) — Requirements for Subservicing Arrangements"
    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 master servicer must con

      '
    drafter_attestation: "Copied verbatim from snapshot f662f911b3ddaf1d. A2-1-07 Form 582\nannual-confirmation requirement headline; full sentence about\nLender Record Information completes in the source. Quote truncated\nbefore the \"ﬁrm\" ligature in \"conﬁrm\" to maintain substring-match\npurity against the PDF extraction (which preserves the ligature).\n"
  promoted_at: '2026-05-25T14:27:10+00:00'
  promoted_from: fnma-svc-a2-1-07-roundd-v1.yaml
  program_review: Does the program ensure existing subservicing arrangements are confirmed annually via the Lender Record Information (Form 582) submission to Fannie Mae?
  file_review: For each year, confirm the completed Form 582 reflecting the then-current subservicing arrangements.
  judgment: false
- id: fnma-svc-a2-1-07-no-interference-with-remitting-reporting
  canonical_id: fnma-svc-a2-1-07-no-interference-with-remitting-reporting
  section: "FNMA Servicing Guide A2-1-07 — Subservicing must not interfere with remitting / reporting"
  description: '[LENDER], as master servicer, may use a subservicer only if doing so

    will NOT interfere with [LENDER]''s ability to meet Fannie Mae''s

    remitting and reporting requirements.

    '
  type: refrain
  audit_question: For every active subservicing arrangement, can [LENDER] evidence that the arrangement has not impaired [LENDER]'s ability to meet FNMA remitting and reporting requirements (i.e., monthly cash remittance, MBS pool reporting, P&I and T&I pass-through accuracy)?
  workflow_phase: general_servicing_ops
  owner_role: vendor_management
  secondary_owner_role: compliance_officer
  cadence: continuous
  consequence: Persistent remitting / reporting failures may force termination of subservicing arrangement and master-servicer enforcement.
  tags:
  - round-d
  - regulator-direct
  - fnma
  - subservicing
  - remitting
  - reporting
  - promoted
  primary_source:
    tier: 1
    authority: "FNMA Servicing Guide A2-1-07 (05/13/2026) — Requirements for Subservicing Arrangements"
    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 use a subservicer only if it will not interfere with the servicer’s ability to meet Fannie Mae’s\n"
    drafter_attestation: 'Copied verbatim from snapshot f662f911b3ddaf1d. A2-1-07 no-interference

      operative clause. Quote uses U+2019 curly apostrophes matching the

      source PDF; "remitting and reporting requirements" tail paraphrased

      in description.

      '
  promoted_at: '2026-05-25T14:27:10+00:00'
  promoted_from: fnma-svc-a2-1-07-roundd-v1.yaml
  program_review: Does the program ensure a subservicing arrangement is used only where it will not interfere with meeting FNMA remitting and reporting requirements (monthly cash remittance, MBS pool reporting, P&I/T&I pass-through accuracy)?
  file_review: Review remitting/reporting performance for subserviced loans; the compliance person judges whether the arrangement impaired remitting/reporting.
  judgment: true
_promotion_history:
- promoted_at: '2026-05-25T14:27:10+00:00'
  candidate_path: obligations\_remediation\round-d-investor-guides\fnma-svc-a2-1-07-roundd-v1.yaml
  candidates_promoted: 6
  candidates_skipped_existing: 0
