source:
  type: regulation
  id: fnma-svc-e-5
  authority: "FNMA Servicing Guide E-5 — Requesting Reimbursement for Expenses Associated with Default-Related Legal Matters"
  description: 'Servicing Guide Chapter E-5 governs servicer requests for default-legal expense reimbursement.

    '
obligations:
- id: fnma-svc-e-5-60-day-final-reimbursement-request
  canonical_id: fnma-svc-e-5-60-day-final-reimbursement-request
  section: "FNMA Servicing Guide E-5-01 — Requesting Reimbursement for Expenses"
  description: 'When multiple requests for reimbursement are submitted in connection

    with the same mortgage loan, [LENDER] must submit its final request

    for expense reimbursement for expenses incurred during the disposition

    process within 60 days of the applicable milestone. If [LENDER]

    submits a request for reimbursement of advances after the date Fannie

    Mae specifies for the submission of the final request for expense

    reimbursement, Fannie Mae will deny the request.

    '
  type: do
  audit_question: For every Fannie Mae mortgage loan with default-related expense reimbursement requests, can [LENDER] evidence the final reimbursement request submitted within 60 days of the applicable milestone (workout completion, third-party sale, reinstatement/payoff, REO disposition, or final FHA/VA/RD claim proceeds)?
  workflow_phase: servicing
  owner_role: bankruptcy_specialist
  secondary_owner_role: foreclosure_specialist
  cadence: per-event
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - fnma
  - servicing-guide
  - expense-reimbursement
  - 60-day
  - promoted
  primary_source:
    tier: 1
    authority: FNMA Servicing Guide E-5-01
    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: "the servicer must submit its ﬁnal request for expense reimbursement for expenses incurred during the"
    drafter_attestation: 'Copied verbatim from FNMA Servicing Guide snapshot cf63a82bbb4adfba (chapter E-5) at 2026-05-22.

      '
  promoted_at: '2026-05-23T00:25:13+00:00'
  promoted_from: fnma-svc-e-5-roundb-v1.yaml
  program_review: Does the program ensure the final expense-reimbursement request is submitted within 60 days of the applicable milestone (since post-deadline requests are denied)?
  file_review: For loans with reimbursement requests, confirm the final request was submitted within 60 days of the applicable milestone.
  judgment: false
- id: fnma-svc-e-5-attorney-fees-actual-reasonable-necessary
  canonical_id: fnma-svc-e-5-attorney-fees-actual-reasonable-necessary
  section: "FNMA Servicing Guide E-5-02 — Servicer Responsibilities Prior to Requesting Reimbursement of Attorney Fees and Costs"
  description: 'Before requesting reimbursement of attorney fees and costs on a Fannie

    Mae mortgage loan, [LENDER] must review and approve the attorney fees

    and costs to ensure they comply with Fannie Mae guidelines, including

    the requirement that all costs be actual, reasonable, and necessary.

    '
  type: do
  audit_question: For every reimbursement request for default-related attorney fees and costs on a Fannie Mae mortgage loan, can [LENDER] evidence a pre-submission review and approval confirming the fees and costs are actual, reasonable, and necessary in conformance with Fannie Mae guidelines?
  workflow_phase: servicing
  owner_role: bankruptcy_specialist
  secondary_owner_role: foreclosure_specialist
  cadence: per-event
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - fnma
  - servicing-guide
  - attorney-fees
  - actual-reasonable-necessary
  - promoted
  primary_source:
    tier: 1
    authority: FNMA Servicing Guide E-5-02
    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: Review and approve the attorney fees and costs to ensure they comply with Fannie Mae
    drafter_attestation: 'Copied verbatim from FNMA Servicing Guide snapshot cf63a82bbb4adfba (chapter E-5) at 2026-05-22.

      '
  promoted_at: '2026-05-23T00:25:13+00:00'
  promoted_from: fnma-svc-e-5-roundb-v1.yaml
  program_review: Does the program ensure attorney fees/costs are reviewed and approved before reimbursement requests to confirm they are actual, reasonable, and necessary per FNMA guidelines?
  file_review: For attorney-fee reimbursement requests, confirm a pre-submission review; the compliance person judges whether the fees/costs were actual, reasonable, and necessary.
  judgment: true
_promotion_history:
- promoted_at: '2026-05-23T00:25:13+00:00'
  candidate_path: C:\Users\earlc\broker-tools\obligations\_remediation\_round_b_drafts\fnma-svc-e-5-roundb-v1.yaml
  candidates_promoted: 2
  candidates_skipped_existing: 0
