source:
  type: guide
  id: fnma-svc-a4-2.2-01
  authority: Fannie Mae Servicing Guide A4-2.2-01 — Selecting and Retaining Law Firms
  description: Fannie Mae Servicing Guide A4-2.2-01 — Selecting and Retaining Law
    Firms.
  coverage_tier: operative
obligations:
- id: fnma-svc-a4-2.2-01-full
  canonical_id: fnma-svc-a4-2.2-01-full
  section: Fannie Mae Servicing Guide A4-2.2-01 — Selecting and Retaining Law Firms
  type: do
  tags:
  - regulator-direct
  - fnma
  - servicing-guide
  - corpus-expansion
  - tier-operative
  primary_source:
    tier: 1
    authority: Fannie Mae Servicing Guide A4-2.2-01 — Selecting and Retaining Law
      Firms
    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: 'A4-2.2-01, Selecting and Retaining Law Firms (05/08/2024) Introduction
      This topic contains the following: Overview Performing Due Diligence When Selecting
      and Retaining Law Firms Submitting a Servicer Selection Form Law Firm Training
      and the Limited Retention Agreement The Use of Special Counsel Overview The
      servicer is responsible for selecting qualiﬁed, experienced law ﬁrms for all
      jurisdictions to handle default- related legal services relating to Fannie Mae
      mortgage loans. Default related legal services include foreclosure, workout
      options, bankruptcy and related litigation. Published May 13, 2026 150 See F-2-04,
      Firm Minimum Requirements and Compliance with the HERA in Selling Guide A3-2-01,
      Compliance with Laws for additional information regarding requirements for law
      ﬁrm selection. For a Mortgage Release, a servicer is authorized to select a
      third-party other than a law ﬁrm to prepare documentation; however, the servicer
      must select qualiﬁed and experienced vendors to complete the services related
      to this activity. In order to mitigate risk arising from the concentration of
      legal work relating to Fannie Mae mortgage loans, the servicer must select and
      retain an appropriate number of law ﬁrms for each jurisdiction. Fannie Mae does
      not allow for the direct referrals of Fannie Mae mortgage loans to trustees
      for foreclosure in any jurisdiction. Fannie Mae retains counsel directly for
      legal services relating to acquired properties. Performing Due Diligence When
      Selecting and Retaining Law Firms The following table lists the servicer''s
      duties related to law ﬁrm selection. ✓ The servicer must… Collect data from
      the law ﬁrm. Conduct appropriate due diligence to evaluate whether the law ﬁrm
      meets Fannie Mae''s minimum requirements as described in F-2-04, Firm Minimum
      Requirements. Maintain documentation evidencing its law ﬁrm selection process,
      including how law ﬁrms are • solicited, • evaluated, and • selected. If the
      servicer concludes that a law ﬁrm does not meet Fannie Mae’s minimum requirements,
      or as a result of the due diligence process decides not to retain the law ﬁrm,
      the servicer must inform the law ﬁrm that it has not been selected. Information
      relating to law ﬁrms that are not selected and retained by the servicer must
      be maintained for the longer of any retention period applicable to the servicer,
      or seven years. The servicer is not obligated to inform Fannie Mae if the servicer
      determines that a law ﬁrm does not meet the minimum requirements, or decides
      not to retain a law ﬁrm. Submitting a Servicer Selection Form The servicer must
      submit a Servicer Selection Form (Form 200) to Fannie Mae for each law ﬁrm it
      wishes to retain to provide default-related legal services for Fannie Mae mortgage
      loans. By submitting Form 200, the servicer certiﬁes the law ﬁrm’s satisfaction
      of Fannie Mae’s minimum requirements and other certain required disclosures.
      Published May 13, 2026 151 The following table provides Fannie Mae’s requirements
      related to the submission of Form 200. ✓ The servicer must… Submit a Form 200
      for each jurisdiction for which the servicer wishes to retain a law ﬁrm, if
      the law ﬁrm practices in multiple jurisdictions. Retain all information submitted
      by a law ﬁrm in support of the law ﬁrm’s application or otherwise gathered by
      the servicer regarding the law ﬁrm. Note: Information relating to law ﬁrms that
      are selected and retained by the servicer must be maintained as long as the
      law ﬁrm is providing legal services with respect to Fannie Mae mortgage loans
      and, thereafter, for the longer of any retention period applicable to the servicer,
      or seven years. Make all information available to Fannie Mae upon request. Within
      15 business days following the submission of Form 200, Fannie Mae expects that
      it will be in a position to issue a "No Objection" determination, an "Objection"
      determination, or request additional information for each Form 200 submitted.
      The following table provides the servicer with further instructions based on
      Fannie Mae''s response to Form 200. If Fannie Mae… Then the servicer must… issues
      an ”Objection” determination not retain the law ﬁrm to handle Fannie Mae matters
      and inform the law ﬁrm that it was not selected. issues a ”No Objection” determination
      inform the law ﬁrm that it must attend Fannie Mae new law ﬁrm training and sign
      a limited retention agreement with Fannie Mae in order to become eligible to
      receive referrals of Fannie Mae mortgage loans. requests additional information
      provide the requested information as quickly as possible. The servicer cannot
      rely upon the fact that another servicer previously submitted Form 200 with
      respect to a law ﬁrm and received a ”No Objection” determination. Law Firm Training
      and the Limited Retention Agreement All law ﬁrms that receive a "No Objection"
      determination from Fannie Mae must complete Fannie Mae new law ﬁrm training.
      Law ﬁrms only have to attend this training once, regardless of the number of
      servicers that select Published May 13, 2026 152 and retain the law ﬁrm. Law
      ﬁrms must also execute a limited retention agreement. The limited retention
      agreement will recognize and reﬂect a joint attorney-client relationship between
      the law ﬁrm, Fannie Mae and the servicer. It will also provide that it controls
      in the event that there are any inconsistent provisions in any agreement between
      the law ﬁrm and the servicer. The servicer may access the form of the limited
      retention agreement by logging in to the password-protected portion of Fannie
      Mae’s website. Fannie Mae considers the form of the limited retention agreements
      to be conﬁdential and proprietary information, and the servicer must treat the
      forms consistent with this classiﬁcation. The Use of Special Counsel From time
      to time, servicers retain counsel at their own expense to represent Fannie Mae
      and/or the servicer pursuant to their indemniﬁcation obligations to Fannie Mae
      (Special Counsel). Special Counsel retained and paid by servicers pursuant to
      their indemniﬁcation obligations to Fannie Mae do not have to be selected and
      retained pursuant to the guidelines described in A4-2.2-01, Selecting and Retaining
      Law Firms. The following table describes the requirements of the servicer if
      it retains Special Counsel. ✓ The servicer must… Notify Fannie Mae of the retention
      of Special Counsel. Ensure that its Special Counsel keeps Fannie Mae updated
      on the progress of the matters handled by the law ﬁrm. Ensure that it or the
      Special Counsel periodically updates the law ﬁrm to which the foreclosure, bankruptcy,
      or eviction matter was originally referred regarding the status of the matter
      for which the Special Counsel was retained. Once any issues for which Special
      Counsel was retained are resolved, the servicer must transition the foreclosure,
      bankruptcy, or eviction matter back to the law ﬁrm to which it was originally
      referred for any required further proceedings. See Selling Guide A2-1-03, Indemniﬁcation
      for Losses for additional information. Recent Related Announcements The table
      below provides references to recently issued Announcements that are related
      to this topic. Announcements Issue Date Announcement SVC-2024-03 May 8, 2024
      Published May 13, 2026 153 Announcements Issue Date Announcement SVC-2022-01
      February 9, 2022'
  judgment: false
