source:
  type: regulation
  id: fhlmc-9301.3
  authority: Freddie Mac Single-Family Seller/Servicer Guide §9301.3 — Foreclosure process and legal considerations
    (12/03/25)
  description: "Freddie Mac Guide §9301.3 (Foreclosure process and legal considerations). Gap-fill (verbatim, ID-diff).\
    \ \n"
obligations:
- id: fhlmc-9301.3-0
  canonical_id: fhlmc-9301.3-0
  section: Freddie Mac Guide 9301.3
  description: '9301.3 Foreclosure process and legal considerations: (12/03/25) This section contains requirements
    related to: ■ Choosing a judicial or nonjudicial foreclosure process ■ Obtaining the original Note ■ Foreclosing
    in the Servicer’s name ■ Solicitation during the foreclosure process ■ Servicer’s responsibility to work with
    foreclosure…'
  type: do
  tags:
  - regulator-direct
  - gap-fill
  - fhlmc-guide
  - section-complete
  primary_source:
    tier: 1
    authority: Freddie Mac Single-Family Seller/Servicer Guide §9301.3 — Foreclosure process and legal considerations
      (12/03/25)
    source_class: gse-guide
    source_url: https://guide.freddiemac.com/
    snapshot_id: 5869ee9e606cd4ae
    fetched_at: '2026-06-18T00:00:00+00:00'
    content_hash: sha256:9a1b23e5024bb369e7a59d36b3702383c11ace68b5d209fdef791bc8f955c637
    paragraph_quote: '(12/03/25) This section contains requirements related to: ■ Choosing a judicial or nonjudicial
      foreclosure process ■ Obtaining the original Note ■ Foreclosing in the Servicer’s name ■ Solicitation during
      the foreclosure process ■ Servicer’s responsibility to work with foreclosure counsel (a) Choosing a judicial
      or nonjudicial foreclosure process In States where the Servicer has the option of pursuing a judicial or nonjudicial
      foreclosure process, the Servicer must choose the nonjudicial process. However, if the Servicer determines
      its filing of a judicial foreclosure will preserve the right to pursue a deficiency judgment, and/or is in
      Freddie Mac’s best interests, the Servicer should refer to Exhibit 57A, Approved Attorney, Foreclosure, Mediation,
      Postponement Fees and Title Expenses, to determine if Freddie Mac has approved judicial foreclosure attorney
      fees in the State. If Freddie Mac has approved judicial foreclosure attorney fees in the State, the Servicer
      may pursue a judicial foreclosure process without Freddie Mac’s approval. If Freddie Mac does not have approved
      judicial foreclosure attorney fees in the State, or the filing of a judicial foreclosure will incur additional
      attorney fees exceeding the expense limits in Exhibit 57A, the Servicer must obtain Freddie Mac’s approval
      prior to referral to judicial foreclosure by submitting a request for pre-approval via PAID (Payments Automated
      Intelligent and Dynamic) (see Exhibit 88, Servicing Tools).'
    drafter_attestation: Verbatim from Freddie Guide §9301.3 body (max-gap occurrence), snapshot 5869ee9e606cd4ae;
      substring-verified.
  judgment: false
- id: fhlmc-9301.3-1
  canonical_id: fhlmc-9301.3-1
  section: Freddie Mac Guide 9301.3
  description: '9301.3 Foreclosure process and legal considerations: 301-21 Note: Refer to Section 9301.6(b) regarding
    when to request Freddie Mac’s approval to preserve deficiency rights. (b) Obtaining the original Note If physical
    or constructive possession of the original Note is needed to perform the foreclosure, the Servicer must request
    the …'
  type: do
  tags:
  - regulator-direct
  - gap-fill
  - fhlmc-guide
  - section-complete
  primary_source:
    tier: 1
    authority: Freddie Mac Single-Family Seller/Servicer Guide §9301.3 — Foreclosure process and legal considerations
      (12/03/25)
    source_class: gse-guide
    source_url: https://guide.freddiemac.com/
    snapshot_id: 5869ee9e606cd4ae
    fetched_at: '2026-06-18T00:00:00+00:00'
    content_hash: sha256:9a1b23e5024bb369e7a59d36b3702383c11ace68b5d209fdef791bc8f955c637
    paragraph_quote: '301-21 Note: Refer to Section 9301.6(b) regarding when to request Freddie Mac’s approval to
      preserve deficiency rights. (b) Obtaining the original Note If physical or constructive possession of the
      original Note is needed to perform the foreclosure, the Servicer must request the Note from the Document Custodian
      maintaining the Note by submitting to the Document Custodian a completed Form 1036, Request for Physical or
      Constructive Possession of Documents, or an electronic or system-generated version of the form (or, in the
      case of The Bank of New York Mellon Trust Company, N.A. as the Designated Custodian, a copy of the electronically
      generated 1036 Release Receipt Report) in accordance with the requirements of Section 8107.1(b). If there
      is a full or partial reinstatement of the Mortgage, the Servicer must return the Note to the Document Custodian
      with either the original Form 1036 or a copy. (c) Foreclosing in the Servicer’s name (i) Conducting the foreclosure
      The Servicer must instruct the foreclosure counsel to process the foreclosure in the Servicer’s name and in
      a manner that would avoid any obligation to pay a transfer tax. However, the Servicer may instruct foreclosure
      counsel to conduct the foreclosure in Freddie Mac’s name if applicable law: ■ Precludes the Servicer from
      conducting the foreclosure in its name because it owns or services a subordinate Mortgage on the Mortgaged
      Premises, or ■ Requires the foreclosure to be processed in Freddie Mac’s name to avoid any obligation to pay
      a transfer tax and foreclosure counsel could not otherwise process the foreclosure in a manner that would
      successfully avoid imposition of the transfer tax obligation For these special circumstances, the Servicer
      does not need to obtain written approval but must notify Freddie Mac within two Business Days of the Servicer’s
      determination to foreclose in Freddie Mac’s name and record the basis of the decision in the Mortgage file.
      All notifications must be sent via e-mail (see Directory 5). For all other circumstances in which the Servicer
      may need to instruct foreclosure counsel to conduct the foreclosure in Freddie Mac’s name, the Servicer must
      obtain written approval from Freddie Mac (refer to Section 9402.1(b) regarding initiating legal actions on
      Freddie Mac’s behalf). When processing the foreclosure in Freddie Mac’s name, all pleadings and related documents
      must comply with Section 9402.1(b)(iii). The Servicer remains obligated to notify Freddie Mac pursuant to
      Section 9501.5(d) in the event that any foreclosure conducted in Freddie Mac’s name evolves into a non-routine
      litigation matter (see Section 9402.1(b)).'
    drafter_attestation: Verbatim from Freddie Guide §9301.3 body (max-gap occurrence), snapshot 5869ee9e606cd4ae;
      substring-verified.
  judgment: false
- id: fhlmc-9301.3-2
  canonical_id: fhlmc-9301.3-2
  section: Freddie Mac Guide 9301.3
  description: '9301.3 Foreclosure process and legal considerations: 301-22 When a Servicer conducts the foreclosure
    in Freddie Mac’s name, the Servicer is not permitted to have the same foreclosure counsel represent the Servicer
    or another lienholder in the same proceeding. Freddie Mac does not consent to dual representation of Freddie
    Mac and an…'
  type: do
  tags:
  - regulator-direct
  - gap-fill
  - fhlmc-guide
  - section-complete
  primary_source:
    tier: 1
    authority: Freddie Mac Single-Family Seller/Servicer Guide §9301.3 — Foreclosure process and legal considerations
      (12/03/25)
    source_class: gse-guide
    source_url: https://guide.freddiemac.com/
    snapshot_id: 5869ee9e606cd4ae
    fetched_at: '2026-06-18T00:00:00+00:00'
    content_hash: sha256:9a1b23e5024bb369e7a59d36b3702383c11ace68b5d209fdef791bc8f955c637
    paragraph_quote: '301-22 When a Servicer conducts the foreclosure in Freddie Mac’s name, the Servicer is not
      permitted to have the same foreclosure counsel represent the Servicer or another lienholder in the same proceeding.
      Freddie Mac does not consent to dual representation of Freddie Mac and another lienholder on the same property.
      (ii) Executing documents If Freddie Mac needs to execute a document that is not authorized for the Servicer
      to execute under the Limited Power of Attorney (see Exhibit 53, Limited Power of Attorney) for the Servicer
      to: ■ Process the foreclosure, or ■ Execute a document related to a foreclosure sale The Servicer must submit
      Form 105, Multipurpose Loan Servicing Transmittal, to Freddie Mac (see Directory 5) with all supporting documentation,
      which may include, but is not limited to, the last recorded document in the chain of title, and include the
      document Freddie Mac needs to execute. Note: Refer to Sections 8101.2(b) and 8601.2(b) for requirements on
      obtaining a Limited Power of Attorney for Freddie Mac to sign documents on behalf of Freddie Mac. If an assignment
      of the Security Instrument to Freddie Mac has been recorded and the Servicer is conducting the foreclosure
      in its name, then the Security Instrument must be assigned back to the Servicer before the foreclosure counsel
      files the first legal action. Refer to Section 9301.5(a)(i) for an explanation of first legal action. To have
      the Security Instrument assigned back to the Servicer, the Servicer must submit a completed assignment with
      a Request for Assistance Form (available at: https://sf.freddiemac.com/docs/pdf/fact-sheet/sats699.pdf), to
      Freddie Mac (see Directory 9). Freddie Mac will endeavor to execute the assignment and return it to the Servicer
      within 10-12 Business Days of receiving the documents. If the Servicer is foreclosing on a Mortgage registered
      with MERS®, the Servicer must prepare and execute (using the Servicer’s employee who is a MERS authorized
      “signing officer”) an assignment of the Security Instrument from MERS to the Servicer. The Servicer must record
      the prepared assignment where required by State law. State mandated recordings are non-reimbursable by Freddie
      Mac, are not considered part of the Freddie Mac allowable foreclosure counsel fees and must not be billed
      to the Borrower. If the Mortgage is an FHA, Section 502 GRH or VA Mortgage, then the Servicer must follow
      FHA, RHS or VA guidelines to determine whose name the foreclosure action should be brought.'
    drafter_attestation: Verbatim from Freddie Guide §9301.3 body (max-gap occurrence), snapshot 5869ee9e606cd4ae;
      substring-verified.
  judgment: false
- id: fhlmc-9301.3-3
  canonical_id: fhlmc-9301.3-3
  section: Freddie Mac Guide 9301.3
  description: '9301.3 Foreclosure process and legal considerations: 301-23 Note: Refer to Section 6301.2(d) for
    additional information on Freddie Mac’s requirements for assignments of the Security Instrument. (d) Solicitation
    during the foreclosure process If a Servicer previously determined that a Borrower, who was less than 60 days
    delinquent a…'
  type: do
  tags:
  - regulator-direct
  - gap-fill
  - fhlmc-guide
  - section-complete
  primary_source:
    tier: 1
    authority: Freddie Mac Single-Family Seller/Servicer Guide §9301.3 — Foreclosure process and legal considerations
      (12/03/25)
    source_class: gse-guide
    source_url: https://guide.freddiemac.com/
    snapshot_id: 5869ee9e606cd4ae
    fetched_at: '2026-06-18T00:00:00+00:00'
    content_hash: sha256:9a1b23e5024bb369e7a59d36b3702383c11ace68b5d209fdef791bc8f955c637
    paragraph_quote: '301-23 Note: Refer to Section 6301.2(d) for additional information on Freddie Mac’s requirements
      for assignments of the Security Instrument. (d) Solicitation during the foreclosure process If a Servicer
      previously determined that a Borrower, who was less than 60 days delinquent at the time of evaluation, did
      not qualify for any alternative to foreclosure and the Borrower subsequently becomes 60 days delinquent, then
      the Servicer must continue its solicitation and collection efforts with the Borrower in accordance with the
      requirements of Chapter 9102. Continued solicitation includes sending another Borrower Solicitation Package,
      as applicable, if documentation needs to be refreshed in order to perform the subsequent evaluation of the
      Borrower for alternatives to foreclosure. Unless required to continue contact attempts by applicable law,
      attempts to contact any delinquent Borrower and related loss mitigation solicitations must discontinue 60
      days prior to a foreclosure sale date for judicial foreclosures or 30 days prior to a foreclosure sale date
      for non-judicial foreclosures. Loss mitigation solicitations while the Mortgage is in foreclosure must be
      communicated to and coordinated with the foreclosure counsel, as appropriate. A Servicer must keep the foreclosure
      counsel informed of the status of relevant alternative to foreclosure negotiations and must notify the foreclosure
      counsel within two Business Days after arrangements for an alternative to foreclosure have been agreed to
      or within two Business Days after the Mortgage is fully reinstated. (e) Servicer’s responsibility to work
      with foreclosure counsel (i) After Servicer referral Once the Servicer has referred a Mortgage to foreclosure,
      the Servicer must work with the foreclosure counsel to: 1. Identify any viable alternatives to foreclosure
      2. Monitor the progress of the foreclosure 3. Facilitate prompt and efficient completion of the foreclosure
      proceedings and acquisition of clear and marketable title, including conducting the foreclosure in a way that
      will expedite an eviction of the tenant or Borrower (ii) Communication Servicer must maintain communication
      with the foreclosure counsel so that the Servicer can manage the foreclosure effectively. No less than one
      time per month, the Servicer must require the foreclosure counsel to report the status of the foreclosure,
      request any documentation needed from Servicer and report any relevant information to the Servicer.'
    drafter_attestation: Verbatim from Freddie Guide §9301.3 body (max-gap occurrence), snapshot 5869ee9e606cd4ae;
      substring-verified.
  judgment: false
- id: fhlmc-9301.3-4
  canonical_id: fhlmc-9301.3-4
  section: Freddie Mac Guide 9301.3
  description: '9301.3 Foreclosure process and legal considerations: 301-24 The Servicer must maintain this information
    in the Mortgage file or on its Mortgage system. (iii)Compliance with the Servicemembers Civil Relief Act (SCRA)
    A Servicer must ensure foreclosure counsel complies with the SCRA and all State Military Relief Laws as they
    apply to…'
  type: do
  tags:
  - regulator-direct
  - gap-fill
  - fhlmc-guide
  - section-complete
  primary_source:
    tier: 1
    authority: Freddie Mac Single-Family Seller/Servicer Guide §9301.3 — Foreclosure process and legal considerations
      (12/03/25)
    source_class: gse-guide
    source_url: https://guide.freddiemac.com/
    snapshot_id: 5869ee9e606cd4ae
    fetched_at: '2026-06-18T00:00:00+00:00'
    content_hash: sha256:9a1b23e5024bb369e7a59d36b3702383c11ace68b5d209fdef791bc8f955c637
    paragraph_quote: 301-24 The Servicer must maintain this information in the Mortgage file or on its Mortgage
      system. (iii)Compliance with the Servicemembers Civil Relief Act (SCRA) A Servicer must ensure foreclosure
      counsel complies with the SCRA and all State Military Relief Laws as they apply to any Borrower or Mortgage
      including verification that the Borrower is not a Servicemember currently serving a Period of Military Service
      (as those terms are referenced in Section 8503.1(a)), or if the Borrower was a Servicemember, that more than
      one year has elapsed since their period of Military Service ended. (See Section 9701.3(a) regarding when verification
      should be completed by foreclosure counsel). (iv) Providing information to the foreclosure counsel For any
      Mortgage that the Servicer refers for foreclosure, the Servicer must provide complete written reinstatement
      or payoff figures to foreclosure counsel, workout specialist or outsourcing vendor requesting the information.
      This information must be provided within two Business Days of the date on which a written request is received.
      The Servicer may provide the written reinstatement or payoff figures via a paper document, facsimile or e-mail.
      If the foreclosure counsel requests additional information and/or documentation from the Servicer (such as
      certificates of judgment), at any time, the Servicer must provide such requested information and/or documents
      within three Business Days after receipt of the request, or within such earlier time frame if necessary to
      comply with timing requirements under applicable law or court orders and procedures. (v) Foreclosure counsel
      fees Foreclosure counsel fees and costs must be reasonable and comparable to those customarily charged in
      the area where the property is located. Exhibit 57A, Approved Attorney, Foreclosure, Mediation, Postponement
      Fees and Title Expenses, provides Freddie Mac’s expense limits for foreclosure counsel fees. The Servicer
      must obtain Freddie Mac’s written approval prior to incurring foreclosure counsel fees in excess of the expense
      limits. Refer to Section 9701.1(c) for details on obtaining Freddie Mac’s written pre-approval for exceeding
      the expense limits in Exhibit 57A. (vi) Fees and Borrower’s defenses Freddie Mac will reimburse the Servicer
      for Freddie Mac’s proportionate share of expenses for responding to Borrower defenses. Refer to Section 9402.1(b)
      and Chapter 9701 for details regarding expense reimbursements.
    drafter_attestation: Verbatim from Freddie Guide §9301.3 body (max-gap occurrence), snapshot 5869ee9e606cd4ae;
      substring-verified.
  judgment: false
- id: fhlmc-9301.3-5
  canonical_id: fhlmc-9301.3-5
  section: Freddie Mac Guide 9301.3
  description: '9301.3 Foreclosure process and legal considerations: Reporting requirements: referral and during
    the foreclosure proceeding (09/10/25) This section contains requirements related to: ■ Monthly foreclosure reporting
    ■ Responding to and reporting Borrower defenses ■ Reporting the scheduled foreclosure sale date The Servicer
    must notif…'
  type: do
  tags:
  - regulator-direct
  - gap-fill
  - fhlmc-guide
  - section-complete
  primary_source:
    tier: 1
    authority: Freddie Mac Single-Family Seller/Servicer Guide §9301.3 — Foreclosure process and legal considerations
      (12/03/25)
    source_class: gse-guide
    source_url: https://guide.freddiemac.com/
    snapshot_id: 5869ee9e606cd4ae
    fetched_at: '2026-06-18T00:00:00+00:00'
    content_hash: sha256:9a1b23e5024bb369e7a59d36b3702383c11ace68b5d209fdef791bc8f955c637
    paragraph_quote: 'Reporting requirements: referral and during the foreclosure proceeding (09/10/25) This section
      contains requirements related to: ■ Monthly foreclosure reporting ■ Responding to and reporting Borrower defenses
      ■ Reporting the scheduled foreclosure sale date The Servicer must notify Freddie Mac via an EDR transmission
      within the first three Business Days of the month following the month that the Servicer referred the Mortgage
      to foreclosure. Use a default action code of 43 and provide the date the Mortgage was referred to foreclosure.
      For additional information on EDR requirements, refer to Section 9102.6(c). (a) Monthly foreclosure reporting
      Once the Servicer has reported that a Mortgage has been referred to foreclosure the Servicer must report a
      default action code 68 (Date of first legal action) with the corresponding date of the first legal action
      (as defined in Section 9301.5(a)(i)). The Servicer must continue to report that the Mortgage is in foreclosure
      in its monthly EDR transmission using a default action code of 43 (Referred to foreclosure) until: ■ The Servicer
      reports the results of a foreclosure sale or the execution of a deed-in-lieu of foreclosure, or ■ The Servicer
      reports that the Mortgage is fully reinstated or paid off, or ■ A workout is completed For additional information
      on EDR requirements, refer to Section 9102.6. (b) Responding to and reporting Borrower defenses (i) Responding
      to Borrower defenses The Servicer must respond to legal actions brought by the Borrower during the foreclosure.
      Refer to Chapter 9401 for specific requirements for handling bankruptcy and routine litigation and Chapter
      9402 for non-routine litigation actions. (ii) Reporting a bankruptcy filing If the Borrower files bankruptcy
      during the foreclosure process, the Servicer must report the bankruptcy filing to Freddie Mac. The Servicer
      must submit this notification via an'
    drafter_attestation: Verbatim from Freddie Guide §9301.3 body (max-gap occurrence), snapshot 5869ee9e606cd4ae;
      substring-verified.
  judgment: false
- id: fhlmc-9301.3-6
  canonical_id: fhlmc-9301.3-6
  section: Freddie Mac Guide 9301.3
  description: '9301.3 Foreclosure process and legal considerations: 301-26 EDR transmission within the first three
    Business Days of the month following the month that the bankruptcy was filed. The Servicer must include the
    date of the filing and the applicable default action code to indicate the bankruptcy chapter number, as shown
    below. Bankrupt…'
  type: do
  tags:
  - regulator-direct
  - gap-fill
  - fhlmc-guide
  - section-complete
  primary_source:
    tier: 1
    authority: Freddie Mac Single-Family Seller/Servicer Guide §9301.3 — Foreclosure process and legal considerations
      (12/03/25)
    source_class: gse-guide
    source_url: https://guide.freddiemac.com/
    snapshot_id: 5869ee9e606cd4ae
    fetched_at: '2026-06-18T00:00:00+00:00'
    content_hash: sha256:9a1b23e5024bb369e7a59d36b3702383c11ace68b5d209fdef791bc8f955c637
    paragraph_quote: '301-26 EDR transmission within the first three Business Days of the month following the month
      that the bankruptcy was filed. The Servicer must include the date of the filing and the applicable default
      action code to indicate the bankruptcy chapter number, as shown below. Bankruptcy default action codes Bankruptcy
      Chapter Default Action Code Chapter 12 bankruptcy petition filed 59 Chapter 7 bankruptcy petition filed 65
      Chapter 11 bankruptcy petition filed 66 Chapter 13 bankruptcy petition filed 67 The Servicer must also notify
      Freddie Mac when the bankruptcy plan is confirmed by reporting a default action code of 69 (Bankruptcy plan
      confirmed), and providing the date the plan was confirmed, or in the event of a scheduled bankruptcy cramdown,
      by reporting a default action code of 35 (bankruptcy cramdown Scheduled). The Servicer must continue to report
      each month that the Borrower is in bankruptcy until the bankruptcy is cleared or the stay lifted, and the
      Servicer has reported the event to Freddie Mac. When the bankruptcy is cleared or the stay is lifted, the
      Servicer must notify Freddie Mac via an EDR transmission within the first three Business days of the month
      following the month that the action occurred. Use a default action code of 76 (Bankruptcy court clearance
      obtained/stay lifted) and provide the date that the action occurred. Note: For additional information on EDR
      requirements refer to Section 9102.6. (iii) Reporting a contested foreclosure and/or other litigation The
      Servicer must notify Freddie Mac of a contested foreclosure. The Servicer must also notify Freddie Mac of
      any pending litigation that affects the enforceability of the Mortgage or the marketability of the property
      securing the Mortgage. (Refer to Section 9402.1(b).) The Servicer must submit this notification via an EDR
      transmission within the first three Business Days of the month following the month in which the Servicer became
      aware of the contested foreclosure or other litigation. Use a default action code of 33 (Contested foreclosure
      and litigation) and provide the date that the action occurred.'
    drafter_attestation: Verbatim from Freddie Guide §9301.3 body (max-gap occurrence), snapshot 5869ee9e606cd4ae;
      substring-verified.
  judgment: false
- id: fhlmc-9301.3-7
  canonical_id: fhlmc-9301.3-7
  section: Freddie Mac Guide 9301.3
  description: '9301.3 Foreclosure process and legal considerations: 301-27 The Servicer must report each month
    that the foreclosure is being contested or about the other litigation as long as the case is pending. Note:
    For additional information on EDR requirements, refer to Section 9102.6. (c) Reporting the scheduled foreclosure
    sale date The Se…'
  type: do
  tags:
  - regulator-direct
  - gap-fill
  - fhlmc-guide
  - section-complete
  primary_source:
    tier: 1
    authority: Freddie Mac Single-Family Seller/Servicer Guide §9301.3 — Foreclosure process and legal considerations
      (12/03/25)
    source_class: gse-guide
    source_url: https://guide.freddiemac.com/
    snapshot_id: 5869ee9e606cd4ae
    fetched_at: '2026-06-18T00:00:00+00:00'
    content_hash: sha256:9a1b23e5024bb369e7a59d36b3702383c11ace68b5d209fdef791bc8f955c637
    paragraph_quote: '301-27 The Servicer must report each month that the foreclosure is being contested or about
      the other litigation as long as the case is pending. Note: For additional information on EDR requirements,
      refer to Section 9102.6. (c) Reporting the scheduled foreclosure sale date The Servicer must notify Freddie
      Mac via an EDR transmission within the first three Business Days of the month following the month that a foreclosure
      sale has been scheduled, by reporting a default action code of 71 (Foreclosure sale scheduled) along with
      the scheduled sale date. When the Servicer reports the scheduled foreclosure sale in its EDR transmission,
      the Servicer must also indicate that the Mortgage is in foreclosure using a default action code of 43 (Referred
      to foreclosure). Therefore, the Servicer will be reporting multiple default action codes in the same EDR transmission.
      For additional information on EDR requirements, refer to Section 9102.6.'
    drafter_attestation: Verbatim from Freddie Guide §9301.3 body (max-gap occurrence), snapshot 5869ee9e606cd4ae;
      substring-verified.
  judgment: false
