source:
  type: regulation
  id: fhlmc-3201.1
  authority: Freddie Mac Single-Family Seller/Servicer Guide §3201.1 — Fraud prevention and detection measures (05/06/26)
  description: "Freddie Mac Guide §3201.1 (Fraud prevention and detection measures). Gap-fill (verbatim, ID-diff).\
    \ \n"
obligations:
- id: fhlmc-3201.1-0
  canonical_id: fhlmc-3201.1-0
  section: Freddie Mac Guide 3201.1
  description: '3201.1 Fraud prevention and detection measures: (05/06/26) The Seller/Servicer must have in place
    comprehensive practices and procedures to prevent and detect fraud throughout each stage of the origination
    and Servicing of a Mortgage and in related real estate transactions. This section identifies fraud prevention
    and detectio…'
  type: do
  tags:
  - regulator-direct
  - gap-fill
  - fhlmc-guide
  - section-complete
  primary_source:
    tier: 1
    authority: Freddie Mac Single-Family Seller/Servicer Guide §3201.1 — Fraud prevention and detection measures
      (05/06/26)
    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: '(05/06/26) The Seller/Servicer must have in place comprehensive practices and procedures to
      prevent and detect fraud throughout each stage of the origination and Servicing of a Mortgage and in related
      real estate transactions. This section identifies fraud prevention and detection requirements related to:
      ■ Employee hiring and training ■ Origination and Servicing ■ Seller/Servicer’s in-house quality control program
      ■ Additional fraud mitigation resources Seller/Servicers must implement additional practices and procedures,
      as deemed necessary, to ensure that an effective fraud prevention and detection plan is in place. (a) Employee
      hiring and training The Seller/Servicer must have screening and hiring practices in place to ensure the integrity
      of its employees. Employees and any entity or individual engaged to handle or perform functions typically
      handled by employees, and in a position to notice or report fraud and suspected fraud, must receive training
      in each applicable area of the Seller/Servicer’s mortgage business about: ■ Common and emerging fraud schemes
      ■ Red flags that may signal fraud and the need for more review The Seller/Servicer must communicate its procedures
      (including requirements of this chapter) for prevention, detection and reporting of fraud and suspected fraud
      to its employees and the entities and individuals referenced above. Parties engaged to handle or perform functions
      typically performed by employees and in a position to notice or report fraud or suspected fraud may include:
      ■ Contract underwriters'
    drafter_attestation: Verbatim from Freddie Guide §3201.1 body (max-gap occurrence), snapshot 5869ee9e606cd4ae;
      substring-verified.
  judgment: false
- id: fhlmc-3201.1-1
  canonical_id: fhlmc-3201.1-1
  section: Freddie Mac Guide 3201.1
  description: '3201.1 Fraud prevention and detection measures: 201-2 ■ Contract processing services (including
    loan processors) ■ Contract quality control firms ■ Borrower outreach companies ■ Loss mitigation services ■
    Collection companies The training must include periodic updates at least annually to ensure employees and parties
    reference…'
  type: do
  tags:
  - regulator-direct
  - gap-fill
  - fhlmc-guide
  - section-complete
  primary_source:
    tier: 1
    authority: Freddie Mac Single-Family Seller/Servicer Guide §3201.1 — Fraud prevention and detection measures
      (05/06/26)
    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: '201-2 ■ Contract processing services (including loan processors) ■ Contract quality control
      firms ■ Borrower outreach companies ■ Loss mitigation services ■ Collection companies The training must include
      periodic updates at least annually to ensure employees and parties referenced above are aware of emerging
      fraud scenarios. The Seller/Servicer must either provide the training directly, hire a third party to provide
      the training, or obtain an annual written verification from the engaged entity or individual confirming that
      training has already been received from another party in accordance with the requirements of this section.
      (b) Origination and Servicing The Seller/Servicer must take the following minimum steps to prevent and detect
      fraud in the areas of origination and Servicing: ■ Escalate internally and properly investigate information
      received from any source that indicates suspected fraud. Sources can include: • Borrowers • Participants in
      the Mortgage transaction • Participants in the related real estate transactions • Servicing functions relating
      to a Mortgage or REO property • Loss mitigation activities or transactions, such as: ■ Forbearance plans ■
      Loan modifications ■ Foreclosures ■ Deeds-in-lieu of foreclosure'
    drafter_attestation: Verbatim from Freddie Guide §3201.1 body (max-gap occurrence), snapshot 5869ee9e606cd4ae;
      substring-verified.
  judgment: false
- id: fhlmc-3201.1-2
  canonical_id: fhlmc-3201.1-2
  section: Freddie Mac Guide 3201.1
  description: '3201.1 Fraud prevention and detection measures: 201-3 ■ Short sales of the underlying property ■
    Investigate unusual patterns or discrepancies or other red flags, such as first and early- payment defaults
    ■ Comply with Section 3101.1 regarding screening through the Freddie Mac Exclusionary List ■ Comply with all
    other Guide pr…'
  type: do
  tags:
  - regulator-direct
  - gap-fill
  - fhlmc-guide
  - section-complete
  primary_source:
    tier: 1
    authority: Freddie Mac Single-Family Seller/Servicer Guide §3201.1 — Fraud prevention and detection measures
      (05/06/26)
    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: '201-3 ■ Short sales of the underlying property ■ Investigate unusual patterns or discrepancies
      or other red flags, such as first and early- payment defaults ■ Comply with Section 3101.1 regarding screening
      through the Freddie Mac Exclusionary List ■ Comply with all other Guide provisions relating to fraud prevention
      and detection Red flags identified in origination and/or Servicing may include, but are not limited to: ■
      Origination: ❑ Collateral, appraisal and property fraud (e.g., flipping, flopping, over or under valuation,
      property condition) ❑ Misrepresentations (e.g., assets, liabilities/debt, occupancy, strawbuyer, employment,
      income) ❑ Identity theft ❑ Irregularities in the loan application or Mortgage documentation (e.g., false documents,
      forgeries, excessive gift funds) ■ Servicing: ❑ Potentially suspicious payment activity (e.g., structured
      cash payments, payments returned due to fraud, curtailments or large payments with unknown source of funds,
      payment kiting) ❑ Loan modification and foreclosure fraud (e.g., loan modification rescue schemes, misrepresentation
      of eligibility requirements) ❑ Debt elimination schemes (e.g., false identity theft claims, sovereign citizen
      fraud) ❑ Potentially suspicious or fraudulent payoffs (e.g., early payoffs, potentially suspicious or fraudulent
      wires, diversion of funds) Seller/Servicers must know the parties with whom they do business. ■ Sellers must
      approve, evaluate and monitor Mortgage Brokers, Correspondents, Mortgage Service Providers, appraisers, and
      property data collectors ■ Servicers must approve, evaluate and monitor appraisers and any third party to
      whom Servicing functions relating to a Mortgage or REO property are outsourced or assigned,'
    drafter_attestation: Verbatim from Freddie Guide §3201.1 body (max-gap occurrence), snapshot 5869ee9e606cd4ae;
      substring-verified.
  judgment: false
- id: fhlmc-3201.1-3
  canonical_id: fhlmc-3201.1-3
  section: Freddie Mac Guide 3201.1
  description: '3201.1 Fraud prevention and detection measures: 201-4 including, but not limited to, any loss mitigation
    activities or transactions such as foreclosures, deeds-in-lieu of foreclosure or short sales (c) Seller/Servicer’s
    in-house quality control program Pre- and post-funding quality control reviews are an integral part of fraud…'
  type: do
  tags:
  - regulator-direct
  - gap-fill
  - fhlmc-guide
  - section-complete
  primary_source:
    tier: 1
    authority: Freddie Mac Single-Family Seller/Servicer Guide §3201.1 — Fraud prevention and detection measures
      (05/06/26)
    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: 201-4 including, but not limited to, any loss mitigation activities or transactions such as
      foreclosures, deeds-in-lieu of foreclosure or short sales (c) Seller/Servicer’s in-house quality control program
      Pre- and post-funding quality control reviews are an integral part of fraud prevention and detection in the
      mortgage process. In the event populations of loans are identified that have a reason to suspect fraud, discretionary
      samples must be used to identify and report any additional instances of suspected fraud. Seller/Servicers
      must comply with all other Guide provisions relating to quality control reviews, including Section 3402.2(a).
      The Seller/Servicer must periodically (at least annually) update its quality control policies and procedures
      to address emerging fraud scenarios. (d) Additional fraud mitigation resources Information on preventing,
      detecting and investigating potential fraud and other suspicious activity is available on Freddie Mac’s website
      at https://sf.freddiemac.com/working-with- us/fraud-prevention/overview. For additional information, consult
      the Freddie Mac fraud hotline at 800-4FRAUD8 (800- 437-2838) or the Freddie Mac Exclusionary List, which is
      accessible via Freddie Mac Gateway®.
    drafter_attestation: Verbatim from Freddie Guide §3201.1 body (max-gap occurrence), snapshot 5869ee9e606cd4ae;
      substring-verified.
  judgment: false
- id: fhlmc-3201.1-4
  canonical_id: fhlmc-3201.1-4
  section: Freddie Mac Guide 3201.1
  description: '3201.1 Fraud prevention and detection measures: Fraud and other Suspicious Activity reporting requirements
    (05/06/26) This section contains requirements related to: ■ Procedures for detecting, identifying and reporting
    fraud, suspected fraud and Suspicious Activity ■ Requirement to report fraud, suspected fraud and Suspicious
    …'
  type: do
  tags:
  - regulator-direct
  - gap-fill
  - fhlmc-guide
  - section-complete
  primary_source:
    tier: 1
    authority: Freddie Mac Single-Family Seller/Servicer Guide §3201.1 — Fraud prevention and detection measures
      (05/06/26)
    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: 'Fraud and other Suspicious Activity reporting requirements (05/06/26) This section contains
      requirements related to: ■ Procedures for detecting, identifying and reporting fraud, suspected fraud and
      Suspicious Activity ■ Requirement to report fraud, suspected fraud and Suspicious Activity ■ Required reporting
      timelines ■ Use of the Tip Referral Tool ■ Fraud types and trends The Seller/Servicer must take measures to
      ensure that Mortgages sold to, or serviced for, Freddie Mac are free from any fraud, suspected fraud, Suspicious
      Activity, potential Suspicious Activity,'
    drafter_attestation: Verbatim from Freddie Guide §3201.1 body (max-gap occurrence), snapshot 5869ee9e606cd4ae;
      substring-verified.
  judgment: false
- id: fhlmc-3201.1-5
  canonical_id: fhlmc-3201.1-5
  section: Freddie Mac Guide 3201.1
  description: '3201.1 Fraud prevention and detection measures: 201-5 misrepresentation, misstatement or omission,
    and the Seller/Servicer must report impacted Mortgage(s) in accordance with the requirements outlined in this
    section. Mortgages involving any misstatement, misrepresentation or omission by the Borrower or any other party
    in the …'
  type: do
  tags:
  - regulator-direct
  - gap-fill
  - fhlmc-guide
  - section-complete
  primary_source:
    tier: 1
    authority: Freddie Mac Single-Family Seller/Servicer Guide §3201.1 — Fraud prevention and detection measures
      (05/06/26)
    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: '201-5 misrepresentation, misstatement or omission, and the Seller/Servicer must report impacted
      Mortgage(s) in accordance with the requirements outlined in this section. Mortgages involving any misstatement,
      misrepresentation or omission by the Borrower or any other party in the Mortgage and/or real estate transaction
      are not eligible for sale to Freddie Mac. (a) Procedures for detecting, identifying and reporting fraud, suspected
      fraud and Suspicious Activity The Seller/Servicer must have a documented program with procedures for detecting,
      identifying and reporting fraud, suspected fraud and other Suspicious Activity in connection with a Mortgage
      sold to, or serviced for, Freddie Mac and discovered at any time, including, but not limited to, during origination,
      quality control reviews, Servicing activities or loss mitigation efforts. Before reporting to Freddie Mac,
      a Seller/Servicer must perform due diligence to establish whether there is a reasonable basis to believe that
      fraud, suspected fraud or Suspicious Activity may have occurred. (b) Requirement to report fraud, suspected
      fraud and Suspicious Activity The Seller/Servicer must report to Freddie Mac when the Seller/Servicer has
      a reasonable belief that one of the following is occurring or has occurred during the origination, sale or
      Servicing of a Mortgage (including, but not limited to, any loss mitigation activity) regardless of whether
      (i) it had an impact on the eligibility of the Mortgage for sale to Freddie Mac or (ii) there was a breach
      of the Guide: ■ Any misrepresentation, misstatement or omission related to the Mortgage, the Borrower, the
      Mortgaged Premises or underlying real estate transaction ■ Involvement of a person or entity on the Freddie
      Mac Exclusionary List is involved or was involved in the origination, sale or Servicing of the Mortgage or
      the underlying real estate transaction in violation of Section 3101.1. (Note: For reporting the discovery
      of any possible breach of warranties regarding the Exclusionary List, refer to instructions in Section 3101.1(c)(i).)
      ■ Involvement of a person or entity on the FHFA Suspended Counterparty Program list in the origination, sale
      or Servicing of the Mortgage or the related real estate transactions in violation of Section 3101.2 ■ Termination
      or denial of mortgage insurance based on fraud (c) Required reporting timelines'
    drafter_attestation: Verbatim from Freddie Guide §3201.1 body (max-gap occurrence), snapshot 5869ee9e606cd4ae;
      substring-verified.
  judgment: false
- id: fhlmc-3201.1-6
  canonical_id: fhlmc-3201.1-6
  section: Freddie Mac Guide 3201.1
  description: '3201.1 Fraud prevention and detection measures: 201-6 The Seller/Servicer must report any reportable
    activity as defined in Section 3201.2(a) through Freddie Mac’s Tip Referral Tool, accessible via Freddie Mac
    Gateway, within the time frames outlined in the table below. Required reporting timelines Required time frame
    for repo…'
  type: do
  tags:
  - regulator-direct
  - gap-fill
  - fhlmc-guide
  - section-complete
  primary_source:
    tier: 1
    authority: Freddie Mac Single-Family Seller/Servicer Guide §3201.1 — Fraud prevention and detection measures
      (05/06/26)
    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: '201-6 The Seller/Servicer must report any reportable activity as defined in Section 3201.2(a)
      through Freddie Mac’s Tip Referral Tool, accessible via Freddie Mac Gateway, within the time frames outlined
      in the table below. Required reporting timelines Required time frame for reporting Discovery of reportable
      activity Within 30 days ■ Reportable activity discovered during a quality control review: The Seller/Servicer
      must notify Freddie Mac within 30 days after the date the quality control results are reported in writing
      to the Seller/Servicer’s Senior Management, in accordance with the reporting requirements in Section 3402.3(b)
      ■ Reportable activity discovered through any means other than a quality control review: The Seller/Servicer
      must notify Freddie Mac within 30 days after discovery Immediate (within one Business Day) In addition to
      the above 30-day reporting requirements, the Seller/Servicer must notify Freddie Mac within one Business Day
      after: ■ Becoming aware of theft of custodial funds, lack of collateral, non-remittance of pay-off funds or
      multiple deliveries of the same Mortgage ■ Determining there is a substantial likelihood that the fraud, suspected
      fraud or other Suspicious Activity will receive significant public exposure or publicity ■ Receiving notification
      of the entry of a civil judgment, guilty plea or criminal conviction indicating lack of integrity and relating
      to a participant in a Mortgage or the underlying real estate transaction or relating to a board member, officer,
      employee or contractor of the Seller/Servicer ■ Receiving notification from law enforcement or another governmental
      authority that such authority is conducting an investigation or prosecution of fraud relating to Mortgages
      owned by, or serviced for, Freddie Mac or relating to a board member, officer, employee or contractor of the
      Seller/Servicer ■ Identifying a possible fraud scheme or pattern of Suspicious Activity involving (i) more
      than five Mortgages sold to, or serviced for, Freddie Mac or (ii) Mortgages sold'
    drafter_attestation: Verbatim from Freddie Guide §3201.1 body (max-gap occurrence), snapshot 5869ee9e606cd4ae;
      substring-verified.
  judgment: false
- id: fhlmc-3201.1-7
  canonical_id: fhlmc-3201.1-7
  section: Freddie Mac Guide 3201.1
  description: '3201.1 Fraud prevention and detection measures: 201-7 Required reporting timelines Required time
    frame for reporting Discovery of reportable activity to, or serviced for, Freddie Mac with an aggregate UPB
    of at least $1 million ■ Identifying actual or possible terrorist financing or ongoing or possible money laundering
    schemes…'
  type: do
  tags:
  - regulator-direct
  - gap-fill
  - fhlmc-guide
  - section-complete
  primary_source:
    tier: 1
    authority: Freddie Mac Single-Family Seller/Servicer Guide §3201.1 — Fraud prevention and detection measures
      (05/06/26)
    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: '201-7 Required reporting timelines Required time frame for reporting Discovery of reportable
      activity to, or serviced for, Freddie Mac with an aggregate UPB of at least $1 million ■ Identifying actual
      or possible terrorist financing or ongoing or possible money laundering schemes or activity Seller/Servicers
      are not required to, and must not, disclose to Freddie Mac any Financial Crimes Enforcement Network Suspicious
      Activity Reports (SARs) or draft SARs, documents or information revealing the existence of a SAR or indicating
      whether a SAR has been filed, or where disclosure of Suspicious Activity would otherwise be prohibited by
      law. (d) Use of the Tip Referral Tool Seller/Servicers must report all Mortgage fraud, suspected Mortgage
      fraud and other Suspicious Activity using the Tip Referral Tool. Referrals made through the Tip Referral Tool
      must include: ■ Freddie Mac loan number ■ Property address ■ Mortgage fraud/Suspicious Activity type and category
      ■ Parties involved ■ Supporting documentation ■ A detailed narrative description of the activity, including
      why it has been deemed suspicious or fraudulent. (Seller/Servicers should not include protected personal information,
      such as Social Security numbers, in the narrative description.) ■ Any other required information as identified
      in the Tip Referral Tool (e) Fraud types and trends In connection with the Seller/Servicer’s fraud tracking
      procedures required in Section 3201.3(b), the Seller/Servicer must maintain and, upon request, provide Freddie
      Mac with aggregated records and reporting detailing fraud types and trends, including the number of fraud
      cases and positive Exclusionary List hits.'
    drafter_attestation: Verbatim from Freddie Guide §3201.1 body (max-gap occurrence), snapshot 5869ee9e606cd4ae;
      substring-verified.
  judgment: false
- id: fhlmc-3201.1-8
  canonical_id: fhlmc-3201.1-8
  section: Freddie Mac Guide 3201.1
  description: '3201.1 Fraud prevention and detection measures: Fraud cooperation and additional requirements (12/17/25)
    This section contains requirements related to: ■ Fraud cooperation ■ Additional fraud (a) Fraud cooperation
    The Seller/Servicer must cooperate with Freddie Mac to prevent and investigate fraud and other Suspicious Activity.…'
  type: do
  tags:
  - regulator-direct
  - gap-fill
  - fhlmc-guide
  - section-complete
  primary_source:
    tier: 1
    authority: Freddie Mac Single-Family Seller/Servicer Guide §3201.1 — Fraud prevention and detection measures
      (05/06/26)
    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: 'Fraud cooperation and additional requirements (12/17/25) This section contains requirements
      related to: ■ Fraud cooperation ■ Additional fraud (a) Fraud cooperation The Seller/Servicer must cooperate
      with Freddie Mac to prevent and investigate fraud and other Suspicious Activity. Cooperation includes making
      available to Freddie Mac individuals with relevant knowledge and providing to Freddie Mac and, when permitted
      by law, assisting Freddie Mac in obtaining all information, documentation and records requested by Freddie
      Mac relating to a Mortgage and related real estate transactions, including, but not limited to: ■ Closing
      or settlement agent files ■ Mortgage files ■ Borrower payment records ■ Reverifications of employment, income,
      occupancy and assets ■ Any internal or external communications The Seller/Servicer must provide all information
      requested by Freddie Mac within 14 days after receiving the request. (b) Additional fraud Seller/Servicers
      are reminded of their continuing obligation to comply with all applicable federal, State and local laws, including
      those relating to fraud and anti-money laundering (see Section 1301.2). Seller/Servicers must have in place
      written procedures for preventing, detecting and reporting fraud, and detecting and reporting Suspicious Activity,
      including the requirements of this chapter, and must make these procedures available to Freddie Mac upon request.
      Seller/Servicers must implement fraud risk management processes and controls, which may include screening
      software/tools and monitoring. Procedures must be in place to identify and track fraud trends, volume of potential
      fraud (such as number of fraud incidents and Exclusionary List hits) and Suspicious Activity and fraud alert
      review and resolution.'
    drafter_attestation: Verbatim from Freddie Guide §3201.1 body (max-gap occurrence), snapshot 5869ee9e606cd4ae;
      substring-verified.
  judgment: false
