source:
  type: regulation
  id: fhlmc-9101
  authority: "Freddie Mac Single-Family Seller/Servicer Guide Chapter 9101 — Delinquency Management for Mortgages Secured by Primary Residences"
  description: 'Chapter 9101 governs collection efforts, Borrower communications,

    foreclosure postponement, and management of the appeals process for

    denial of a Trial Period Plan, for Mortgages secured by Primary

    Residences. NOTE: actual title is "Delinquency Management for

    Mortgages Secured by Primary Residences".

    '
obligations:
- id: fhlmc-9101-individualized-collection-techniques
  canonical_id: fhlmc-9101-individualized-collection-techniques
  section: "Freddie Mac Guide Section 9101.1(a) — Servicer collection efforts"
  description: "[LENDER] must treat each Delinquency individually by varying the\ncollection techniques to fit the individual circumstances, and must\navoid establishing a fixed routine — particularly when dealing with\nchronically delinquent Borrowers.\n"
  type: do
  audit_question: Can [LENDER] evidence that, for each delinquent Freddie Mac-serviced Mortgage secured by a Primary Residence, collection techniques were varied to fit individual circumstances rather than applied as a fixed routine?
  workflow_phase: servicing
  owner_role: default_servicing_analyst
  secondary_owner_role: compliance_officer
  cadence: per-delinquency-event
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - fhlmc
  - freddie-mac
  - servicing-guide
  - delinquency-management
  - collections
  - promoted
  primary_source:
    tier: 1
    authority: Freddie Mac Single-Family Seller/Servicer Guide Section 9101.1(a)
    source_class: fhlmc-guide
    source_url: https://guide.freddiemac.com/ci-guide
    snapshot_id: 5869ee9e606cd4ae
    fetched_at: '2026-05-23T00:27:40Z'
    content_hash: sha256:9a1b23e5024bb369e7a59d36b3702383c11ace68b5d209fdef791bc8f955c637
    paragraph_quote: The Servicer must treat each Delinquency individually by varying the collection techniques
    drafter_attestation: Copied verbatim from Freddie Mac Guide snapshot 5869ee9e606cd4ae (Chapter 9101) at 2026-05-22.
  promoted_at: '2026-05-23T00:55:44+00:00'
  promoted_from: fhlmc-9101-roundb-v1.yaml
  program_review: Does the program facilitate varying collection techniques to fit individual circumstances rather than a fixed routine, especially for chronically delinquent Borrowers?
  file_review: Review collection notes on delinquent Primary-Residence loans; the compliance person judges whether techniques were individualized rather than a fixed routine.
  judgment: true
  feeds:
  - fhlmc-9101-refer-to-loss-mit-on-risk-of-loss
- id: fhlmc-9101-refer-to-loss-mit-on-risk-of-loss
  canonical_id: fhlmc-9101-refer-to-loss-mit-on-risk-of-loss
  section: "Freddie Mac Guide Section 9101.1(a) — Loss mitigation referral on risk of loss"
  description: 'If there is a known potential risk of loss or ownership to Freddie

    Mac, [LENDER] must refer the Borrower for loss mitigation

    immediately.

    '
  type: do
  audit_question: Can [LENDER] evidence that, on every known potential risk of loss or ownership to Freddie Mac, the Borrower was referred for loss mitigation immediately?
  workflow_phase: servicing
  owner_role: default_servicing_analyst
  secondary_owner_role: loss_mitigation_specialist
  cadence: per-risk-event
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - fhlmc
  - freddie-mac
  - servicing-guide
  - delinquency-management
  - loss-mitigation-referral
  - promoted
  primary_source:
    tier: 1
    authority: Freddie Mac Single-Family Seller/Servicer Guide Section 9101.1(a)
    source_class: fhlmc-guide
    source_url: https://guide.freddiemac.com/ci-guide
    snapshot_id: 5869ee9e606cd4ae
    fetched_at: '2026-05-23T00:27:40Z'
    content_hash: sha256:9a1b23e5024bb369e7a59d36b3702383c11ace68b5d209fdef791bc8f955c637
    paragraph_quote: If there is a known potential risk of loss or ownership to Freddie Mac, the Borrower must be
    drafter_attestation: Copied verbatim from Freddie Mac Guide snapshot 5869ee9e606cd4ae (Chapter 9101) at 2026-05-22.
  promoted_at: '2026-05-23T00:55:44+00:00'
  promoted_from: fhlmc-9101-roundb-v1.yaml
  program_review: Does the program ensure that on any known potential risk of loss/ownership to Freddie Mac the Borrower is referred for loss mitigation immediately?
  file_review: Start with the servicing notes to confirm the ball moved forward — that a known risk-of-loss triggered an immediate loss-mit referral. The compliance person judges whether the risk was known and the referral timely.
  judgment: true
- id: fhlmc-9101-ach-missed-contact-48hrs
  canonical_id: fhlmc-9101-ach-missed-contact-48hrs
  section: "Freddie Mac Guide Section 9101.1(b) — Borrowers on automatic withdrawal (ACH)"
  description: 'If an ACH payment cannot be processed on the specified date the

    Borrower has agreed to, [LENDER] must begin efforts to contact the

    Borrower within 48 hours to determine the reason for the missed

    payment.

    '
  type: do
  audit_question: Can [LENDER] evidence that, for every ACH payment that could not be processed on the agreed-upon date, efforts to contact the Borrower were begun within 48 hours to determine the reason for the missed payment?
  workflow_phase: servicing
  owner_role: default_servicing_analyst
  secondary_owner_role: compliance_officer
  cadence: per-failed-ach-event
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - fhlmc
  - freddie-mac
  - servicing-guide
  - delinquency-management
  - ach
  - 48-hour-contact
  - promoted
  primary_source:
    tier: 1
    authority: Freddie Mac Single-Family Seller/Servicer Guide Section 9101.1(b)
    source_class: fhlmc-guide
    source_url: https://guide.freddiemac.com/ci-guide
    snapshot_id: 5869ee9e606cd4ae
    fetched_at: '2026-05-23T00:27:40Z'
    content_hash: sha256:9a1b23e5024bb369e7a59d36b3702383c11ace68b5d209fdef791bc8f955c637
    paragraph_quote: processed on the specified date the Borrower has agreed to, the Servicer must begin efforts to
    drafter_attestation: Copied verbatim from Freddie Mac Guide snapshot 5869ee9e606cd4ae (Chapter 9101) at 2026-05-22.
  promoted_at: '2026-05-23T00:55:44+00:00'
  promoted_from: fhlmc-9101-roundb-v1.yaml
  program_review: Does the program ensure that when an agreed ACH payment cannot be processed, Borrower-contact efforts begin within 48 hours to determine the reason?
  file_review: For failed-ACH events, confirm from the notes that contact efforts began within 48 hours.
  judgment: false
_promotion_history:
- promoted_at: '2026-05-23T00:55:44+00:00'
  candidate_path: obligations\_remediation\_round_b_drafts\fhlmc-9101-roundb-v1.yaml
  candidates_promoted: 3
  candidates_skipped_existing: 0
