source:
  type: regulation
  id: fnma-sel-a2-1-01
  authority: "FNMA Selling Guide A2-1-01 — Contractual Obligations for Sellers/Servicers"
  description: 'FNMA Selling Guide A2-1-01 establishes the foundational legal

    relationship between [LENDER] (seller/servicer) and Fannie Mae:

    executed MSSC (Mortgage Selling and Servicing Contract),

    incorporation-by-reference of the Selling Guide, Servicing Guide,

    Supplements, Announcements, Lender Letters; special-approval

    requirements for co-op share / HomeStyle Renovation / eMortgages /

    SMP bifurcation servicers; Lender Contract integration and non-

    divisibility; and joint-and-several responsibility on servicing

    transfers. Fills FNMA Selling A2-1 chapter gap.

    '
obligations:
- id: fnma-sel-a2-1-01-execute-mssc-and-relevant-agreements
  canonical_id: fnma-sel-a2-1-01-execute-mssc-and-relevant-agreements
  section: "FNMA Selling Guide A2-1-01 — Execute MSSC and any other relevant agreements"
  description: 'Following FNMA approval, [LENDER] (seller, servicer, or

    seller/servicer) and Fannie Mae shall execute the Mortgage

    Selling and Servicing Contract (MSSC) and any other relevant

    agreements. The MSSC establishes the basic legal relationship and

    incorporates by reference the Selling Guide, Servicing Guide,

    Document Custodian Requirements, Technology Guide, the

    Information Security and Business Resiliency Supplement, the UAD

    3.6 Policy Supplement, Manuals, Announcements, Lender Letters,

    Release Notes, Notices, and directives.

    '
  type: do
  audit_question: Can [LENDER] produce its executed MSSC and all addenda/amendments, plus evidence of acknowledgment of the documents incorporated by reference (Selling/Servicing Guides, Supplements, etc.)?
  workflow_phase: corporate_governance
  owner_role: chief_compliance_officer
  secondary_owner_role: general_counsel
  cadence: per-approval-and-amendment
  consequence: Without an executed MSSC, [LENDER] is not an approved FNMA seller/servicer; no FNMA business relationship.
  tags:
  - round-d
  - regulator-direct
  - fnma
  - selling-guide
  - mssc
  - lender-contract
  - promoted
  primary_source:
    tier: 1
    authority: "FNMA Selling Guide A2-1-01 — Role of MSSC"
    source_class: fnma-guide
    source_url: https://singlefamily.fanniemae.com/media/document/pdf/selling-guide
    snapshot_id: 5f7b8b79da595d76
    fetched_at: '2026-05-25T14:09:57Z'
    content_hash: sha256:placeholder-snapshot-content-hash-from-source-json
    paragraph_quote: 'both parties execute the Mortgage Selling and Servicing Contract (MSSC) and any other relevant agreements

      '
    drafter_attestation: 'Copied verbatim from snapshot 5f7b8b79da595d76. A2-1-01 MSSC-

      execution operative phrase.

      '
  promoted_at: '2026-05-25T19:08:47+00:00'
  promoted_from: fnma-sel-a2-1-01-roundd-v1.yaml
  program_review: Does the program maintain the executed MSSC and all addenda, plus acknowledgment of the documents incorporated by reference (Selling/Servicing Guides, Document Custodian Requirements, Technology Guide, Information Security & Business Resiliency Supplement, UAD 3.6 Policy Supplement, Manuals, Announcements, Lender Letters, etc.)?
  file_review: Confirm the executed MSSC and addenda are on file and that the incorporated-by-reference documents are acknowledged in the obligations inventory.
  judgment: false
- id: fnma-sel-a2-1-01-special-approval-required-for-listed-loan-types
  canonical_id: fnma-sel-a2-1-01-special-approval-required-for-listed-loan-types
  section: "FNMA Selling Guide A2-1-01 — Special approval required for co-op / HomeStyle / eMortgages / SMP bifurcation"
  description: '[LENDER] (Sellers/servicers) may NOT sell or service the following

    loan types unless [LENDER] obtains the applicable special approval

    and executes any additional agreements required by Fannie Mae:

    co-op share loans, HomeStyle Renovation mortgages, electronic

    mortgages (eMortgages), and bifurcation servicer roles in

    Servicing Marketplace (SMP). HomeStyle Renovation approval

    additionally requires a Special Lender Approval Form (Form 1000A).

    '
  type: refrain
  audit_question: For every loan type requiring FNMA special approval that [LENDER] has sold/serviced, can [LENDER] produce (a) the special approval documentation and (b) any required additional agreements (e.g., Form 1000A for HomeStyle Renovation)?
  workflow_phase: corporate_governance
  owner_role: chief_compliance_officer
  secondary_owner_role: general_counsel
  cadence: per-special-approval-loan-type
  consequence: Selling/servicing special-approval loan types without approval is a Lender Contract breach; FNMA enforcement risk.
  tags:
  - round-d
  - regulator-direct
  - fnma
  - selling-guide
  - special-approval
  - emortgages
  - homestyle
  - promoted
  primary_source:
    tier: 1
    authority: "FNMA Selling Guide A2-1-01 — Special Seller/Servicer Approval and MSSC Addendum"
    source_class: fnma-guide
    source_url: https://singlefamily.fanniemae.com/media/document/pdf/selling-guide
    snapshot_id: 5f7b8b79da595d76
    fetched_at: '2026-05-25T14:09:57Z'
    content_hash: sha256:placeholder-snapshot-content-hash-from-source-json
    paragraph_quote: 'Sellers/servicers may not sell or service these loan types unless they obtain the applicable special approval and execute any additional agreements required by Fannie Mae.

      '
    drafter_attestation: 'Copied verbatim from snapshot 5f7b8b79da595d76. A2-1-01 special-

      approval-loan-types operative requirement. Enumerated list (co-op,

      HomeStyle, eMortgages, SMP bifurcation) and Form 1000A reference

      paraphrased in description.

      '
  promoted_at: '2026-05-25T19:08:47+00:00'
  promoted_from: fnma-sel-a2-1-01-roundd-v1.yaml
  program_review: Does the program account for the special-approval gate — no co-op share loans, HomeStyle Renovation, eMortgages, or SMP bifurcation servicing without the applicable FNMA special approval and any additional agreement (Form 1000A for HomeStyle Renovation)?
  file_review: For any of the listed loan types sold/serviced, confirm the special-approval documentation and any required additional agreement are on file.
  judgment: false
- id: fnma-sel-a2-1-01-lender-contract-single-integrated-contract
  canonical_id: fnma-sel-a2-1-01-lender-contract-single-integrated-contract
  section: "FNMA Selling Guide A2-1-01 — Lender Contract is a single, integrated contract"
  description: "The MSSC, all documents incorporated by reference (Guides,\nSupplements, Manuals, Announcements, etc.), and any other\nagreements between [LENDER] and Fannie Mae imposing additional\nobligations (commitments, variances, special requirements,\ntechnology agreements, collateral agreements) together form a\nsingle, integrated contract — the \"Lender Contract\". [LENDER]\nmay not segregate breach analysis to a single Guide section.\n"
  type: notice
  audit_question: Does [LENDER] manage its FNMA contractual obligations recognizing the integrated nature of the Lender Contract (MSSC + all incorporated documents + side agreements), and does it have a consolidated obligations register?
  workflow_phase: corporate_governance
  owner_role: general_counsel
  secondary_owner_role: chief_compliance_officer
  cadence: continuous
  consequence: Segregated/piecemeal compliance management may miss cross-document breach exposure.
  tags:
  - round-d
  - regulator-direct
  - fnma
  - selling-guide
  - lender-contract
  - integrated-contract
  - promoted
  primary_source:
    tier: 1
    authority: "FNMA Selling Guide A2-1-01 — Lender Contract: Integration and Non-Divisibility"
    source_class: fnma-guide
    source_url: https://singlefamily.fanniemae.com/media/document/pdf/selling-guide
    snapshot_id: 5f7b8b79da595d76
    fetched_at: '2026-05-25T14:09:57Z'
    content_hash: sha256:placeholder-snapshot-content-hash-from-source-json
    paragraph_quote: 'form a single, integrated contract

      '
    drafter_attestation: 'Copied verbatim from snapshot 5f7b8b79da595d76. A2-1-01 single-

      integrated-contract operative phrase. Quote intentionally short

      to avoid surrounding curly-quote "Lender Contract" tag; enumerated

      component documents (MSSC, Guides, Supplements, side agreements)

      paraphrased in description.

      '
  promoted_at: '2026-05-25T19:08:47+00:00'
  promoted_from: fnma-sel-a2-1-01-roundd-v1.yaml
  program_review: Does the program manage FNMA obligations as a single integrated Lender Contract (MSSC + all incorporated documents + side agreements) with a consolidated obligations register, rather than segregating breach analysis to one Guide section?
  file_review: Review the consolidated obligations register; confirm it spans the MSSC, incorporated documents, and side agreements as one integrated contract.
  judgment: false
- id: fnma-sel-a2-1-01-selling-servicing-cannot-be-separated
  canonical_id: fnma-sel-a2-1-01-selling-servicing-cannot-be-separated
  section: "FNMA Selling Guide A2-1-01 — Selling and Servicing obligations integrated, cannot be separated"
  description: '[LENDER]''s benefits and obligations to service loans under the

    Lender Contract are integrated and cannot be separated from the

    seller''s or seller/servicer''s benefits and obligations to sell

    loans under the Lender Contract. Fannie Mae relies on this

    integration in entering into and continuing to be bound by the

    Lender Contract and in consenting to a servicing transfer.

    Operationally: [LENDER] cannot, by selling the servicing rights,

    escape selling-side reps-and-warranties exposure (or vice versa).

    '
  type: notice
  audit_question: Has [LENDER] structured its servicing-transfer due diligence and FNMA-relationship governance to recognize the inseparability of selling and servicing obligations under the Lender Contract?
  workflow_phase: corporate_governance
  owner_role: general_counsel
  secondary_owner_role: chief_compliance_officer
  cadence: per-transfer-or-amendment
  consequence: Treating selling and servicing obligations as separable can lead to under-reserving for legacy R&W exposure and FNMA-consent surprises.
  tags:
  - round-d
  - regulator-direct
  - fnma
  - selling-guide
  - lender-contract
  - non-divisibility
  - promoted
  primary_source:
    tier: 1
    authority: "FNMA Selling Guide A2-1-01 — Lender Contract: Integration and Non-Divisibility"
    source_class: fnma-guide
    source_url: https://singlefamily.fanniemae.com/media/document/pdf/selling-guide
    snapshot_id: 5f7b8b79da595d76
    fetched_at: '2026-05-25T14:09:57Z'
    content_hash: sha256:placeholder-snapshot-content-hash-from-source-json
    paragraph_quote: 'are integrated and cannot be separated from

      '
    drafter_attestation: "Copied verbatim from snapshot 5f7b8b79da595d76. A2-1-01 selling-\nand-servicing-cannot-be-separated operative phrase. Quote\nintentionally short to avoid surrounding U+2019 curly apostrophes\nin \"seller's\", \"servicer's\", and U+FB01 ligature in \"beneﬁts\".\nFull inseparability text paraphrased in description.\n"
  promoted_at: '2026-05-25T19:08:48+00:00'
  promoted_from: fnma-sel-a2-1-01-roundd-v1.yaml
  program_review: Does the program's servicing-transfer due diligence and FNMA governance recognize that selling and servicing benefits/obligations are integrated and cannot be separated — selling the servicing rights does not escape selling-side R&W exposure (or vice versa)?
  file_review: Review servicing-transfer due-diligence records; confirm they reflect the inseparability of selling and servicing obligations. The compliance person judges whether the governance adequately accounts for it.
  judgment: true
- id: fnma-sel-a2-1-01-joint-and-several-responsibility-on-transfer
  canonical_id: fnma-sel-a2-1-01-joint-and-several-responsibility-on-transfer
  section: "FNMA Selling Guide A2-1-01 — Joint-and-several responsibility on servicing transfer"
  description: 'Unless Fannie Mae otherwise agrees in writing, upon the transfer

    of servicing loans, [LENDER] (as either transferor or transferee)

    is on notice that the transferor and transferee are jointly and

    severally responsible for all selling representations, warranties,

    and obligations related to the transferred loans, including those

    that arise before delivery of the loans to Fannie Mae; AND the

    transferee is jointly and severally responsible for all servicing

    obligations and liabilities of the transferor, including those

    that arise before delivery of the loans.

    '
  type: notice
  audit_question: For every servicing-transfer transaction [LENDER] participated in (as transferor or transferee), can [LENDER] evidence due-diligence reflecting joint-and-several R&W liability exposure (vs. assumption of clean-handoff)?
  workflow_phase: servicing-transfer
  owner_role: general_counsel
  secondary_owner_role: chief_compliance_officer
  cadence: per-servicing-transfer
  consequence: Under-pricing or under-diligencing servicing transfers ignoring joint-and-several R&W liability can leave [LENDER] holding pre-transfer breaches.
  tags:
  - round-d
  - regulator-direct
  - fnma
  - selling-guide
  - joint-and-several
  - servicing-transfer
  - promoted
  primary_source:
    tier: 1
    authority: "FNMA Selling Guide A2-1-01 — General Contract Terms — Joint and Several Responsibility"
    source_class: fnma-guide
    source_url: https://singlefamily.fanniemae.com/media/document/pdf/selling-guide
    snapshot_id: 5f7b8b79da595d76
    fetched_at: '2026-05-25T14:09:57Z'
    content_hash: sha256:placeholder-snapshot-content-hash-from-source-json
    paragraph_quote: 'the transferor and transferee are jointly and severally responsible for all selling representations, warranties, and obligations related to the transferred loans

      '
    drafter_attestation: 'Copied verbatim from snapshot 5f7b8b79da595d76. A2-1-01 joint-and-

      several-responsibility-on-transfer operative phrase. The

      transferee-takes-all-prior-servicing-liability sister rule and the

      "unless FNMA agrees in writing" caveat paraphrased in description.

      '
  promoted_at: '2026-05-25T19:08:48+00:00'
  promoted_from: fnma-sel-a2-1-01-roundd-v1.yaml
  program_review: Does the program's transfer due diligence reflect that, absent FNMA's written agreement otherwise, transferor and transferee are jointly and severally responsible for all selling reps/warranties/obligations (including pre-delivery), and the transferee for all transferor servicing obligations/liabilities (including pre-delivery)?
  file_review: For servicing-transfer transactions, review the due diligence; the compliance person judges whether it accounts for joint-and-several R&W exposure rather than assuming a clean handoff.
  judgment: true
_promotion_history:
- promoted_at: '2026-05-25T19:08:48+00:00'
  candidate_path: obligations\_remediation\round-d-investor-guides\fnma-sel-a2-1-01-roundd-v1.yaml
  candidates_promoted: 5
  candidates_skipped_existing: 0
