LIBOR TRANSITION – SOFR ARM ELIGIBILITY REQUIREMENTS in Guide Bulletin 2020-1, We Announced the Retirement of LIBOR-Indexed Arms

TO: Freddie Mac Sellers and Servicers April 1, 2020 | 2020-9

SUBJECT: LIBOR TRANSITION – SOFR ARM ELIGIBILITY REQUIREMENTS In Guide Bulletin 2020-1, we announced the retirement of LIBOR-indexed ARMs. We also announced that in a future Bulletin we would provide eligibility requirements and new ARM Notes and riders in support of Freddie Mac’s purchase of ARMs that use an index based on a 30-day average of the Secured Overnight Financing Rate (SOFR) applicable to residential ARMs (SOFR Index). With this Bulletin, we are announcing: • Our eligibility, underwriting and delivery requirements for SOFR-indexed ARMs • The availability of new ARM Notes and riders specific to the SOFR ARM offering In addition, we are updating the Guide to reflect the retirement of LIBOR-indexed ARMs.

SOFR ARMS Effective November 16, 2020 As of March 2, 2020, the Federal Reserve Bank of New York publishes the “30-day Average SOFR” each business day. Refer to the February 12, 2020 Federal Reserve Bank announcement for more information. We are updating the Guide to add a definition of “SOFR Index” to the Glossary and to reflect our eligibility, underwriting and delivery requirements for SOFR-indexed ARMs.

Eligible SOFR-indexed ARMs Freddie Mac purchases nonconvertible rate-capped ARMs that are fully-amortizing First Lien Mortgages. The following nonconvertible SOFR-indexed ARMs will be eligible for purchase by Freddie Mac under the ARM Cash and WAC ARM Guarantor programs:

Reference Index Interest and Initial Fixed Per Change Initial Periodic Life Min Max Prefix Product Source Payment Period Rate Cap Cap Cap Margin Margin (WAC ARM Label Type Adjustment Effective Adjustment (bps) (bps) Guarantor) Index Lead Months Frequency Days Count Count Months Count

3/6-Month 30-day 45 36 6 2 1 5 100 300 8A ARM Average SOFR

5/6-Month 30-day 45 60 6 2 1 5 100 300 8B ARM Average SOFR

7/6-Month 30-day 45 84 6 5 1 5 100 300 8C ARM Average SOFR

10/6-Month 30-day 45 120 6 5 1 5 100 300 8D ARM Average SOFR

Sellers should review revised Guide Sections 4401.2 through 4401.5 and 4401.8 for ARM eligibility requirements related to SOFR-indexed ARMs and Section 4401.9 and Exhibit 19, Credit Fees in Price, for information on the ARM Credit Fee in Price applicable to the sale of certain ARMs and other Credit Fees in Price.

Underwriting requirements – implementation of redesigned Uniform Residential Loan Application and Uniform Loan Application Dataset Effective immediately, a Seller may manually underwrite SOFR-indexed ARMs; that is, the Seller may conclude that Borrower credit reputation and capacity are acceptable based on the documentation included in the Mortgage file and described on Guide Form 1077, Uniform Underwriting and Transmittal Summary, or another document in the Mortgage file, as required in Guide Topics 5100 through 5500. On and after October 1, 2020, Sellers may submit SOFR-indexed ARMs to Loan Product Advisor®; however, to be able to do this, Sellers must have implemented Loan Product Advisor specification v.5.0.06 in conjunction with the redesigned Form 65, Uniform Residential Loan Application, (“URLA”). Freddie Mac is not updating legacy Loan Product Advisor (specification v4.8.01) for the submission of SOFR-indexed ARMs. Sellers may use the redesigned URLA and Uniform Loan Application Dataset (ULAD) during the “Open Production” phase that runs from September 1, 2020 through October 31, 2020. Sellers must use the redesigned URLA and ULAD for Mortgages with Application Received Dates on and after November 1, 2020. Refer to the Uniform Mortgage Data Program® (UMDP®) March 10, 2020 announcement regarding UMDP updates to support the SOFR Index transition and guidance regarding automated underwriting system specification changes and use of the SOFR Index.

Delivery requirements Sellers will be able to take out 30-day Average SOFR Cash Contracts in Loan Selling Advisor® to deliver SOFR-indexed ARMs beginning November 16, 2020. Sellers will be able to take out 30-day Average SOFR guarantor contracts in Loan Selling Advisor to deliver Mortgages into a WAC ARM PC beginning on November 16, 2020 for Mortgages with Settlement Dates on and after December 1, 2020. As announced in the March 10, 2020 UMDP communication, the Uniform Loan Delivery Dataset (ULDD) specification Appendix D – XML Data Requirements Reference Tool will be updated in the coming weeks to include the new ULDD Data Point and enumeration, which will be required for delivery of SOFR-indexed ARMs.

Uniform Instruments With this Bulletin, we are announcing that the 30-day Average SOFR uniform ARM Notes and riders are now available on our Uniform Instruments web page for Sellers to use.

Transfers of Servicing As a reminder, Seller/Servicers must not engage in a Transfer of Servicing involving 30-day Average SOFR-indexed ARMs with any Transferee Servicer that has not developed the operational capacity or capability to service 30-day Average SOFR-indexed ARMs.

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Additional resources and Guide updates We are updating Sections 4101.2, 4101.10, 4204.4, 4301.7, 4304.1, 4401.2 through 4401.5, 4401.8, 4501.3, 4601.1, 4603.3, 5101.1, 5703.3, 5703.9, 6201.3, 6302.7, Glossary, Exhibits 4, 17S and 34 to reflect SOFR-indexed ARMs. Additionally, we have created a fact sheet that summarizes the eligibility and delivery requirements for SOFR ARMs.

RETIREMENT OF LIBOR ARMS Effective January 1, 2021 In Bulletin 2020-1, we announced that Freddie Mac will not purchase any LIBOR-indexed ARM with an Application Received Date on and after October 1, 2020. In addition, Freddie Mac will no longer purchase LIBOR-indexed ARMs on and after January 1, 2021, regardless of the Application Received Date or Note Date. We are updating the Guide to remove references to LIBOR-indexed ARMs. We will provide the Servicing requirements for the replacement index for ARMs indexed to LIBOR in a future Guide Bulletin. Guide impacts: Sections 4101.2, 4101.10, 4301.7, 4401.3, 4401.5, 6302.7, 8502.2, Exhibits 17S and 34

ARM NOTES AND RIDERS: DELIVERY REQUIREMENTS Effective April 1, 2020 In Bulletin 2020-1, we updated the Guide to require the valid value “J23” for ULDD Data Point, Investor Feature Identifier (Sort ID 368) for Mortgages using the revised ARM Notes and riders. We are updating the Guide to clarify that this delivery requirement only applies to CMT- and LIBOR-indexed ARMs. Guide impacts: Section 6302.7 and Exhibit 34

FUTURE RETIREMENT OF CMT ARMS Targeted for 2021 As announced in Bulletin 2020-1, under FHFA guidance, Freddie Mac will cease purchasing CMT-indexed ARMs at some point in 2021. We are developing plans to execute that guidance and will publish definitive requirements in a future Bulletin under the guidance of the FHFA. We are informing Sellers so that they may take this into consideration when developing their business and operational LIBOR transition plans. We do not recommend that Sellers increase their CMT- indexed ARM deliveries to Freddie Mac to address the expiration of LIBOR ARM purchases.

GUIDE UPDATES SPREADSHEET For a detailed list of the Guide updates associated with this Bulletin and the topics with which they correspond, access the Bulletin 2020-9 (SOFR Requirements) Guide Updates Spreadsheet via the Download drop-down available at https://guide.freddiemac.com/app/guide/bulletin/2020-9.

CONCLUSION If you have any questions about the changes announced in this Bulletin, please contact your Freddie Mac representative or call the Customer Support Contact Center at 800-FREDDIE. Sincerely,

Danny Gardner Senior Vice President, Client and Community Engagement

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TO: Freddie Mac Servicers April 8, 2020 | 2020-10

SUBJECT: TEMPORARY SERVICING GUIDANCE RELATED TO COVID-19 Guide Bulletins 2020-4 and 2020-7 provided temporary Servicer guidance in response to the National Emergency Declaration resulting from the outbreak and spread of COVID-19. This Bulletin provides revised temporary guidance in response to feedback from Servicers, including questions relating to the impact of the recently enacted Coronavirus Aid, Relief and Economic Security Act (“CARES Act”). In an effort to provide enhanced clarity for our Servicers, we are updating requirements pertaining to the below listed topics, while also reminding Servicers that they must always comply with all applicable federal, State and local laws, ordinances, regulations, orders and regulatory guidance. Topics addressed in this Bulletin include: • Credit reporting requirements • Foreclosure moratorium • Bankruptcy motions for relief from automatic stay • Forbearance plans • Quality right party contact (QRPC) Additionally, we are clarifying that our requirements for the Servicing of Mortgages for Freddie Mac Borrowers impacted by COVID-19 related hardships (as described in Bulletin 2020-4) are separate and distinct from our requirements for the Servicing of Mortgages and Borrowers impacted by an Eligible Disaster. While we are leveraging certain aspects of our disaster Servicing practices, the requirements for how we are applying those and other COVID-19 requirements are described in Bulletins 2020-4, 2020-6, 2020-7 and this Bulletin. Servicers must not submit disaster reporting codes to Freddie Mac or otherwise leverage disaster related requirements that have not been expressly approved for application as part of our COVID-19 response in one of the previously referenced Bulletins or related Purchase Documents. This includes, but is not limited to: i) proactively applying forbearance without any communication with the Borrower and, ii) suppression of credit reporting (see updated credit reporting requirements below). Going forward, we will continue to address the COVID-19 pandemic as unique and distinct from Eligible Disasters, unless otherwise stated in future communications from Freddie Mac, regardless of any past, present or future Federal Emergency Management Agency (FEMA) declarations.

EFFECTIVE DATE All of the changes announced in this Bulletin are effective immediately unless otherwise noted.

Credit reporting requirements For any Borrower impacted by COVID-19, the Servicer must report activity to the credit bureaus in accordance with applicable law, including the Fair Credit Reporting Act and the CARES Act.

Foreclosure moratorium As provided in the CARES Act, Servicers must suspend all foreclosure actions, including foreclosure sales, through May 17, 2020. This includes initiation of any judicial or non-judicial foreclosure process, move for foreclosure judgment or order of sale. This foreclosure suspension does not apply to Mortgages on properties that have been determined to be vacant or abandoned.

Bankruptcy – Filing motions for relief from automatic stay Freddie Mac generally requires Servicers to file a motion for relief from automatic stay upon certain milestones based on the length of delinquency or post-petition payments per Guide Sections 9401.6 and 9401.7. In light of the CARES Act and other impacts resulting from the COVID-19 National Emergency, we are notifying Servicers that we are temporarily relieving them of their responsibility to meet these timelines. Servicers must continue to work with their bankruptcy counsel to determine the appropriate time to file such a motion.

Forbearance plans In addition to the forbearance plan requirements described in Guide Chapter 9203, and the temporary measures announced in Bulletin 2020-4, we are temporarily making the following adjustments to our requirements for forbearance plan evaluations for Borrowers with a COVID-19 related hardship: • Waiving the requirement that a forbearance plan may not extend beyond a date that would cause the Delinquency to exceed a cumulative total of 12 months of the Borrower’s contractual monthly Mortgage payment, as described in Sections 9203.12 and 9203.13(a) • Affirming that an eligible Borrower may be given an initial forbearance plan for up to 180 days, and thereafter one or more forbearance plan term extensions, provided the total forbearance terms do not exceed 12 months • Affirming that after the terms of the forbearance plan have been determined, Servicers must send the Borrower the forbearance plan agreement to the Borrower, in accordance with Section 9203.13(c), and may use the template provided in Guide Exhibit 93, appropriately modified to reflect the terms of the COVID-19 forbearance As required by the Guide, Bulletin 2020-4 and this Bulletin, the Servicer must make good faith efforts to establish QRPC with the Borrower in order to evaluate the Borrower for a forbearance plan, and the length of each forbearance plan term must be for an appropriate length, based on the Borrower’s individual circumstances and nature of the hardship, and must be agreed upon with or requested by the Borrower. In the event the Servicer and Borrower cannot agree on an appropriate forbearance length, or further communication with the Borrower is not possible under the circumstances, the Servicer must provide the term requested by the Borrower, not to exceed 180 days.

QRPC As described in Section 9102.3(b), QRPC occurs when a Servicer establishes contact with the Borrower and discusses with the Borrower, co-Borrower or trusted advisor, such as a housing counselor, the most appropriate options for Delinquency resolution. Freddie Mac maintains these principles and reaffirms their applicability when working with COVID-19 impacted Borrowers to ensure the Servicer understands the Borrower’s circumstances and determines the best possible outcome for resolving the Borrower’s Delinquency. In the event the Servicer is unable to achieve full QRPC and offers a forbearance plan to a COVID-19 impacted Borrower in compliance with applicable law, the Servicer is considered to be in compliance with the Guide. Outside of the forbearance requirements above, the Servicer must make good faith efforts to establish limited QRPC, in lieu of the full requirements of Section 9102.3(b), as described below for the purpose of determining the best loss mitigation strategy for the Borrower and answering the Borrower’s questions relating to repayment of forborne amounts when the forbearance period has ended: • Determining the reason for the Delinquency and whether the reason is temporary or permanent in nature • Determining the Borrower's ability to repay the debt • Setting payment expectations and educating the Borrower on the availability of alternatives to foreclosure as appropriate • Obtaining a commitment from the Borrower to either resolve the Delinquency through traditional methods (paying the total delinquent amount) or engaging in an alternative to foreclosure solution

ADDITIONAL RESOURCES We encourage Servicers to review the following resources: • Our Single-Family web page on COVID-19 resources, which will include Servicing FAQs in the future

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• Joint guidance and FAQs for Servicers during the COVID-19 crisis issued by federal and State regulators, including the Consumer Financial Protection Bureau

CONCLUSION We appreciate the support that Servicers continue to extend to Borrowers coping with hardships attributed to COVID-19. If you have any questions about the changes announced in this Bulletin, please contact your Freddie Mac representative or call the Customer Support Contact Center at 800-FREDDIE. Sincerely,

Bill Maguire Vice President, Servicing Portfolio Management

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TO: Freddie Mac Sellers April 14, 2020 | 2020-11

SUBJECT: SELLING GUIDANCE RELATED TO COVID-19 We continue to work closely with Fannie Mae under the guidance of the FHFA to address the ongoing economic implications and uncertainty related to the coronavirus disease (COVID-19) pandemic and its impacts on Borrowers and the Mortgage origination process. This Guide Bulletin provides: Property eligibility • Temporary Condominium Project flexibilities • Appraisal flexibility updates • CHOICERenovation® Mortgage updates Seller’s post-funding quality control reviews • Temporary flexibility with respect to Seller’s post-funding quality control review regarding targeted sampling Mandatory Cash Contracts • Revisions to our requirements regarding maximum contract amounts and aggregate cash commitment volume for Mandatory Cash Contracts and WAC ARM Cash Contracts Remote Online Notarization • Updates to our list of permitted States for Remote Online Notarization and additional clarifications We are also reminding Sellers of additional resources, including our Selling FAQs related to COVID-19, which we continue to update.

PROPERTY ELIGIBILITY

Condominium Project reviews These temporary flexibilities are effective immediately for all Mortgages in process and remain in place for Mortgages with Application Received Dates on or before May 17, 2020. Freddie Mac is offering temporary flexibilities and guidance to assist Sellers in Condominium Project reviews during the COVID-19 pandemic

Exempt From Review: LTV/TLTV/HTLTV ratios We are temporarily extending Exempt from Review eligibility for maximum loan-to-value (LTV)/total LTV (TLTV)/Home Equity Line of Credit (HELOC)TLTV (HTLTV) ratios from 80% to the maximum ratios allowed in Guide Section 4203.4 for Freddie Mac owned “no cash-out” refinance Condominium Unit Mortgages secured by Primary Residences only. When using this new flexibility, Sellers must ensure that the Condominium Project meets the exempt from review requirements in Sections 5701.7 and the `project in litigation requirements in Section 5701.3(i) (now applicable to higher LTV ratios). Second Homes and Investment Properties are ineligible. For each Condominium Unit Mortgage, Sellers must deliver ULDD Data Point, Project Classification Identifier (Sort ID 42) as “Exempt From Review.”

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Project Documents used in Condominium Project reviews Sellers have reported that some Homeowners Associations are experiencing a delay in ratifying their 2020 budgets because they are unable to meet in person to vote on a new budget. When an Established Condominium Project review is used, we will accept the budget from the 2019 fiscal year when the current year’s budget has not yet been ratified due to issues related to COVID-19. This flexibility may not be used for New Condominium Project reviews. Sellers are reminded that all other applicable requirements must be met, including requirements relating to delinquent Homeowners Association assessments. Due to the impact of the COVID-19 pandemic on many businesses, we understand that Sellers are having increased difficulties in obtaining Project Documents from Homeowners Associations and property managers. Sellers may use other sources of Condominium Project data to complete project reviews including, but not limited to, appraisals, MLS records, plat map/site surveys, public records, State laws or local ordinances, and tax searches. Additionally, there are various vendor products available that provide Project Documents and/or information regarding Condominium Project eligibility. Some information and/or documents, such as the Condominium Project’s current budget, may be available only from the Homeowners Association or property manager so Seller may be unable to obtain them if these operations are closed for extended periods. Sellers are reminded that, if they completed a project review for an Established Condominium Project during the one year period prior to the Note Date of the particular Mortgage, that project review may be used for multiple Condominium Unit Mortgages in the same Condominium Project for up to one year prior to the Note Date of the particular Mortgages. For New Condominium Projects, the time frame is 180 days prior to the Note Date. Note that: • For all Mortgages with LTV ratios greater than 80%, we require mortgage insurance in accordance with Guide requirements • Capitalized terms in this Condominium Project reviews section that are not defined in the Glossary are defined in Chapter 5701 • We are not updating the Guide to reflect these temporary flexibilities Appraisal flexibilities

Map reference field for desktop and exterior-only appraisals Freddie Mac is clarifying that the map reference field on the appraisal report may only contain the word “desktop” or “exterior.” No other words or phrases may be used or included. The map reference field should reflect the appraisal type agreed to with the acceptance of the assignment and the minimum scope of work required for the assignment. The appraiser is responsible for determining what is the adequate scope of work for any assignment and may choose to expand the scope of work beyond the minimum requirements.

Property valuations – appraisal flexibilities for new construction properties (purchase transactions) In response to Seller inquiries, Freddie Mac is clarifying that the “permissible appraisal requirements” eligibility chart described in Bulletin 2020-5 apply to the appraisal flexibilities for new construction properties including the requirement that second homes with LTVs above 85% require an interior and exterior inspection appraisal.

Loan Product Advisor® – update to identify Freddie Mac-owned Mortgages Loan Product Advisor® will be enhanced at a future date to assist Sellers with identifying if a mortgage being refinanced is owned by Freddie Mac. This enhancement supports our COVID-19 related appraisal flexibilities for Freddie Mac owned no cash-out refinance Mortgages announced in Bulletin 2020-5. If a match is found based on property address and the Social Security number of one or more Borrowers on an existing loan, then informational feedback messages will be returned on both submissions and resubmissions indicating the Mortgage is Freddie Mac-owned. Loan Product Advisor feedback messages will be updated to reflect these changes.

Delivery instructions Beginning on April 13, 2020, for Mortgages with property valuations completed in accordance with the appraisal flexibilities in Bulletin 2020-5, Loan Selling Advisor® will be updated to accept “Desktop Appraisal” and “Drive By” as valid values for ULDD Data Point, Property Valuation Method Type (Sort ID 89). Starting on this date, Sellers should use their best efforts to provide “Drive By” or “Desktop Appraisal,” as applicable, in lieu of “Full Appraisal” for Sort ID 89. However,

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we recognize a Seller’s systems may not be updated to accommodate this change and in these cases, the Seller may continue to deliver “Full Appraisal.” The table below provides the appropriate delivery instructions when either an exterior-only inspection appraisal report or a desktop appraisal report was used in accordance with the flexibilities in Bulletin 2020-5.

Sort ID ULDD Data Point Exterior-only Desktop Appraisal Report inspection appraisal report

89 Property Valuation Drive By Desktop Appraisal Method Type

85 Property Valuation Exterior Only Inspection Residential Uniform Residential Appraisal Form Type Appraisal Report (FRE 2055/FNM Report (FRE 70/FNM 1004) 2055) Individual Condominium Unit Exterior Only Inspection Individual Appraisal Report (FRE 465/FNM Condominium Unit Appraisal Report 1073) (FRE 466/FNM 1075) Individual Cooperative Interest Exterior Only Inspection Individual Appraisal Report (FNM 2090) Cooperative Interest Appraisal Small Residential Income Report (FNM 2095) Property Appraisal Report (FRE Small Residential Income Property 72/FNM 1025) Appraisal Report (FRE 72/FNM Manufactured Home Appraisal 1025) Report (FRE 70B/FNM 1004C) Manufactured Home Appraisal Report (FRE 70B/FNM 1004C)

Negotiated provisions related to appraisal flexibilities The appraisal flexibilities announced in Bulletins 2020-5 and 2020-8 may be used in conjunction with negotiated provisions in the Seller’s Purchase Documents unless the Seller is otherwise notified by Freddie Mac. For refinance Mortgages, only “no cash-out” refinances of Freddie Mac-owned Mortgages being sold to Freddie Mac are eligible for the appraisal flexibility shown below:

Permissible appraisal requirements

Mortgage purpose LTV ratio Occupancy type Ownership of Permissible appraisals Mortgage being refinanced

Purchase transaction, Up to 97% Primary N/A Interior and exterior inspection including new Residence appraisal, desktop appraisal or construction properties* exterior-only appraisal

<85% Second homes N/A Interior and exterior inspection and Investment appraisal, desktop appraisal or Properties exterior-only appraisal

“No cash-out” refinance As All Mortgage being Interior and exterior inspection permitted in refinanced owned by appraisal or exterior-only the Guide Freddie Mac** appraisal

* Permissible appraisals for new construction properties are limited to desktop appraisals.

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** Sellers are reminded to determine whether the existing Mortgage is owned by Freddie Mac by referencing its own Servicing records or by accessing the Freddie Mac Loan Look-Up Tool, provided the Borrower has authorized the Seller to obtain this information on its behalf. Interior and exterior inspection appraisals are required for: • Second home purchase transactions with LTV ratios > 85% • “No cash-out” refinances when the Mortgage being refinanced is not owned by Freddie Mac • Cash-out refinances All other requirements for the use of temporary flexibilities apply. Refer to Bulletins 2020-5 and 2020-8 for complete requirements. Virtual inspections for appraisals Appraisers may use virtual inspection methods to augment the data and imagery that is used for either a desktop appraisal or an exterior-only inspection appraisal. All interior and exterior inspection appraisals require the appraiser to perform a complete onsite interior and exterior inspection of the property. A virtual inspection is not a substitute for an onsite interior and exterior inspection. CHOICERenovation® Mortgages In connection with CHOICERenovation® Mortgages with Borrowers who enter into forbearance plans after the Freddie Mac Settlement Date but prior to completion of the renovations, continuation of draw distributions is permitted during the forbearance period. All other program requirements continue to apply. Additionally, when an appraiser is confirming completion of renovations for a CHOICERenovation Mortgage, an on-site interior and exterior inspection is required for Form 442, Completion Report. Although virtual inspections using video and photographs provided by the Borrower or contractor may be used to evidence renovation progress to disburse additional renovation funds, a virtual inspection may not be used to complete Form 442.

TEMPORARY FLEXIBILITIES REGARDING SELLER’S POST-FUNDING QUALITY CONTROL REQUIREMENTS – TARGETED SAMPLING Freddie Mac recognizes the unique challenges in the market today related to COVID-19 and will allow the following additional temporary flexibility with respect to Seller’s post-funding quality control review. Effective Term: The QC Flexibilities announced in this Bulletin are effective immediately for all Mortgages currently in the process of a post-closing Seller in-house quality control review and will remain in place for all Mortgages selected through June 2020 for post-closing Seller in-house quality control reviews. The requirement in Section 3402.4(b) for a Seller to select all Mortgages sold to Freddie Mac that become 60 days or more past due in the first six months following the Note Date for a targeted sample is amended to allow flexibility with respect to the sample size. In lieu of selecting all such Mortgages for its targeted sample, a Seller may select an appropriate risk-based sample. The risk-based sample population must include Mortgages that are past due as a result of COVID-19 hardships. There is no change to the scope of review. The selected Mortgages must be carefully evaluated to determine the presence of any fraud or other deficiency. Because quality control processes are especially important in times of significant stress, we encourage Sellers to adopt the QC Flexibilities only as they feel necessary.

MANDATORY CASH CONTRACTS AND WAC ARM CASH CONTRACTS We are updating the requirements applicable to offer amounts and procedures for fixed-rate Mandatory Cash Contracts as stated in Section 6101.3(a) and WAC ARM Cash Contracts as stated in Section 6102.4(a) to include the following: • Freddie Mac may, at its discretion and at any time, impose a maximum contract amount for individual Mandatory Cash Contracts

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• Sellers may enter into multiple mandatory fixed-rate and WAC ARM cash commitments but may not exceed $200 million in aggregate fixed-rate and WAC ARM commitment volume per day. Sellers may seek an exception to this amount by contacting the Cash Desk ([email protected] or 571-382-5960). If this limit is exceeded without prior Freddie Mac approval, Freddie Mac may pair off the Seller’s contract(s) or may require the Seller to pair off the contract(s) at the Seller’s expense. The Guide will be updated at a later date to reflect these changes.

REMOTE ONLINE NOTARIZATION In Bulletin 2020-8, we announced that Electronic notarization may involve a remote process (“Remote Online Notarization”) in the States listed in Attachment C to Bulletin 2020-8, Permitted States for Remote Online Notarization, provided that the system used for the remote notarization meets the minimum standards provided in the Bulletin. With this Bulletin, we are adding Arkansas, Georgia and Hawaii to our list of permitted States for Remote Online Notarization (provided in Attachment C to Bulletin 2020-8) and clarifying that in the event the Seller wishes to include the seller of the Mortgaged Premises in the Electronic Closing process: • The Borrower and the seller of the Mortgaged Premises must give their individual, specific and express Electronic consent to their respective Electronic Signatures on an Electronic warranty deed and other purchase and sale documents • The Electronic warranty deed must be recorded in the local recorder’s office in the State in which the Mortgaged Premises is located, in compliance with the requirements of the Guide We are also reminding Sellers that if they are interested in including an Electronic Note (eNote) in the electronic closing package containing other documents that are notarized through a Remote Online Notary process, they must obtain Freddie Mac approval to deliver such Mortgages. (See Chapter 1402 on eMortgages.) Note that capitalized terms in this Remote Online Notarization section that are not defined in the Glossary are defined in Chapters 1401 or 1402.

SYSTEM AND GUIDE UPDATES We are not updating the Guide at this time to reflect any of the changes noted in this Bulletin.

ADDITIONAL RESOURCES We encourage Sellers to review the following resources: • Our Single-Family web page on COVID-19 • Our Selling FAQs related to COVID-19 • The Center for Disease Control’s web page on COVID-19 • The Appraisal Foundation’s Appraiser Qualifications and Standards Q&As • The Appraisal Institute’s Coronavirus-related Direction for Appraisers • National Association of Realtors Coronavirus Guide for Realtors

CONCLUSION We appreciate the support that Sellers continue to extend to Borrowers coping with hardships attributed to COVID-19. If you have any questions about the changes announced in this Bulletin, please contact your Freddie Mac representative or call the Customer Support Contact Center at 800-FREDDIE. Sincerely, Danny Gardner Senior Vice President, Client and Community Engagement

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TO: Freddie Mac Sellers April 22, 2020 | 2020-12

SUBJECT: TEMPORARY SELLING REQUIREMENTS FOR MORTGAGES IN COVID-19 RELATED FORBEARANCE We continue to work closely with Fannie Mae under the guidance of the FHFA with the goal of providing liquidity to the market while supporting responsible lending and sustainable homeownership during the time of the crisis caused by the COVID-19 pandemic. This Guide Bulletin provides requirements for Mortgages in forbearance as defined below, including: • Reminder of general ineligibility of Mortgages in forbearance • Temporary requirements for the purchase of Mortgages in forbearance • Reminders related to Seller representations and warranties We are also reminding Sellers of additional resources and notifying Sellers of our new Mortgages in Forbearance FAQs. The Guide will not be updated to reflect the temporary changes noted in this Bulletin. Note Date references All references to the Note Date refer to the modification date for Seller-Owned Modified Mortgages, the Conversion Date for Seller-Owned Converted Mortgages, the Effective Date of Permanent Financing for Construction Conversion and Renovation Mortgages, or the assumption agreement date, as applicable. Meaning of the term “Mortgage in forbearance” For purposes of the temporary requirements announced in this Bulletin, the term “Mortgage in forbearance” will include a Mortgage for which a Borrower: • Requested forbearance and attested to or otherwise informed the Seller or Servicer that, after the Note Date, he or she suffered financial hardship caused directly or indirectly by COVID-19, or • Was approved for a forbearance plan based on a COVID-19 related financial hardship that occurred after the Note Date Note: A Borrower inquiry without a request for forbearance, does not, in itself, render the Mortgage in forbearance.

REMINDER OF GENERAL INELIGIBILITY OF MORTGAGES IN FORBEARANCE Mortgages that have been placed into forbearance are ineligible for sale to Freddie Mac. Mortgages in forbearance are not considered investment quality Mortgages in accordance with Guide Section 4201.1. In addition, if a Mortgage is in forbearance then certain terms of the Mortgage have been changed or waived, rendering the Mortgage ineligible under Section 4201.2. If either the Seller or the Servicer of the Mortgage is aware that the Borrower has requested forbearance as a result of financial hardship, the Seller would be considered aware of circumstances adversely affecting the value of the Mortgage, rendering the Mortgage ineligible for sale under Section 4201.13.

TEMPORARY REQUIREMENTS: PURCHASE OF MORTGAGES IN FORBEARANCE Although generally, as described above, Mortgages in forbearance are not eligible for sale to Freddie Mac, we are implementing the following temporary eligibility requirements due to the impact of COVID-19 on our Sellers and their Borrowers and in order to continue to provide crucial liquidity to the mortgage industry. Our focus is to provide liquidity to the market, while also managing credit risk. As a result, we will be reviewing the volume of Mortgages delivered in accordance with the provisions of this Bulletin and may adjust our requirements as necessary.

Effective dates These temporary requirements are effective for Mortgages with Note Dates on or after February 1, 2020 and on or before May 31, 2020, and Settlement Dates on or after May 1, 2020. Additionally:

Contract type Additional effective date requirements

Guarantor and MultiLender Contracts • Mortgages with Note Dates on or after February 1, 2020 and on or before March 31, 2020 must have Settlement Dates on or before May 31, 2020 Cash Contracts: Mortgages that are in forbearance, but not yet delinquent • Mortgages with Note Dates on or after April 1, 2020 and on or before May 31, 2020 must have Settlement Dates on or before July 31, 2020

Cash Contracts: Mortgages that are in The Cash Settlement Date must be no later than the 20th of the month forbearance, that are no more than 30 days after the month the Mortgage became 30 days delinquent (see the delinquent definition below). For example: • Notes with a first payment due date of April 1: If the Borrower does not pay the April payment, the Mortgage will become 30 days delinquent at the close of business on April 30. For these loans, the Settlement Date must be on or before May 20. • Notes with first payment due dates of April 2 – April 30: If the Borrower did not pay the April payment, the Mortgage will become 30 days delinquent at the close of business on May 31. For these loans, the Settlement Date must be on or before June 20.

Eligibility requirements We are temporarily updating our Mortgage eligibility requirements to allow Sellers to deliver certain Mortgages in forbearance that would not otherwise be eligible for sale under the Guide. Specifically, we will allow the delivery of Mortgages for which a Borrower: • Requested forbearance and attested to or otherwise informed the Seller or Servicer that, after the Note Date, he or she suffered financial hardship caused directly or indirectly by COVID-19, or • Was approved for a forbearance plan based on a COVID-19 related financial hardship that occurred after the Note Date These Mortgages are eligible provided that each Mortgage: • Is either a purchase transaction Mortgage or a “no cash-out” refinance Mortgage • Is no more than 30 days delinquent as defined below Note: In connection with Mortgages a Seller intends to sell to Freddie Mac, Sellers should not in any way discourage Borrowers from contacting them or encourage Borrowers to delay notifying them either before or after the Note Date if they are experiencing a COVID-19 related financial hardship.

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30 days delinquent For purposes of this Bulletin a Mortgage with a payment due date of the first of the month becomes 30 days delinquent when all or part of only one monthly payment remains unpaid as of the close of business on the last Business Day of the month. If the payment due date is not on the first of the month, the Mortgage becomes 30 days delinquent when all or part of only one monthly payment remains unpaid 30 or more actual calendar days as of the close of business on the last Business Day of the month. Such Mortgages remain 30 days delinquent until the close of business on the last Business Day of any subsequent month when an amount greater than one monthly payment remains unpaid.

Credit Fees in Price Mortgages in forbearance, as defined above, will be subject to the following Credit Fees in Price:

Delivery requirements Loan Selling Advisor® will be updated in support of the temporary requirements above for Mortgages with Settlement Dates on and after May 1, 2020. In connection with each Mortgage delivered in accordance with the temporary requirements above, the Seller must enter the applicable valid value for ULDD Data Point, Investor Feature Identifier (Sort ID 368): • “J76” for Mortgages with COVID-19 related forbearance for non-First-Time Homebuyer, or • “J77” for Mortgages with COVID-19 related forbearance for First-Time Homebuyer As a reminder: • For each Mortgage sold to Freddie Mac, Sellers are required to deliver ULDD Data Point, Delinquent Payments Over Past Twelve Months Count (Sort ID 452). Delinquencies in connection with Mortgages in forbearance must be included when delivering this ULDD Data Point. • If any Borrower meets the definition of a First-Time Homebuyer on a Mortgage in forbearance, the Seller must deliver ULDD Data Point, Borrower First-Time Homebuyer Indicator (Sort ID 597) and the indicator must be set to “true” as defined in Guide Exhibit 1 Reporting forbearance after delivery As a reminder Seller/Servicers must report any COVID-19 related forbearance to us in accordance with the requirements of Bulletin 2020-7. Loan characteristics We expect Mortgages sold to us under these temporary requirements to be representative in both profile and volume of a Seller’s agency-eligible Mortgage originations typically sold to Freddie Mac.

SELLER REPRESENTATIONS AND WARRANTIES REMINDERS In response to the pandemic, we reminded Sellers of their obligations related to determining income continuance and income stability in Bulletin 2020-5 and the related frequently asked questions. We have recommended that Sellers

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practice additional due diligence to ensure accurate information is obtained and we strongly encouraged Sellers to help ensure that the Borrowers’ ability to repay the Mortgage is not negatively impacted. Notwithstanding the temporary updates announced in this Bulletin, the Seller remains responsible for complying with all other requirements and for all representations and warranties in the Guide, including all requirements related to underwriting the Borrower to ensure the Borrower is qualified for the Mortgage as of the Note Date. Additionally, except as specifically permitted in this Bulletin for Mortgages in forbearance, if the Seller or Servicer becomes aware of a change in the Borrower’s circumstances after the Note Date, the Seller must determine whether the Mortgage must be reevaluated in light of the new information. The Mortgage is eligible for sale to Freddie Mac only if all of the requirements of the Purchase Documents are met, including but not limited to, the requirements of Section 5101.7 regarding resubmission to Loan Product Advisor® after the Note Date. Furthermore, in accordance with Section 1301.11, Mortgages that go into forbearance after the Note Date are not eligible for relief of enforcement of the representations and warranties based on the Borrower’s payment history, but may be eligible for relief based on a satisfactory conclusion of a Freddie Mac quality control review of the Mortgage file if the Mortgage otherwise meets the requirements in Version 2 of the selling representation and warranty framework.

ADDITIONAL RESOURCES We encourage Sellers to review the following resources: • Freddie Mac Single-Family web page on COVID-19 • Freddie Mac Selling FAQs related to COVID-19 • The Center for Disease Control’s web page on COVID-19 • The Appraisal Foundation’s Appraiser Qualifications and Standards Q&As • The Appraisal Institute’s Coronavirus-related Direction for Appraisers • National Association of Realtors Coronavirus Guide for Realtors

Danny Gardner Senior Vice President, Client and Community Engagement

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TO: Freddie Mac Sellers April 22, 2020 | 2020-13

SUBJECT: SELLING UPDATES This Guide Bulletin announces: Income requirements • Updates to changes previously announced for income requirements SOFR-indexed ARMs • Updates to underwriting requirements for SOFR ARMs announced in Bulletin 2020-9 eMortgage updates • Updates related to eMortgage eligibility and requirements for eClosing and eNote Vault systems Additional Guide updates and reminders • Further updates as described in the Additional Guide updates and reminders section of this Bulletin

EFFECTIVE DATE All of the changes announced in this Bulletin are effective immediately unless otherwise noted.

INCOME REQUIREMENTS Effective July 2, 2020 Based on the feedback and questions we received from Sellers regarding changes to our income requirements announced in Bulletin 2019-20, we are removing the requirement that, for hourly earnings to be considered non- fluctuating, the documentation in the Mortgage file must support a minimum of six months history of the Borrower working the same number of hours with the same employer. As a reminder, Guide Section 5301.1 requires that, for all stable income, including non-fluctuating employment earnings, the Seller must consider the length of history of the income and whether the earnings have been level and consistent. As such, the Seller must review all required employment and income documentation for consistency. As part of this review, the Seller must ensure it is able to support that the Borrower’s income is stable in instances when the Borrower with a short tenure at their current employer is qualified using income that is not consistent with income received from previous employment. All other changes to the income requirements announced in Bulletin 2019-20 continue to be effective for Mortgages with Settlement Dates on and after July 2, 2020. Guide impact: Section 5303.2

SOFR ARMs

Updated underwriting requirements Eligible for submission to legacy Loan Product Advisor® beginning October 1, 2020 In Bulletin 2020-9, Freddie Mac announced its eligibility, underwriting and delivery requirements for SOFR-indexed ARMs. Sellers could manually underwrite SOFR ARMs effective immediately (April 1, 2020) but would not be able to submit these ARMs to Loan Product Advisor® until October 1, 2020. Further, in order to do so, Sellers would have to have implemented Loan Product Advisor specification v5.0.06 in conjunction with the redesigned Guide Form 65, Uniform Residential Loan Application (“URLA”). Since the mandate date for the redesigned URLA was anticipated to be November 1, 2020, Freddie Mac was not updating legacy Loan Product Advisor (specification v4.8.01) to accept submission of SOFR-indexed ARMs. On April 14, 2020, Freddie Mac and Fannie Mae (the “GSEs”) announced that to support the industry, as a result of the COVID-19 pandemic, the implementation of the redesigned URLA and Uniform Loan Application Dataset (ULAD) would be delayed. The new mandate date is March 1, 2021. As a result, Freddie Mac is updating its underwriting requirements for SOFR-indexed ARMs to permit Sellers to submit SOFR-indexed ARMs to legacy Loan Product Advisor (v4.8.01) beginning October 1, 2020. Additional information and documentation related to this update will be provided to Loan Product Advisor software vendors and lenders in a subsequent communication. Guide impact: Section 5101.1

Updated delivery requirements On April 21, 2020, the GSEs announced updates to the Uniform Loan Delivery Dataset (ULDD) specification (Appendix D) to support the delivery of SOFR ARMs. Sellers can view the announcement and the updated specification on the ULDD web page. eMORTGAGES

Removing restrictions on delivering Mortgages secured by Manufactured Homes as eMortgages Seller/Servicers approved to deliver eMortgages to Freddie Mac may now sell eMortgages secured by Manufactured Homes that are: • Classified as real property, and • Located in non-certificate of title States or certificate of title surrender States, as described in Section 5703.7(b) The Seller/Servicer must comply with the requirements set forth in Chapter 5703 to sell eMortgages secured by Manufactured Homes Guide impact: Section 1402.7 eClosing and eNote Vault system requirements We are specifying in the Guide that the eClosing System used by the Seller/Servicer to originate eMortgages and the eNote Vault System used to store authoritative copies of eNotes must implement disaster recovery, business continuity, data back-up, archival, and retrieval capabilities with well-documented plans and annual tests. Guide impacts: Sections 1402.4 and 1402.5

ADDITIONAL GUIDE UPDATES AND REMINDERS

Post-Fund Data Correction tool Effective July 1, 2020

Form 907, Post-Fund Data Correction Tool Authorized User Role Form In Bulletin 2019-25, Freddie Mac announced broad availability of the Post-Fund Data Correction tool (the “Tool”) to Freddie Mac Sellers. The Tool, a web-based application that allows a Seller/Servicer to electronically submit data

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correction requests related to Mortgage data submitted by a Seller into Loan Selling Advisor®, is available in Servicing Gateway, which launched December 9, 2019. In Bulletin 2019-25, we announced that Seller/Servicers not using Access Manager may request access to the Tool by completing and submitting Form 907, Post-Fund Data Correction Tool Authorized User Role Form, available on the Post- Fund Data Correction Tool web page. Bulletin 2020-6 announced that we have converted this form to a web-based form, renamed it Post-Fund Data Correction Tool Access Request Form, and updated it so that Seller/Servicers may request Tool access online. We also removed “Form 907” from the title because this form is available only on the PFDC Tool web page and not in the Guide.

Transition period As a reminder, Seller/Servicers must submit data corrections electronically using the Tool beginning July 1, 2020. Prior to that date, Seller/Servicers may continue to submit corrections using the Post-Fund Data Correction Form Excel spreadsheet (the DCR Form) on the Post-Fund Data Correction Tool web page.

Training For more information regarding Servicing Gateway, refer to Bulletins 2019-19, 2019-21 and 2019-23. For detailed training, view the Post-Fund Data Correction Tool Overview tutorial, which provides a detailed look at the Tool. Topics include login and navigation, searching for existing loan and post-fund data correction records, and importing and submitting data correction requests.

Form 475, Warehouse Lending Agreement to Access Loan Selling Advisor In Bulletin 2018-19, we announced the combination of Form 475 with Form 990SF, Agreement and Certificate of Incumbency: Warehouse Lender. With this Bulletin, we are updating Section 6305.12 to remove the reference to Form 475, since this form is no longer used. Guide impact: Section 6305.12

Form 1055, Mortgage Bankers’ Financial Reporting Form, attestation Effective September 30, 2020 Freddie Mac is requiring the CEO, CFO or an equivalent officer of non-bank Seller/Servicers that submit financial information through Form 1055, Mortgage Bankers’ Financial Reporting Form (MBFRF), to attest that the information submitted is true and accurate and that the unaudited financial statements are prepared in accordance with generally accepted accounting principles. The officer will make this attestation through the MBFRF platform by checking a box. Failure to make this attestation may impact Seller/Servicers’ eligibility to conduct business with Freddie Mac. Guide impact: Section 2101.5

Guide updates from previous Bulletins We are updating the Guide to reflect previously announced changes as follows:

ACE expansion Effective March 23, 2020 As announced in Bulletin 2020-5, we have expanded our automated collateral evaluation (ACE) eligibility to include certain cash-out and “no cash-out” refinances. With this Bulletin, we are updating the Guide to reflect these changes. Guide impact: Section 5601.9

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Remote Online Notarization Effective March 31, 2020

In Bulletin 2020-8, we announced that Electronic notarization may involve a remote process (“Remote Online Notarization”) in the States listed in Attachment C to Bulletin 2020-8, Permitted States for Remote Online Notarization, provided that the system used for the remote notarization meets the minimum standards provided in the Bulletin. As a follow-up, in Bulletin 2020-11, we announced the addition of Arkansas, Georgia and Hawaii to our list of permitted States for Remote Online Notarization (provided in Attachment C to Bulletin 2020-8) and provided some clarifications about the transactions in which the Seller wishes to include the seller of the Mortgaged Premises in the Electronic Closing process. We are now updating Sections 1401.2 and 1401.16 to reflect the guidance issued through Bulletins 2020-8 and 2020-11. Also, as part of this update, we are removing Section 1401.23, as the requirements contained in this section are now made part of Section 1401.16, and replacing the “Remote Online Electronic Notarization” reference in Section 6302.5 with “Remote Online Notarization.” Finally, we have added the list of permitted States for Remote Online Notarization to the Guide as Exhibit 48. Guide impacts: Sections 1401.2, 1401.16, 1401.23, 1402.2, 1402.8, 6302.5, Exhibits 34 and 48

Mandatory fixed-rate cash contracts and WAC ARM cash contracts Effective April 14, 2020 As announced in Bulletin 2020-11, we have updated the requirements applicable to offer amounts for the following: • Fixed-rate mandatory cash contracts as stated in Section 6101.3(a) • WAC ARM mandatory cash contracts as stated in Section 6102.4(a) With this Bulletin, we are updating the Guide to reflect these changes. Guide impacts: Sections 6101.3 and 6102.4

GUIDE UPDATES SPREADSHEET For a detailed list of the Guide updates associated with this Bulletin and the topics with which they correspond, access the Bulletin 2020-13 (Selling) Guide Updates Spreadsheet via the Download drop-down available at https://guide.freddiemac.com/app/guide/bulletin/2020-13.

Danny Gardner Senior Vice President, Client and Community Engagement

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TO: Freddie Mac Sellers May 5, 2020 | 2020-14

SUBJECT: SELLING REQUIREMENTS AND GUIDANCE RELATED TO COVID-19 We continue to work closely with Fannie Mae under the guidance and direction of the FHFA to address the ongoing economic implications and uncertainty related to the coronavirus disease (COVID-19) pandemic and its impacts on Borrowers and the Mortgage origination process. This Bulletin provides: • Temporary requirements related to: ➢ Mortgage purchase eligibility ➢ Self-reporting requirements for Mortgages in COVID-19 related forbearance • Extension of certain previously announced temporary requirements Additionally, we’re providing guidance and reminders, including those related to: • Furloughs and layoffs • Unemployment compensation • Automated income assessment with Loan Product Advisor® using tax return data We are also reminding Sellers of additional resources, including our Selling FAQs related to COVID-19, which we are updating with this Bulletin.

Note Date references All references to the Note Date refer to the modification date for Seller-Owned Modified Mortgages, the Conversion Date for Seller-Owned Converted Mortgages, the Effective Date of Permanent Financing for Construction Conversion and Renovation Mortgages, or the assumption agreement date.

TEMPORARY CHANGES

Mortgage purchase eligibility The temporary requirements below are effective immediately and will remain in place until further notice. We are temporarily revising our Mortgage eligibility requirements to limit our purchase of Mortgages to those with Settlement Dates no more than six months after the Note Date or, for Construction Conversion and Renovation Mortgages, the Effective Date of Permanent Financing. Additionally, we are temporarily suspending Mortgage purchases through our bulk sales unit.

Self-reporting requirements for Mortgages in forbearance In Bulletin 2020-12, Freddie Mac announced certain requirements for the purchase of Mortgages in COVID-19 related forbearance. If a Seller discovers that it has sold to Freddie Mac a “Mortgage in forbearance” as defined in Bulletin 2020-12 prior to its eligibility for purchase or has delivered such Mortgage without the required ULDD Data Point, Investor Feature Identifier (Sort ID 368) of “J76” or “J77,” the Seller must report such finding to Freddie Mac within 30 days of discovery through either the Post-Fund Data Correction process or the quality control processes set forth in Section 3402.10 or Quality Control Advisor®.

EXTENSION OF TEMPORARY CHANGES FROM PREVIOUS BULLETINS We are extending the temporary requirements and flexibilities that were effective for Mortgages with Application Received Dates through May 17, 2020 to Mortgages with Application Received Dates through June 30, 2020 for the following: • Credit underwriting requirements announced in Bulletins 2020-5 and 2020-8 • Appraisal and GreenCHOICE Mortgage® flexibilities announced in Bulletins 2020-5, 2020-8 and 2020-11 • Condominium Project flexibilities announced in Bulletin 2020-11 • Power of attorney flexibilities announced in Bulletin 2020-8

GUIDANCE AND REMINDERS

Furloughs and layoffs Freddie Mac provides requirements for income while on temporary leave in Section 5303.5. These requirements do not extend to employer-initiated actions such as furloughs and layoffs, regardless of whether there is a projected “return to work” date.

Unemployment compensation While we recognize that many individuals have become eligible for assistance and compensation available through the Unemployment Insurance Provisions provided in the Coronavirus Aid, Relief and Economic Security Act (“CARES Act”), the assistance and compensation are temporary in nature and therefore do not represent a stable or continuous source of income. As such, unemployment compensation continues to be eligible for use in qualifying only when it is associated with seasonal employment and all other requirements in Section 5303.3 are met.

Automated income assessment with Loan Product Advisor® using tax return data To align with the IRS federal tax filing extension, we are revising our requirements applicable to automated income assessment with Loan Product Advisor® using tax return data (i.e., AIM for self-employed). For Mortgages with Loan Product Advisor initial submission dates on or after August 1, 2020, the Borrower’s most recent tax returns filed with the IRS must be the 2019 tax return. This is an extension of the May 1, 2020 deadline.

Loan Product Advisor update to identify Freddie Mac-owned Mortgages As announced in Bulletin 2020-11, Loan Product Advisor has been enhanced to assist Sellers with identifying if a Mortgage being refinanced is owned by Freddie Mac, effective for submissions to Loan Product Advisor on and after April 27, 2020. This enhancement supports our COVID-19 related appraisal flexibilities for Freddie Mac owned “no cash- out” refinance Mortgages announced in Bulletin 2020-5. If a match is found based on property address and the Social Security number of one or more Borrowers on an existing loan, then informational feedback messages will be returned on both submissions and resubmissions indicating the Mortgage is Freddie Mac owned.

Mortgages in forbearance Credit Fees in Price As announced in the April 29, 2020 Single-Family News and Insights article, the applicable Mortgage in forbearance Credit Fee in Price will be assessed at settlement unless the contract acceptance date was prior to the publication of Bulletin 2020-12, in which case it will be assessed after funding.

GUIDE UPDATES We are not updating the Guide to reflect any of the changes noted in this Bulletin.

ADDITIONAL RESOURCES We encourage Sellers to review the following resources: • Freddie Mac Single-Family web page on COVID-19

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• Freddie Mac Selling FAQs related to COVID-19 • The Center for Disease Control’s web page on COVID-19 • The Appraisal Foundation’s Appraiser Qualifications and Standards Q&As • The Appraisal Institute’s Coronavirus-related Direction for Appraisers • National Association of Realtors Coronavirus Guide for Realtors

Danny Gardner Senior Vice President, Client and Community Engagement

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TO: Freddie Mac Servicers May 13, 2020 | 2020-15

SUBJECT: FREDDIE MAC COVID-19 PAYMENT DEFERRAL With Bulletin 2020-6, Freddie Mac announced the Payment Deferral, a loss mitigation solution for Borrowers who became delinquent due to a short-term hardship that has since been resolved. As we continue to monitor and respond to the COVID-19 pandemic, and in response to Servicer feedback, we are announcing the Freddie Mac COVID-19 Payment Deferral. The COVID-19 Payment Deferral leverages a similar concept to the recently announced Payment Deferral solution. Under the terms of a COVID-19 Payment Deferral an eligible Borrower will be brought current by deferring delinquent amounts to create a non-interest bearing balance that will become due at the earlier of the Mortgage maturity date, payoff date, or upon transfer or sale of the Mortgaged Premises. The remaining Mortgage term, interest rate schedule (i.e., whether a fixed-rate Mortgage, an ARM or Step-Rate Mortgage) and maturity date of the Mortgage will all remain unchanged.

KEY DIFFERENCES FROM A STANDARD PAYMENT DEFERRAL We have made several adjustments to the requirements of the standard Payment Deferral to create the COVID-19 Payment Deferral, which is designed specifically to assist Borrowers who have a COVID-19 related hardship. All relevant requirements are described in detail in this Bulletin. However, there are several key differences between the previously announced solution and the COVID-19 Payment Deferral, including: • The Borrower’s Delinquency must have been the result of a COVID-19 related hardship, as described in Bulletin 2020-4, and that hardship must be resolved • The Borrower must have been current or less than 31 days delinquent as of the effective date of the National Emergency declaration date, March 1, 2020 • The Mortgage may be up to 12 months delinquent as of the evaluation date • The Borrower is not required to make consecutive payments immediately prior to executing a COVID-19 Payment Deferral (i.e., there is no rolling delinquency requirement) • The Servicer must defer all delinquent principal and interest payments (P&I), but for a COVID-19 Payment Deferral must also defer any other amounts that are permitted to be capitalized as part of a Freddie Mac Flex Modification®, and as described in Guide Section 9206.15 • Certain eligibility restrictions of the Payment Deferral are not applicable to the COVID-19 Payment Deferral (e.g., there is no origination seasoning requirement or any restrictions regarding a previous non-COVID-19 Payment Deferral or a recently failed Flex Modification or Flex Modification Trial Period Plan) • Under certain circumstances, the Servicer must proactively send an eligible Borrower an offer for a COVID-19 Payment Deferral without first establishing quality right party contact (as described in the “Solicitation for a COVID-19 Payment Deferral” section below) Servicers must complete a COVID-19 Payment Deferral in accordance with all requirements described in the below sections of this Bulletin.

EFFECTIVE DATE Servicers must begin evaluating eligible Borrowers for a COVID-19 Payment Deferral on and after July 1, 2020.

FREDDIE MAC COVID-19 PAYMENT DEFERRAL Eligibility requirements and exclusions To be eligible for the COVID-19 Payment Deferral, all of the following requirements must be met:

COVID-19 Payment Deferral eligibility requirements and exclusions Borrower eligibility The Servicer must achieve quality right party contact in accordance with the requirements specified in Bulletin 2020-10 (“Limited QRPC”). In addition to the information required to achieve Limited QRPC, the Servicer must confirm that the Borrower: • Has a resolved COVID-19 hardship • Is capable of continuing to make the existing contractual monthly Mortgage payment • Is unable to afford a repayment plan or full reinstatement of the Mortgage If the Borrower’s Mortgage was previously modified under the Home Affordable Modification ProgramSM (HAMP®) and the Borrower is in “good standing” when they entered into a COVID-19 forbearance plan and the Borrower transitions directly to a COVID-19 Payment Deferral, then the Borrower will not lose good standing as a result of the forbearance plan or as a result of a COVID-19 Payment Deferral. Delinquency/Payment requirements The Mortgage must: • Have been current or less than 31 days delinquent as of March 1, 2020, the effective date of the National Emergency declaration related to COVID-19, and • Be 31 or more days delinquent but less than or equal to 360 days delinquent as of the date of evaluation Note: If a Borrower had a COVID-19 related hardship but was 31 or more days delinquent as of the effective date of the National Emergency declaration (March 1, 2020), and the Servicer determines the Borrower can maintain the existing monthly contractual payment, the Servicer must transmit an exception request via Workout Prospector® to Freddie Mac. Mortgage/property The Mortgage: eligibility • Must be a conventional First Lien Mortgage currently owned or guaranteed by Freddie Mac; and • May be a fixed-rate Mortgage, an ARM or a step-rate Mortgage The property may be a Primary Residence, second home or Investment Property and may be vacant or condemned. Mortgages subject to indemnification agreements If the Mortgage is subject to an indemnification agreement and is otherwise eligible under the COVID-19 Payment Deferral requirements of this Bulletin, the Servicer has the discretion to approve the COVID-19 Payment Deferral provided the following conditions are met: • The Mortgage receiving the COVID-19 Payment Deferral retains its credit enhancement • If the Servicer is not the credit enhancement provider, the Servicer must first obtain in writing any required approval under the terms of the credit enhancement from the entity providing the enhancement to enter into a COVID-19 Payment Deferral that complies with the requirements of this Bulletin • The Servicer remits to Freddie Mac an annual payment for the amount of COVID- 19 Payment Deferral related costs (e.g., interest rate shortfall). The loss amount calculation for the COVID-19 Payment Deferral will be determined in the same

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manner as the Modification Loss Amounts as described in Bulletins 2016-5 and 2017-1. Note: The Servicer is not eligible to receive an incentive for completing a COVID-19 Payment Deferral on a Mortgage that is subject to an indemnification agreement. Mortgage insurance If the Mortgage is subject to mortgage insurance, and the mortgage insurance company is not included on our list of delegated mortgage insurance companies for Mortgage modifications, the Servicer must obtain delegation of authority from the MI or seek approval from the MI to complete the COVID-19 Payment Deferral. Texas Equity Section 50(a)(6) Mortgages If the Borrower is eligible and qualifies for the COVID-19 Payment Deferral, the Servicer must offer the COVID-19 Payment Deferral to the Borrower. If the Servicer receives Borrower notification classifying the COVID-19 Payment Deferral as a modification and claiming that the terms of the modification agreement do not comply with the provisions of Article XVI Section 50(a)(6) of the Texas Constitution, the Servicer must notify Freddie Mac within seven Business Days of receipt of such objection or complaint to Freddie Mac at [email protected] and include the following: • Freddie Mac loan number • Servicer loan number • Transaction type (e.g., Texas Home Equity modification) • Accounting Cycle in which Freddie Mac settled the workout • Servicer’s analysis (e.g., a Borrower complaint received related to a provision) Upon receipt of Freddie Mac’s instructions, the Servicer must comply with any required response time frames to claims of defects and any other complaint in accordance with Section 8104.1 and the Texas Constitution. Borrower documentation The Servicer must not require a complete Borrower Response Package (BRP) to evaluate the Borrower for a COVID-19 Payment Deferral if the Borrower has been evaluated in accordance with all requirements described in this Bulletin and the eligibility criteria are satisfied. Eligibility exclusions The following Mortgages and Borrowers are ineligible for the COVID-19 Payment Deferral: • FHA, VA and Guaranteed Rural Housing Mortgages • Mortgages subject to recourse • The Mortgage was subject to a previous COVID-19 Payment Deferral • Mortgages that are subject to an approved short sale or deed-in-lieu of foreclosure transaction • The Mortgage is currently subject to an unexpired offer to the Borrower for a mortgage modification or other alternative to foreclosure • Borrowers who are currently performing under a modification Trial Period Plan, a non-COVID-19 forbearance plan or repayment plan

Determining the terms of the COVID-19 Payment Deferral The steps to determine the terms of the COVID-19 Payment Deferral are described in the table below:

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Determining COVID-19 Payment Deferral Terms Delinquent Payment The Servicer must follow the steps below when determining the terms of the Deferral COVID-19 Payment Deferral. If the existing Mortgage includes a non-interest bearing UPB as a result of a prior modification, the terms impacting that non-interest bearing UPB will remain unchanged. The Servicer must apply the COVID-19 Payment Deferral forbearance as follows: • Defer the delinquent P&I and any other expenses or amounts due that are permitted to be capitalized under Flex Modification capitalization rules (described in Section 9206.15(b)), into an existing or newly created non-interest-bearing UPB (Deferred UPB). The aggregate Deferred UPB will become due on the earlier of: ➢ The Mortgage maturity date ➢ The Mortgage payoff date (e.g., refinance or payoff of the interest-bearing UPB); or ➢ Upon transfer or sale of the Mortgaged Premises The Servicer must: • Advance the DDLPI to bring the Mortgage to current status • Ensure that the remaining payment schedule associated with the interest-bearing UPB remains unchanged from the Mortgage’s pre-COVID-19 Payment Deferral payment schedule • Waive all accrued and unpaid late charges upon completion of the COVID-19 Payment Deferral When offering the COVID-19 Payment Deferral, the Servicer must ensure all other terms of the existing Mortgage remain unchanged including, but not limited to, the: • Remaining amortization schedule • Monthly P&I portion of the existing contractual monthly Mortgage payment • Interest rate (this includes maintaining the existing rate adjustment schedule for an ARM or a Step-Rate Mortgage); and • Maturity date NOTE: The maximum number of monthly payments that may be deferred as part of a COVID-19 Payment Deferral is twelve. Escrow Escrow analysis The Servicer is not required to perform an Escrow analysis in conjunction with a COVID-19 Payment Deferral and may continue to perform the Escrow analysis as regularly scheduled. If the Servicer chooses to perform an Escrow analysis, any Escrow account shortage that is identified at the time of the COVID-19 Payment Deferral must not be capitalized and the Servicer is not required to fund any existing Escrow account shortage. Any Escrow advances must be included in the deferred balance, as described in the “Delinquent COVID-19 Payment Deferral” section, above. In addition, the Servicer is not required to revoke any Escrow account waiver.

Completing a COVID-19 Payment Deferral The Servicer must send a COVID-19 Payment Deferral Agreement provided as Attachment A to this Bulletin, or the Servicer’s customized equivalent of the COVID-19 Payment Deferral Agreement, to the Borrower no later than five days after completion (e.g., a closed /settled workout option) of the COVID-19 Payment Deferral. In the event the Servicer elects to require the Borrower to sign and return the COVID-19 Payment Deferral Agreement, it must receive the fully executed COVID-19 Payment Deferral Agreement prior to the settlement date. The use of Attachment A to this Bulletin is optional; however, it reflects the minimum level of information that the Servicer must communicate. The Servicer must ensure the COVID-19 Payment Deferral Agreement complies with applicable law.

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The Servicer must complete the COVID-19 Payment Deferral in the same month it determines the Borrower is eligible. If the Servicer is unable to complete the COVID-19 Payment Deferral within this timeframe, the Servicer may, at its option, use an additional month to allow for sufficient processing time (“processing month”) to complete the COVID-19 Payment Deferral. The Servicer must treat all Borrowers equally in applying the processing month, as evidenced by a written policy (i.e., the criteria for when a processing month is required must be the same for all Borrowers). Additionally, the Servicer is not permitted to defer more than twelve months of payments as part of a Payment Deferral, so if a processing month is used for a borrower who is already twelve months delinquent, the Servicer must require a payment during the processing month. Otherwise, the Borrower is not required to submit a payment during the processing month for a COVID-19 Payment Deferral. The Servicer must process a COVID-19 Payment Deferral Agreement in compliance with the requirements for processing a regular Payment Deferral Agreement, as described in Section 9203.23. This includes the requirements for recordation, title endorsement and Document Custodian. The table below provides some of the key criteria:

COVID-19 Payment Deferral Agreement COVID-19 Payment Deferral Recordation conditions The Servicer must ensure that the Mortgage subject to the COVID-19 Payment Deferral retains its First Lien position and continues to be fully enforceable in accordance with its terms at the time of completion of the COVID-19 Payment Deferral, throughout the term of the Mortgage, and during any bankruptcy or foreclosure proceeding involving the Mortgage. The Servicer must record the COVID-19 Payment Deferral Agreement only when doing so is necessary to ensure its compliance with this First Lien retention and the COVID-19 Payment Deferral enforcement requirement. Title endorsement • The Servicer is responsible for ensuring that the Mortgage subject to the COVID- 19 Payment Deferral complies with applicable law, retains Freddie Mac’s First Lien position, and is enforceable against the Borrower(s) in accordance with its terms • The Servicer must obtain a title endorsement or similar title insurance product issued by a title insurance company if the COVID-19 Payment Deferral Agreement will be recorded Document Custodian • If the COVID-19 Payment Deferral Agreement is not required to be signed by the Borrower, the Servicer must send a copy of the Servicer-executed COVID-19 Payment Deferral Agreement to the Document Custodian within 25 days of the effective date of the COVID-19 Payment Deferral • If the COVID-19 Payment Deferral Agreement must be recorded, the Servicer must: ➢ Send a certified copy of the fully executed COVID-19 Payment Deferral Agreement to the Document Custodian within 25 days of the effective date of the COVID-19 Payment Deferral; and ➢ Send the original COVID-19 Payment Deferral Agreement when returned from the recorder’s office to the Document Custodian within five Business Days of receipt • If the COVID-19 Payment Deferral Agreement must be signed by the Borrower but not recorded, the Servicer must send the fully executed original COVID-19 Payment Deferral Agreement to the Document Custodian within 25 days of the effective date of the COVID-19 Payment Deferral

Evaluation hierarchy To be eligible for a COVID-19 Payment Deferral, a Borrower must have been current or less than 31 days delinquent as of the effective date of the National Emergency declaration (March 1, 2020). Otherwise, the Servicer must conduct all loss mitigation evaluations in accordance with our standard loss mitigation evaluation hierarchy, as described in Section 9201.2 (or must submit an exception request for Freddie Mac approval, as described above).

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If Limited QRPC is established with a COVID-19 impacted Borrower who was current or less than 31 days delinquent (i.e., the Borrower had not missed more than one monthly payment) as of the effective date of the National Emergency declaration, and the Borrower is unable to resolve the Delinquency through a reinstatement or repayment plan, the Servicer must evaluate the Borrower for the loss mitigation options set forth in the following COVID-19 evaluation hierarchy: 1. COVID-19 Payment Deferral 2. Flex Modification (in accordance with the requirements described in Bulletin 2020-7, if applicable) 3. Standard Short Sale 4. Standard Deed-in-Lieu of Foreclosure NOTE: In most cases, Borrowers with a COVID-19 related hardship who qualify to be evaluated for a COVID-19 Payment Deferral (as described in this section) will be transitioning from a COVID-19 forbearance, but forbearance is not a prerequisite in order to be eligible. Extend Modification and Capitalization and Extend Modification Upon the mandatory effective date of the COVID-19 Payment Deferral on July 1, 2020, we are revising the guidance we provided in Bulletin 2020-4 by eliminating the Extend Modification and the Capitalization and Extend Modification as options in the COVID-19 evaluation hierarchy and replacing those options with the COVID-19 Payment Deferral, as shown in the hierarchy described above. Prior to the July 1 effective date, Servicers must continue to evaluate Borrowers based on the existing guidance from Bulletin 2020-4, which includes the Extend Modification and Cap and Extend Modification. Solicitation for a COVID-19 Payment Deferral The Servicer must proactively solicit the Borrower to offer a COVID-19 Payment Deferral within 15 days after the expiration of the forbearance plan if: • The Servicer is not able to establish Limited QRPC during the COVID-19 related forbearance plan, and • The Mortgage was current or less than 31 days delinquent as of the effective date of the National Emergency declaration (March 1, 2020), and • The Mortgage does not meet any of the criteria described in the “Eligibility Exclusions” section of this Bulletin We have provided a solicitation letter template as Attachment B to this Bulletin that the Servicer may use at its discretion, but the solicitation letter must, at a minimum, provide the details of the COVID-19 Payment Deferral and instructions on how to accept the offer. The Borrower may accept the COVID-19 Payment Deferral offer via: • Contacting the Servicer directly in accordance with any acceptable outreach and communication method as described in Bulletin 2020-7, or • Returning an executed COVID-19 Payment Deferral Agreement, if applicable, or • Any other method evidencing the Borrower’s acceptance, in compliance with applicable law (e.g., making the monthly payment due under the terms of the COVID-19 Payment Deferral offer*) The solicitation letter must also include language that additional forbearance options are available, as applicable, if the Borrower’s hardship is ongoing, or a Flex Modification may be available if the Borrower needs payment relief. *If permitting payment to constitute acceptance of the COVID-19 Payment Deferral offer, the Servicer must require the Borrower’s payment to be submitted so that it is received by the Servicer in the same month as the Payment Deferral offer is sent. This requirement must be described in the Solicitation Letter, if applicable. Solicitation for a Flex Modification If the Borrower is ineligible for a solicitation for a COVID-19 Payment Deferral, as described above, then the Servicer must evaluate the Borrower for a streamlined offer for a Flex Modification (provided that as of the evaluation date the Borrower is at least 90 days delinquent or is at least 60 days delinquent and has a Step-Rate Mortgage). Flex Modifications for Borrowers with a COVID-19 related hardship who were current or less than 31 days delinquent as of March 1, 2020 must be completed in accordance with the streamlined Flex Modification evaluations described in the section below, under “Reduced Flex Mod Requirements.” Otherwise, the Servicer must evaluate in accordance with our standard requirements in Section 9206.5. The Servicer must send a streamlined offer for a Flex Modification to an eligible Borrower within 15 days after the expiration of the forbearance plan.

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If the Borrower was eligible for a solicitation for a COVID-19 Payment Deferral, but did not accept the offer, then the Servicer must evaluate the Borrower for a streamlined offer for a Flex Modification following the same requirements as described in the above paragraph, except that the Servicer must send the streamlined offer to an eligible Borrower within 15 days of the expiration of the COVID-19 Payment Deferral offer. Flex Modification evaluations for failed COVID-19 Payment Deferral If the Borrower accepts a COVID-19 Payment Deferral and subsequently becomes 60 days delinquent within six months of the effective date, then the Servicer must evaluate the Borrower for a Flex Modification based on the special eligibility criteria described below, and the Servicer is not required to first establish quality right party contact or collect a complete Borrower Response Package. A Flex Modification offer must be sent to an eligible Borrower under these requirements no later than the 75th day of Delinquency.

Reduced Flex Modification requirements In lieu of the regular Guide requirements for Flex Modification eligibility as described in Sections 9206.5 and 9206.6, the Servicer will exclude only the following Mortgages from eligibility in these instances: • The Mortgage is an FHA, VA or Guaranteed Rural Housing Mortgage • The Mortgage is subject to recourse • The Mortgage is currently performing under another forbearance plan, Trial Period Plan or repayment plan • The Mortgage is subject to an approved short sale or deed-in-lieu of foreclosure • The Mortgage is currently subject to an unexpired offer to the Borrower for another modification or other foreclosure prevention alternative, such as a forbearance plan or repayment plan If the Servicer was not collecting Escrows on the existing Mortgage, the Borrower is not required to establish an Escrow account as a condition of the modification unless otherwise required by applicable law, or the Servicer confirms that the taxes and insurance premiums have not been paid and are past due. Workout Prospector® Workout Prospector® is being updated to accommodate the submission and settlement of COVID-19 Payment Deferrals. Although Servicers must begin their evaluations on and after July 1, 2020, the Payment Deferral path described below will not be available until July 13, 2020. Therefore, settlements using Workout Prospector should be withheld until July 13, 2020, even when the evaluation may have been conducted on or after July 1, but before July 13. To model the terms of the COVID-19 Payment Deferral and complete the settlement process, Servicers must use the “Payment Deferral” path in Workout Prospector. Servicers must comply with the requirements in Section 9203.24 and the instructions provided in the Workout Prospector Users’ Guide to complete the submission and settlement process for a COVID-19 Payment Deferral. Servicers may use a proprietary system or third-party system to generate the terms of the COVID-19 Payment Deferral; however, this data also must be entered in its entirety into Workout Prospector. The Servicer must ensure that its results comply with the requirements in Sections 9203.18 through 9203.25 and are the same as the data entered into Workout Prospector prior to sending the COVID-19 Payment Deferral Agreement to the Borrower. Reporting requirements In most cases, the COVID-19 Payment Deferral does not have an associated unique EDR status code. For each Mortgage subject to the COVID-19 Payment Deferral, the Servicer must continue reporting the appropriate delinquency status information to Freddie Mac through EDR in accordance with requirements in Section 9102.7 and Guide Exhibit 88, Servicing Tools. Once the COVID-19 Payment Deferral has been completed and the Mortgage is brought current, the EDR status code must reflect the Mortgage as current. However, the Servicer must report Event Code H6, Payment Deferral Offer, to notify Freddie Mac that the Mortgage is subject to an active COVID-19 Payment Deferral offer in the following instances: • The forbearance period ends prior to settlement of an accepted COVID-19 Payment Deferral (e.g. if the Servicer elected to use a processing month and the forbearance plan expires), or • The Servicer has made a proactive offer following the expiration of a forbearance plan in accordance with the “Solicitation for a COVID-19 Payment Deferral” section above

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In these instances, the Servicer must continue to report Event Code H6 until the offer has expired, or the Payment Deferral has been completed. Other requirements Other requirements for the COVID-19 Payment Deferral include: • Reimbursement of expenses: Servicers may use the Reimbursement System to request reimbursement for the following fees associated with the COVID-19 Payment Deferral in accordance with Section 9203.25: ➢ Recordation fees ➢ Title costs ➢ Notary fees • Credit reporting: For each Mortgage that receives the COVID-19 Payment Deferral, the Servicer must provide a “full file” status report describing the status of the Mortgage to each of the four major credit repositories in accordance with the credit bureau standards as provided by the Consumer Data Industry Association, and subject to applicable law (e.g. the Coronavirus Aid, Relief and Economic Security Act (“CARES Act”) and the Fair Credit Reporting Act). • Incentive payment: Servicer incentive for the COVID-19 Payment Deferral will be announced at a later date. • Servicing fee: There are no adjustments being made to the servicing fee, referred to as the Servicing Spread. The Servicer will continue to receive the Servicing Spread it was receiving prior to completing a COVID-19 Payment Deferral. • Future Flex Modification evaluations: If the Servicer is evaluating a Borrower for a future Flex Modification, the COVID-19 Payment Deferral will not count as a previous loan modification for purposes of calculating the number of times the Mortgage has previously been modified. • Future Payment Deferral evaluations: If the Servicer is evaluating a Borrower for a future (non-COVID-19) Payment Deferral in accordance with Bulletin 2020-6, the COVID-19 Payment Deferral will not cause the Borrower to be ineligible. • No Trial Period Plan: The COVID-19 Payment Deferral does not include a Trial Period Plan. The Borrower does not need to complete a Trial Period Plan prior to entering into a COVID-19 Payment Deferral. • Reimbursement of advanced interest, taxes and insurance: The interest the Servicer advances during the Delinquency, along with any advances for escrow, taxes or insurance, will be reimbursed to the Servicer upon settlement of the COVID-19 Payment Deferral.

ADDITIONAL RESOURCES We encourage Servicers to review the following COVID-19 resources: • Freddie Mac Single-Family web page on COVID-19 resources • Freddie Mac Servicing FAQs on COVID-19 • Joint guidance and FAQs for Servicers during the COVID-19 crisis issued by federal and State regulators, including the Consumer Financial Protection Bureau

GUIDE UPDATES The Guide will not be updated at this time to reflect these changes.

Bill Maguire Vice President, Servicing Portfolio Management

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TO: Freddie Mac Servicers May 14, 2020 | 2020-16

SUBJECT: TEMPORARY SERVICING GUIDANCE RELATED TO COVID-19 Bulletins 2020-4, 2020-7 and 2020-10 provided temporary Servicer guidance in response to the National Emergency Declaration resulting from the outbreak and spread of COVID-19. As we continue to monitor and assess the situation, and in response to Servicer questions, with this Bulletin we are providing additional clarity on the following items: • Extension to the COVID-19 foreclosure moratorium • Property inspections for delinquent Mortgages • EDR reminder – reporting Mortgages impacted by COVID-19 • Property valuations for short sales and deeds-in-lieu of foreclosure • HAMP good standing for Mortgages on a COVID-19 forbearance plan, repayment plan, or COVID-19 Payment Deferral • National Emergency Declaration effective date

EFFECTIVE DATE All of the changes announced in this Bulletin are effective immediately unless otherwise noted.

EXTENSION TO THE COVID-19 FORECLOSURE MORATORIUM We are extending the foreclosure moratorium announced in Bulletins 2020-4 and 2020-10. Servicers must suspend all foreclosure actions, including foreclosure sales, through June 30, 2020. This includes initiation of any judicial or non- judicial foreclosure process, move for foreclosure judgment or order of sale. This foreclosure suspension does not apply to Mortgages on properties that have been determined to be vacant or abandoned.

PROPERTY INSPECTIONS FOR DELINQUENT MORTGAGES In Bulletin 2020-7, we announced that Freddie Mac was temporarily relieving Servicers from their responsibility to complete property inspections for delinquent Mortgages as described in Section 9202.12 as a result of the COVID-19 pandemic. With this Bulletin we are expanding upon our previous announcement. Effective immediately, Servicers must not complete property inspections on a Mortgaged Premises where the Borrower is experiencing a hardship related to COVID-19 unless as of the effective date of the National Emergency declaration effective date (March 1, 2020): • The Mortgage was delinquent, and • The property was confirmed to be vacant or abandoned. For a Mortgaged Premises where the Mortgage was delinquent and the property was confirmed to be vacant or abandoned, the Servicer must complete delinquent property inspections in accordance with Bulletin 2020-7.

EDR REMINDER – REPORTING MORTGAGES IMPACTED BY COVID-19 As a reminder, Servicers must notify Freddie Mac when a Borrower has a COVID-19 related hardship, in accordance with our requirements as described in Bulletin 2020-4, by reporting default reason code 032. Additionally, if a Mortgage is subject to a COVID-19 related hardship and is on an active forbearance plan, required reporting (in compliance with our

Electronic Default Reporting requirements) must include both default reason code 032 and default action code 09, forbearance.

PROPERTY VALUATIONS FOR SHORT SALES AND DEEDS-IN-LIEU OF FORECLOSURE When obtaining a property valuation as part of a short sale or deed-in-lieu of foreclosure, Freddie Mac requires the Servicer to use an interior property valuation that Freddie Mac provides, as described in Sections 9208.5(a) and 9209.5(a). Due to the COVID-19 pandemic, we are temporarily using external valuations in some cases. In these instances, Servicers must use the valuation we provide, even if it is not an internal valuation.

HAMP GOOD STANDING FOR MORTGAGES ON A COVID-19 FORBEARANCE PLAN AND TRANSITION TO A REPAYMENT PLAN OR A COVID-19 PAYMENT DEFERRAL If the Borrower’s Mortgage was previously modified under the Home Affordable Modification ProgramSM (HAMP®) and the Borrower is in “good standing” when they entered into a COVID-19 forbearance plan, then the Borrower will not lose good standing while on the active forbearance plan, even if the Borrower becomes more than 90 days delinquent. Additionally, the Borrower will not lose “good standing” if they transition directly from a COVID-19 forbearance plan to: • A reinstatement, or • An active repayment plan, or • A settled COVID-19 Payment Deferral If the Borrower successfully transitions directly from a COVID-19 forbearance plan to a reinstatement, repayment plan or COVID-19 Payment Deferral, the Borrower will not lose good standing while the relief option is active or upon completing the relief option to become current. If the COVID-19 forbearance plan expires without transitioning directly to one of these solutions, or if the Borrower does not successfully reinstate the Mortgage as a result of one of these options, then the Borrower will lose “good standing.”

NATIONAL EMERGENCY DECLARATION EFFECTIVE DATE In Bulletins 2020-4 and 2020-7, we communicated the following requirement as relates to evaluations for Borrowers with a COVID-19 related hardship for the Extend Modification, the Capitalization and Extension Modification (Cap and Extend), and streamlined Flex Modification evaluations for Borrowers: • The Borrower must have been current or less than 31 days delinquent (i.e., must not have missed more than one monthly payment) as of the date of the National Emergency Declaration related to COVID-19, March 13, 2020 Effective immediately, we are revising this requirement to reflect the following: • The Borrower must have been current or less than 31 days delinquent (i.e., must not have missed more than one monthly payment) as of the date of the COVID-19 National Emergency Declaration effective date, March 1, 2020 This change also applies to Extend Modification and Cap and Extend Modification evaluations described in the “Borrower Contact Requirements and Loss Mitigation Hierarchy” section in Bulletin 2020-4, and to any other previous reference to the March 13 date. As a reminder, per Bulletin 2020-15 the Extend Modification and the Cap and Extend will be replaced in the COVID-19 evaluation hierarchy for all evaluations conducted on and after July 1, 2020.

GUIDE UPDATES The Guide will not be updated at this time to reflect these changes.

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Bill Maguire Vice President, Servicing Portfolio Management

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TO: Freddie Mac Sellers May 19, 2020 | 2020-17

We are reissuing Bulletin 2020-17 on May 22, 2020 to notify Sellers of a correction to the original publication. When the Bulletin was first published on 5/19/2020 at 1pm, the language in the last column of the “is subject to a repayment plan” row in the Eligibility Requirements table incorrectly included the language “being refinanced or any other Mortgage” at the end of the statement. This language was removed from the table in AllRegs as of 5/19/2020 at 4:42pm and has also been removed in this reissuance. In addition, we are updating the second column (Eligibility requirements) of that same row of the table, to add the word “consecutive” to more specifically describe the three payment requirement. No other changes have been made to the Bulletin.

SUBJECT: SELLING GUIDANCE RELATED TO COVID-19 We continue to work closely with Fannie Mae under the guidance of the FHFA to address the ongoing economic implications and uncertainty related to the coronavirus disease (COVID-19) pandemic and its impacts on Borrowers and the Mortgage origination process. This Bulletin provides: • Temporary purchase and refinance eligibility requirements for Borrowers with existing Mortgages • An update to representation and warranty framework requirements related to Mortgages subject to forbearance agreements • An extension of temporary requirements for purchase of Mortgages in forbearance We are also reminding Sellers of additional resources, including our Selling FAQs related to COVID-19, which we continue to update. Note Date references All references to the Note Date refer to the modification date for Seller-Owned Modified Mortgages, the Conversion Date for Seller-Owned Converted Mortgages, the Effective Date of Permanent Financing for Construction Conversion and Renovation Mortgages, or the assumption agreement date, as applicable.

TEMPORARY PURCHASE AND REFINANCE ELIGIBILITY REQUIREMENTS FOR BORROWERS WITH EXISTING MORTGAGES In an effort to support responsible lending and sustainable homeownership during this unprecedented COVID-19 pandemic, we are implementing the following temporary purchase and refinance requirements for Borrowers with existing Mortgages.

Effective date These temporary requirements are effective for Mortgages with Application Received Dates on and after June 2, 2020 and until further notice. Sellers are encouraged to implement these requirements to their loans in process.

Eligibility requirements In addition to meeting all other requirements of the Purchase Documents and regardless of the Loan Product Advisor® Risk Class, as of the Note Date of the new Mortgage, each existing Mortgage on which the Borrower is obligated that is secured by either the subject property or any other 1- to 4-unit residential property, must meet the requirements described in the following table:

If any existing Mortgage … Eligibility requirements Use of proceeds if the subject transaction is a “no cash-out” or cash out refinance Is current as of the Note Date (i.e., the No additional eligibility requirements As stated in Guide Sections Borrower made all Mortgage 4301.4 and 4301.5 payments due in the month prior to the Note Date no later than the last Business Day of that month) and not in a repayment plan, loan modification Trial Period Plan, Payment Deferral or subject to another loss mitigation program Is not current as of the Note Date (as The new Mortgage is ineligible unless N/A defined above) OR is in a repayment the amounts outstanding on any existing plan, loan modification Trial Period Mortgage are resolved by meeting the Plan or Payment Deferral applicable additional eligibility requirements below

Was fully reinstated on or after the Seller must document the source of Proceeds may not be used to Application Received Date but prior to funds used for reinstatement. The reinstate the Mortgage being the Note Date source of funds must be an eligible refinanced or any other Mortgage source as described in Section 5501.3.

Additional eligibility requirements Is subject to a repayment plan The Borrower must either: In connection with the Mortgage (i) Have successfully completed the being refinanced, proceeds may repayment plan, OR be used to pay off the remaining payments under the repayment (ii) Be performing under the plan (i.e., plan has not missed any payments due under the plan) and must have made at least three consecutive payments

Is subject to a Payment Deferral The Borrower must have made at least In connection with the Mortgage three consecutive timely payments being refinanced, proceeds may following the approval of the payment be used to pay off the deferred deferral agreement amount under the Payment Deferral Is subject to a modification Trial The Borrower must have successfully In connection with the Mortgage Period Plan completed the Trial Period Plan being refinanced, proceeds may be used to pay off the modified Mortgage Is subject to a loss mitigation program The Borrower must either: In connection with the Mortgage not mentioned above (i) Have successfully completed the being refinanced, proceeds may loss mitigation program, OR be used to pay off the remaining payments under the program

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If any existing Mortgage … Eligibility requirements Use of proceeds if the subject transaction is a “no cash-out” or cash out refinance (ii) Be performing under the program (i.e. has not missed any payments due under the program) and must have made at least three consecutive full monthly payments

Documentation requirements and guidance In addition to reviewing the Borrower’s credit report, Sellers must exercise additional due diligence to verify whether or not each Mortgage is current (as defined above), has been reinstated after the Application Received Dates, or is in a repayment plan, loan modification Trial Period Plan, Payment Deferral or is subject to another loss mitigation program, as well as whether the additional requirements in the table above are met, if applicable. The Seller must include any related documentation in the Mortgage file. Examples of ways the Seller may confirm compliance with the above requirements include: • Reviewing the payment history provided by the servicer(s) for each existing Mortgage • Reviewing the Borrower-provided Mortgage statements or electronic Mortgage history for each existing Mortgage • Using a third-party verification service to confirm Mortgage payment history • For Mortgages being refinanced, reviewing the pay-off statement

Evaluation of Mortgage payment history for Manually Underwritten Mortgages For Manually Underwritten Mortgages, Mortgage payments missed during COVID-19-related forbearance are not considered significant derogatory credit information for the purpose of compliance with requirements in Section 5202.5.

Enhanced Relief Refinance® Mortgages These temporary requirements do not apply to Enhanced Relief Refinance® Mortgages. All of the requirements in Guide Chapter 4304, including the payment history requirements applicable to the Mortgage being refinanced and the use of refinance proceeds, continue to apply.

Loan Product Advisor® and Guide updates Loan Product Advisor® feedback messages and the Guide will not be updated to reflect these temporary requirements.

REPRESENTATION AND WARRANTY FRAMEWORK RELIEF FOR MORTGAGES SUBJECT TO FORBEARANCE AGREEMENTS Effective immediately, we are updating our requirements such that a Mortgage that was subject to a forbearance agreement during the payment history period may be eligible for relief from enforcement of selling representations and warranties regardless of the forbearance agreement, provided the acceptable payment history requirements in Section 1301.11 are met. These Mortgages also continue to be eligible for relief based on a satisfactory conclusion of a Freddie Mac quality control review of the Mortgage file if the Mortgage otherwise meets the requirements in version 2 of the selling representation and warranty framework. Section 1301.11 will be updated with a future Bulletin to remove the requirement that in order to qualify for selling representation and warranty relief, a Mortgage must not have been subject to a forbearance agreement during the payment history period.

EXTENSION OF TEMPORARY REQUIREMENTS FOR PURCHASE OF MORTGAGES IN FORBEARANCE We are extending the temporary requirements for purchase of Mortgages in forbearance announced in Bulletin 2020-12. These requirements are now effective for Mortgages with Note Dates on or after February 1, 2020 and on or before

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June 30, 2020, and Settlement Dates on or after May 1, 2020 and on or before August 31, 2020. The chart below has been updated to reflect these changes.

Contract type Additional effective date requirements

Guarantor and MultiLender Contracts • Mortgages with Note Dates on or after February 1, 2020 and on or before March 31, 2020 must have Settlement Dates on or before May 31, 2020 Cash Contracts: Mortgages that are in forbearance, but not yet delinquent • Mortgages with Note Dates on or after April 1, 2020 and on or before June 30, 2020 must have Settlement Dates on or before August 31, 2020 (Revised)

CONCLUSION We appreciate the support that Sellers continue to extend to Borrower coping with hardships attributed to COVID-19. If you have any questions about the changes announced in this Bulletin, please contact your Freddie Mac representative or call the Customer Support Contact Center at 800-FREDDIE. Sincerely,

Danny Gardner Senior Vice President, Client and Community Engagement

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TO: Freddie Mac Sellers May 20, 2020 | 2020-18

SUBJECT: SELLING UPDATES This Guide Bulletin announces: ARM Cash Program • Updates to ARM Cash program – August 3, 2020 Cash window process for securities trading accounts • Changes to the process for establishing a securities trading account, including addition of the requirements to the Guide Third-party business continuity planning • Seller/Servicer minimum information security program requirements – October 1, 2020 Additional Guide updates • Further updates as described in the Additional Guide updates section of this Bulletin

EFFECTIVE DATE All of the changes announced in this Bulletin are effective immediately unless otherwise noted.

ARM CASH PROGRAM Effective for ARM Cash Contracts with contract expiration dates on or after August 3, 2020 We are enhancing Loan Selling Advisor to provide a streamlined, uniform pricing methodology that will enable Note Rate contract pricing for ARM Cash Contracts, consistent with fixed-rate pricing methodology. The pricing methodology will not rely on Weighted Average Coupon (WAC) pricing, weighted average Contract Level Tolerances or the assessment of Yield Maintenance Fees. Modifications include updating the ARM Cash Contract commitment process to remove weighted average terms and calculations. In addition, we are updating associated contract terms that are included in Guide Form 15, Loan Purchase Statement for ARM Cash. There are no changes to the underlying loan level information available in Form 15. As a result of these changes, as it relates to ARM Cash Contracts, we are updating the Guide to remove references to “WAC,” Contract Level Tolerance and Yield Maintenance Fees. For pipeline contracts with a contract expiration date on or after August 3, 2020, the contract will not rely on WAC pricing and will not be assessed a Yield Maintenance Fee. Capitalized terms used above that are not defined in the Glossary are defined in Section 6102.2. Guide impacts: Sections 1501.4, 4401.4, 4401.5, 6102.1 through 6102.9, 6302.1, 6302.2, 6302.7, 6302.40, 6303.1, 6303.2, 8302.18, Exhibit 17S, Form 15 and the Glossary

CASH WINDOW CUSTOMER AGREEMENT FOR SECURITIES TRADING ACCOUNT Freddie Mac provides market liquidity for mortgage securities by providing a trading relationship with approved Sellers. Our securities trading program allows Sellers to engage in the purchase and sale of Uniform Mortgage-Backed Securities and Freddie Mac Mortgage Participation Certificates. We are simplifying our process for establishing these securities trading relationships and adding the requirements to the Guide. As outlined in new Chapter 6103, Sellers may now establish a securities trading account with Freddie Mac by contacting the Cash Window trading desk at [email protected] or (571) 382-3080. All such securities transactions (including transactions executed under a previously executed Customer Agreement) will be subject to the terms and conditions of new Exhibit 102, Securities Trading Customer Agreement. Trading accounts approved by Freddie Mac are subject to margining and credit limits on the securities positions which the Seller may maintain with Freddie Mac. Freddie Mac may decline to initiate a new securities position with the Seller at any time. Guide impacts: Chapter 6103, Sections 6101.1, 6102.1 and Exhibit 102

Third-Party business continuity planning Effective October 1, 2020 Chapter 1302 requires that Seller/Servicers have and maintain an information security program and business continuity plan that ensures the Seller/Servicer's ongoing ability to conduct business operations with Freddie Mac. We are updating the Guide to make explicit that a Seller/Servicer's obligation to implement minimum information security program requirements includes requirements to reduce the impact and likelihood of unauthorized access to Freddie Mac proprietary information in the Seller/Servicers' files, records, storage facilities and systems of any Third-party provider (TPP) or other Related Third Party. Specifically, a Seller/Servicer must obligate each TPP and any other Related Third Party to comply with certain requirements to safeguard and maintain the security, confidentiality and availability of systems, data and information. Seller/Servicers have until October 1, 2020 to make sure that these minimum information security program requirements are met. Capitalized terms used above that are not defined in the Glossary are defined in Section 1401.2 or 2401.1. Guide impacts: Sections 1302.1, 1302.3 and 1401.2

ADDITIONAL GUIDE UPDATES

API clarification and restrictions on sharing Loan Advisor output We are clarifying that when we refer to an "interface," we also mean an application programming interface or "API" created and hosted by Freddie Mac to facilitate back-end access to our systems. We are also updating the Guide to more broadly state our restrictions on sharing System-generated Output. Unless authorized by Freddie Mac in writing, System Users may not distribute to, or otherwise share Output with, a party not licensed by Freddie Mac to access such Output, except when the Output relates to a consumer requesting the same. Capitalized terms used above that are not defined in the Glossary are defined in Section 2401.1. Guide impact: Section 2401.1

Updated ARM Notes and Riders – required implementation date and delivery requirements In Bulletin 2020-1, we announced updated uniform ARM Notes and riders revised to reflect the final fallback language recommended by the Alternative Reference Rates Committee (ARRC) for ARMs. We are reminding Sellers that they are required to use the updated uniform documents for all CMT- and LIBOR-indexed ARMs with Note Dates on or after June 1, 2020. We are also reminding Sellers that when delivering CMT- and LIBOR- indexed ARMs originated using the updated ARM Notes and riders (rev. 2/20), they must deliver the valid value "J23" for ULDD Data Point, Investor Feature Identifier (Sort ID 368). The updated Notes and riders are available on our Uniform Instruments web page.

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GUIDE UPDATES SPREADSHEET For a detailed list of the Guide updates associated with this Bulletin and the topics with which they correspond, access the Bulletin 2020-18 (Selling) Guide Updates Spreadsheet via the Download drop-down available at https://guide.freddiemac.com/app/guide/bulletin/2020-18.

Danny Gardner Senior Vice President, Client and Community Engagement

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TO: Freddie Mac Sellers May 28, 2020 | 2020-19

SUBJECT: SELLING GUIDANCE RELATED TO COVID-19 We continue to work closely with Fannie Mae under the guidance and direction of the FHFA to address the ongoing economic implications and uncertainty related to the coronavirus disease (COVID-19) pandemic and its impacts on Borrowers and the Mortgage origination process. This Bulletin provides: • Temporary requirements and guidance for Borrowers with qualifying income derived from self-employment • Temporary flexibilities for CHOICERenovationSM Mortgages • Delivery requirements for “no cash-out” refinance Mortgages • Temporary eligibility requirements related to the purchase of delinquent Mortgages in forbearance We are also reminding Sellers of additional resources, including our Selling FAQs related to COVID-19, which we continue to update.

UNDERWRITING BORROWERS WITH SELF-EMPLOYMENT INCOME

Effective date Sellers are encouraged to apply these temporary requirements to existing Mortgages in process; however, they must be applied to Mortgages with Application Received Dates on or after June 11, 2020 and until further notice.

Determining income stability with additional analysis and documentation Due to the continued impact of the COVID-19 pandemic on economic conditions and businesses throughout the country, in addition to the requirements in Guide Chapters 5301 and 5304, Sellers must comply with the following temporary requirements when assessing income derived from self-employment in order to determine if the Borrower’s income is stable and there is a reasonable expectation of continuance. The Mortgage file must include a written analysis of the self- employed income amount and justification of the determination that the income used to qualify the Borrower is stable.

Minimum additional documentation requirements

At a minimum, the following additional documentation must be obtained when assessing income from self-employment: • An unaudited year-to-date (YTD) profit and loss statement that is signed by the Borrower and reports business revenue (i.e., gross receipts or sales), expenses and net income. The information in the YTD profit and loss statement must cover the most recent month preceding the Application Received Date and be dated no more than 60 calendar days prior to the Note Date, and

• Two months business account statements no older than the latest two months represented on the YTD profit and loss statement ➢ For example, if the YTD profit and loss statement is through May 31, 2020, the business account statements can be no older than for April and May ➢ Personal asset account statements evidencing business deposits and expenses may be used when the Borrower is an owner of a small business and does not have a separate business account Or • An audited YTD profit and loss statement reporting business revenue (i.e., gross receipts or sales), expenses and net income. The information in the YTD profit and loss statement must cover the most recent month preceding the Application Received Date and be dated no more than 60 calendar days prior to the Note Date. Note: The Seller may need to obtain additional documentation to supplement the minimum required documentation in order to effectively assess the impact of the pandemic on the business.

Reviewing YTD profit & loss statements, business account statements and other relevant documentation

• The Seller must determine if the business revenue, expenses and net income documented in the unaudited YTD profit and loss statement are reasonably consistent with the revenue and expense cash flow documented on the business account statements • If the information on the YTD profit and loss statement is not reasonably consistent with the information on the business account statements, additional documentation (e.g., month-to-month or quarterly trending for YTD profit and loss, additional months and/or more recent bank statements) must be obtained to support the information and resolve the discrepancy • If the unaudited YTD profit and loss statement cannot be supported by business account statements and/or other documentation, the self-employment income is not eligible for use in qualifying • If the unaudited YTD profit and loss statement is supported, or if an audited YTD profit and loss statement is used, proceed to determining the current level of stable monthly income as outlined below

Establishing stable monthly income

• The Seller must review the YTD profit and loss statement (unaudited or audited), business account statements, and all other relevant factors and documentation to determine the extent to which a business has been impacted by COVID-19. Refer to the Business review and analysis section below for additional information regarding relevant factors. • The Seller must establish the current level of stable monthly self-employment income using details from the YTD profit and loss statement, business account statements, and supplemental documentation, as applicable • The Seller must determine whether the income level has declined by comparing the information on the YTD profit and loss statement to the business revenue (i.e., gross receipts or sales) and expenses reported on the most recent year’s business tax return(s), and the net monthly income as calculated in accordance with requirements and guidance in Chapter 5304, including use of Guide Form 91, Income Calculations, or a similar alternative form

The income level has not Use the qualifying income calculated following standard requirements and changed or has increased guidance in Chapter 5304, including the use of Form 91 or a similar alternative form. A YTD profit and loss statement, audited or unaudited, cannot be used to support a higher level of income than the amount derived from Form 91 or a similar alternative form.

The income level has declined • Determine if the income has stabilized. The Seller may need to obtain additional documentation to supplement the YTD profit and loss statement (e.g., a month-to-month income trending analysis, additional months and/or more recent business account statements) to make this determination. • If the income has stabilized:

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➢ Use no more than the current level of stable monthly self-employment income using details from the YTD profit and loss statement, business account statements, and supplemental documentation, as applicable ➢ Adjustments (e.g., depreciation) to the YTD profit and loss net income may be made in accordance with the requirements and guidance in Guide Section 5304.1(d) and Form 91, and in alignment with the adjustments based on the tax returns, as appropriate • If the income is declining and has not stabilized, then the income is not eligible for qualifying

Business review and analysis

The Seller continues to be responsible for establishing that the Borrower’s income is stable and likely to continue at the same level as used to qualify the Borrower. It is also expected that all Sellers ensure they are knowledgeable of the economic conditions related to a Borrower’s business. The documentation and the Seller's analysis of the business must support that the business has sufficient liquidity and is financially capable of producing stable monthly income for the Borrower. In addition to the business review and analysis requirements and guidance in Section 5304.1(d), the Seller must consider pandemic-related factors which may include, but are not limited to, the following: • If the ability of the business to generate revenue or operate at full capacity has been negatively impacted by the pandemic, have business operations been modified to support continued revenue? Is continued business revenue supported by any other documentation or information supplied by the Borrower (e.g., modified business plans) or obtained from other sources? • Impacts to the business operation, revenue and/or expenses, such as a break-down in the supply chain that is needed to maintain the product, a higher cost of expenses to obtain the product, or a lack of consumer demand for the product or service • Impacts to the business operation, revenue and/or expenses due to temporary restrictions such as State shelter-in- place, stay at home or other similar State or local orders • If temporary restrictions have been recently lifted, will the business continue to operate at a reduced level of revenue due to COVID-19-related factors, such as social distancing? If so, has the business been operating at this reduced level of revenue and/or increased level of expenses for a long enough period to establish income stability and is this documented with more recent business bank account statements evidencing this revenue flow or other equivalent information? • Does the business currently have documented liquid assets or access to capital for operating expenses that support the financial ability of the business to operate given current market and economic conditions? Are those assets comprised of or supplemented by loan proceeds from the Small Business Administration (SBA) Payroll Protection Plan (PPP) or any other similar COVID-19-related program (e.g., federal, State or local level business loans and grants)? A current balance sheet may be used to support the lenders determination of business stability, in conjunction with the profit and loss statement and business bank statements. • Additional economic information related to the business such as: ➢ Whether the business is part of an industry that is experiencing increasingly negative pandemic-related impacts ➢ Reputable news sources and economic forecasts related to the business industry and pandemic progression ➢ Whether the business type is in what is considered a high contact-intensive industry and if the higher risk of exposure to COVID-19 may present an impact to the potential for income stability and/or continuance until the medical issues surrounding the pandemic are closer to being resolved, whether or not there are State or local orders that temporarily restrict the business operation

Business assets Loan proceeds from the SBA Payroll Protection Plan (PPP) and/or any other similar COVID-19-related program(s) (e.g., federal, State or local level business loans and grants) are not considered business assets (as described in Section 5501.3(b)(iv)) for the purposes of eligible funds to qualify the Borrower for the Mortgage transaction, including, but not limited to, funds for Down Payment, Closing Costs and reserves.

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Reminder: verification of the current existence of the business The requirements and guidance published in Bulletin 2020-8 regarding verifying that the Borrower’s business is open and operating within 10 Business Days prior to the Note Date continue to apply.

AIM for self-employed At this time, we are still evaluating impacts to automated income assessment with Loan Product Advisor® using tax return data (i.e., AIM for self-employed). Freddie Mac will issue guidance at a future date.

CHOICERENOVATIONSM MORTGAGES

Mortgages sold with recourse and in forbearance These temporary flexibilities are effective immediately and remain in place until further notice. These temporary flexibilities are for CHOICERenovation Mortgages sold with recourse previously in COVID-19-related forbearance.

Under Chapter 4607, approved Sellers may deliver CHOICERenovation Mortgages with Settlement Dates prior to completion of the renovations provided the Mortgages are sold with recourse. We are offering temporary flexibilities to our requirements for removal of recourse for CHOICERenovation Mortgages previously in COVID-19-related forbearance. These flexibilities apply to “Mortgages in forbearance” as defined in Bulletin 2020-12 and CHOICERenovation Mortgages subject to forbearance plans in accordance with the temporary measures announced in Bulletin 2020-4 and as revised in Bulletin 2020-10. For the flexibilities below to apply, the forbearance period must have ended, the CHOICERenovation Mortgage must not be delinquent at the time of the request to remove recourse and the Borrower must be making the monthly payments due: • If the Borrower did not miss any monthly payments during the forbearance period and the CHOICERenovation Mortgage is no longer subject to the forbearance plan, recourse may be removed • If the Borrower missed one or more monthly payments during the forbearance period, recourse may be removed upon the Borrower having successfully completed a repayment plan • As of February 1, 2020, the CHOICERenovation Mortgage must not have been 30 days delinquent more than once during the renovation period and prior to being subject to the forbearance plan. If it does not meet this requirement, then the recourse may be removed at a later date as specified in Section 4607.15. Note: Mortgages subject to recourse that may require a payment deferral or loan modification due to missed payments during the forbearance period continue to be subject to our existing requirements.

Mortgages with Settlement Dates after completion of renovations In Bulletin 2020-14, Freddie Mac temporarily revised our Mortgage eligibility requirements to limit our purchase of Mortgages to those with Settlement Dates no more than six months after the Note Date or, for Construction Conversion and Renovation Mortgages, the Effective Date of Permanent Financing. Effective immediately, we are offering flexibility to these temporary requirements for CHOICERenovation Mortgages with Settlement Dates after completion of renovations. After completion of renovations, the Seller may sell the CHOICERenovation Mortgage to Freddie Mac provided the Settlement Date is no more than 12 months after the Note Date. (Note: Pursuant to Section 4607.4(a), all renovations must be completed within 365 days of the Note Date for a CHOICERenovation Mortgage.)

DELIVERY REQUIREMENTS FOR “NO CASH-OUT” REFINANCE MORTGAGES For Freddie Mac-owned “no cash-out” refinance Mortgages utilizing the appraisal flexibilities in Bulletin 2020-5, Sellers should enter the ULDD Data Point, Related Loan Investor Type (Sort ID 222) of “FRE” as well as the nine-digit Freddie Mac loan number assigned to the original Mortgage in ULDD Data Point, Related Investor Loan Identifier (Sort ID 221). Sellers should use their best efforts to provide this information. However, we recognize a Seller’s process and systems may not be updated to accommodate this change and in these cases the Seller is not required to provide this information. This temporary guidance does not waive any current requirements in Section 6302.16(b)(ii).

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PURCHASE OF DELINQUENT MORTGAGES IN FORBEARANCE Bulletin 2020-12 announced, and Bulletin 2020-17 extended, temporary eligibility requirements allowing Sellers to sell to Freddie Mac certain Mortgages for which the Borrower has requested forbearance. Under the temporary eligibility requirements, the Mortgages must be no more than 30 days delinquent. Sellers were instructed to populate the ULDD Data Point, Investor Feature Identifier (Sort ID 368) with either J76 or J77, as applicable, and reminded to populate the ULDD Data Point, Delinquent Payments Over Past 12 Months Count (Sort ID 452) as appropriate. With this Bulletin, effective for Mortgages that are 30 days delinquent and with Settlement Dates on or after June 1, 2020, Sellers must submit the following updates using the Post-Fund Data Correction process to ensure the Mortgage servicing data is reflected accurately. • Loan Acquisition Scheduled UPB Amount (Sort ID 385). The updated value for this ULDD Data Point must reflect the actual balance as of the Settlement Date. • Last Paid Installment Due Date (Sort ID 440). The updated value for this ULDD Data Point must be the actual date of the last paid installment. Sellers must deliver these updated values for the ULDD Data Points according to the format instructions provided on the Post-Fund Data Correction Form (DCR Form). These updates must be submitted in the same month as the Settlement Date. The $500 compensatory fee associated with contract non-compliance and contract changes will be waived. Please note that all Credit Fees in Price found in Guide Exhibit 19 will apply to the revised UPB amount. NOTE: The Seller must provide standard required ULDD information at delivery and subsequently provide these updates. If the Seller provides data in accordance with the instructions above at the time of delivery, the Mortgage will receive a critical edit in Loan Selling Advisor®.

GUIDE AND SYSTEM UPDATES We are not updating the Guide or Loan Product Advisor to reflect any of the changes noted in this Bulletin.

Danny Gardner Senior Vice President, Client and Community Engagement

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TO: Freddie Mac Sellers June 3, 2020 | 2020-20

SUBJECT: SELLING UPDATES This Guide Bulletin announces: • Addition of a new chapter in the Guide Selling segment containing property insurance requirements previously located in the Guide Servicing segment – June 10, 2020 • The addition of a new eligibility category for leased amenities in Freddie Mac Condo Project Advisor® – June 18, 2020 • Updates related to eMortgages – June 10, 2020

PROPERTY INSURANCE REQUIREMENTS Effective June 10, 2020 Currently, the insurance requirements for Mortgages sold to and serviced for Freddie Mac are located in Guide Chapter 8202, Property Insurance, in the Guide Servicing segment. To make it easier for Sellers to locate and refer to the requirements applicable to Mortgages eligible for sale to Freddie Mac, we are moving these insurance requirements to new Chapter 4703. We are not changing any of the requirements at this time, but minor updates were included for clarification. Among other things, Chapter 4703 includes: • Requirements for property insurance insurer licensing and ratings • Property insurance types and amounts, and • Flood insurance (including requirements for a flood zone determination for each property securing a Mortgage sold to Freddie Mac) We are also updating Guide Sections 8202.1 through 8202.3, 8202.5 through 8202.8 and 8202.10 to reflect the movement of the insurance requirements to new Chapter 4703 located in the Selling segment. Additionally, applicable cross-references throughout the Guide will be updated to refer to the new location. Guide impacts: Sections 2101.8, 4201.12, 4304.7, 4407.1, 4607.14, 5601.12, 5701.2, 5702.1, 5705.2, 7101.14, 8202.1 through 8202.3, 8202.5 through 8202.8, 8202.10, Chapter 4703 and Directory 5

ADDITION OF LEASED AMENITIES TO CONDO PROJECT ADVISOR® Effective June 18, 2020 Condo Project Advisor®, which is accessible through the Freddie Mac Loan Advisor® portal, allows Sellers to request single-loan exceptions (referred to as Project Waiver Requests (PWR)) for Established Condominium Projects that do not meet certain project eligibility requirements. We are adding a seventh Condominium Project eligibility category, Leased Amenities, to Condo Project Advisor: • Project in which the unit owners do not possess sole ownership of the Common Elements (referred to as “Leased Amenities” in Condo Project Advisor) – Section 5701.3(h) Additionally, authorized Sellers continue to be able to request a PWR through Condo Project Advisor in one or more of the following eligibility categories: • Delinquent assessments – Section 5701.5(e)

• Excessive commercial space – Section 5701.3(d) • Pending litigation – Section 5701.3(i) • Owner occupancy (referred to as “Project Unit Occupancy” in Condo Project Advisor) – Section 5701.5(c) • Reserves for capital expenditures and deferred maintenance – Section 5701.5(d) • Excessive single investor concentration (referred to as “Single Entity Ownership” in Condo Project Advisor) – Section 5701.3(j) Sellers interested in Condo Project Advisor should visit our Condo Project Advisor web page. Guide impact: Section 5701.1 eMORTGAGES Effective June 10, 2020

Transfer of Control of eNotes A Servicer will be required to deliver Guide Form 1036, Request for Possession or Control of Documents, to its eNote custodian to request the Transfer of Control from Freddie Mac when the Servicer must be the holder of the eNote in a Legal Action as defined in Section 8107.1(b). If Freddie Mac is the eNote custodian, Form 1036 must be sent to [email protected] at least three Business Days before the change of Control is needed. As a result, Guide Exhibit 47, Sample FHLMC eNote Transfer of Control Request, is being deleted. Guide impacts: Sections 1402.11, 1402.17, Exhibit 47 and Form 1036 eNote Custodians We are specifying that the Freddie Mac-approved eNote Custodian must perform periodic reviews of the eNotes in their eNote Vault system and notify Freddie Mac of any issues. Guide impact: Section 1402.18

GUIDE UPDATES SPREADSHEET For a detailed list of the Guide updates associated with this Bulletin and the topics with which they correspond, access the Bulletin 2020-20 (Selling) Guide Updates Spreadsheet via the Download drop-down available at https://guide.freddiemac.com/app/guide/bulletin/2020-20.

Danny Gardner Senior Vice President, Client and Community Engagement

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TO: Freddie Mac Servicers June 10, 2020 | 2020-21

SUBJECT: TEMPORARY SERVICING GUIDANCE RELATED TO COVID-19 Bulletins 2020-4, 2020-7, 2020-10, 2020-15 and 2020-16 provided temporary Servicer guidance in response to the National Emergency Declaration resulting from the outbreak and spread of COVID-19. As we continue to monitor and assess the situation, and in response to Servicer questions, with this Bulletin we are announcing: • Updates to Servicer incentives • Reminder on requirements for approving a forbearance plan for Borrowers with a COVID-19 related hardship • Clarification on HAMP good standing for a COVID-19 impacted Borrower • Clarification on continued solicitation for a Freddie Mac Flex Modification based on the reduced eligibility criteria • Late notices/payment reminder letters • Updates to Workout Prospector – delinquent interest • Other topics

EFFECTIVE DATE All of the changes announced in this Bulletin are effective immediately unless otherwise noted.

SERVICER INCENTIVES Bulletin 2020-15 stated that the Servicer incentive for a COVID-19 Payment Deferral would be communicated at a later date. With this Bulletin, we are informing Servicers of the COVID-19 Payment Deferral incentive amount, as well as making the following temporary updates to other Servicer incentives:

Incentive Type Incentive Amount

Repayment Plan $500 Effective for all repayment plans with a first payment due date under the repayment plan on or after July 1, 2020

Payment Deferral/COVID-19 Payment Deferral $500 Effective immediately for all Payment Deferrals/COVID-19 Payment Deferrals (NOTE: Payment Deferral evaluations do not begin until on or after July 1, 2020)

Flex Modification® $1,000 Effective for all Flex Modifications completed with a Trial Period Plan effective date on or after July 1, 2020

All incentive types described above are earned by the Servicer in accordance and compliance with all requirements as described in the Guide and associated Bulletins. Additionally, beginning on the effective dates described above, Servicer incentives will be capped at a total of $1,000 per Mortgage in aggregate for all repayment plans, Payment Deferral/COVID-19 Payment Deferrals and Flex Modifications completed going forward. Workout and relief options already completed, or begun prior to the effective dates described above will not be subject to the aggregate incentive cap. Existing incentive amounts for liquidations will remain unchanged, and will not be subject to the incentive cap. Exhibit 96, Servicing Incentives and Compensatory Fees, will be updated with Bulletin 2020-22.

FORBEARANCE PLAN REMINDERS In response to questions received, Freddie Mac is reminding Servicers of the requirements in Bulletin 2020-10 as they relate to approving a forbearance plan for a Borrower with a COVID-19 related hardship. The requirements for approving a forbearance plan for a Borrower with a COVID-19 related hardship include, but are not limited to the following: • Permitting a forbearance plan regardless of delinquency, including one that would establish or extend a delinquency beyond a cumulative 12 months, and • Affirming that the Servicer must send a forbearance plan agreement to the Borrower, and • Clarifying that the Servicer must provide the term requested by the Borrower (i.e. if the Servicer and Borrower cannot agree on the length of the forbearance plan, then the Servicer must offer the forbearance plan term length requested by the Borrower, not to exceed 180 days). • Re-affirming that our temporary forbearance plan requirements require Servicers to approve or extend forbearance plans based on limited QRPC with the Borrower and/or an attestation from the Borrower that they continue to be impacted by a COVID-19 related hardship.

HAMP® GOOD STANDING FOR COVID-19 IMPACTED BORROWERS In Bulletin 2020-16, we announced that if the Borrower’s Mortgage was previously modified under the Home Affordable Modification ProgramSM (HAMP®) and the Borrower is in “good standing” when they entered into a COVID-19 forbearance plan, then the Borrower will retain good standing while on the active forbearance plan, even if the Borrower becomes more than 90 days delinquent. Additionally, the Borrower will retain good standing if they transition directly from a COVID-19 forbearance plan to a reinstatement, a repayment plan or a COVID-19 Payment Deferral. With this Bulletin, we are further clarifying that if a Borrower with a COVID-19 related hardship was not on a forbearance plan, but is less than 90 days delinquent and has not lost good standing upon entering into a COVID-19 Payment Deferral, the Borrower will retain good standing.

CONTINUED SOLICITATION FOR A FLEX MODIFICATION® In Bulletin 2020-15, we provided reduced eligibility criteria for Freddie Mac Flex Modifications® in certain circumstances, and updated solicitation requirements for the Flex Modification. With this Bulletin, we are clarifying that the Servicer is authorized to continue proactive solicitation for a Flex Modification based on the reduced eligibility criteria described in Bulletin 2020-15, at its discretion. In accordance with existing requirements, the Servicer must not solicit a Borrower for a Flex Modification based on reduced eligibility criteria if the Mortgaged Premises has a scheduled foreclosure sale date within 60 days of the evaluation date if in a judicial State, or within 30 days of the evaluation date if in a non-judicial State.

LATE NOTICES/PAYMENT REMINDER LETTERS When a scheduled payment is not received from the Borrower, Guide Section 9102.4 requires the Servicer to send a late notice/reminder letter to the Borrower no later than the 17th day after the Due Date, or the next Business Day if the 17th day after the Due Date is not a Business Day. We are clarifying that the Servicer is authorized to not send a late notice/reminder letter to the Borrower during an active forbearance plan term. This applies without regard to whether the Borrower’s monthly payment is reduced or suspended during the forbearance plan term. Additionally, this applies to forbearance plans for Borrowers with any eligible hardship type, including a COVID-19 related hardship.

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WORKOUT PROSPECTOR® – DELINQUENT INTEREST In response to the Coronavirus Aid, Relief and Economic Security Act (“CARES Act”), we are temporarily updating Workout Prospector® to modify how we calculate delinquent interest for the processing of the Payment Deferral and the Flex Modification in our automated fields. Workout Prospector is being updated to reflect these edits, however in the meantime Servicers must adjust the automated fields to adhere to applicable law. Additionally, Servicers must ensure compliance with the CARES Act and all applicable law during the forbearance plan term for a Borrower with a COVID-19 related hardship, and for any subsequent reinstatement, relief option, or workout option. The Workout Prospector User’s Guide will be updated shortly to identify the field at issue and provide other details.

OTHER TOPICS • We are providing a slightly revised COVID-19 Payment Deferral agreement, updated to remove language referencing the loss of good standing under HAMP, and in reference to the CARES Act (Attachment A)

ADDITIONAL RESOURCES We encourage Servicers to review the following COVID-19 resources: • Freddie Mac Single-Family web page on COVID-19 resources • Freddie Mac Servicing FAQs on COVID-19

GUIDE UPDATES The Guide will not be updated at this time to reflect these changes.

Bill Maguire Vice President, Servicing Portfolio Management

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TO: Freddie Mac Servicers June 10, 2020 | 2020-22

SUBJECT: SERVICING UPDATES This Guide Bulletin announces: Housing expense-to-income (HTI) ratio calculation – September 1, 2020 • Updates to the requirements for calculating a Borrower's monthly housing expense-to-income (HTI) ratio Property insurance requirements • New Guide Selling segment chapter for certain property insurance requirements previously located in the Servicing segment; Servicing segment chapter revisions reflect movement of these requirements. Consent Agreement contract language • Addition of Consent Agreement language that is required when a Servicer wants Freddie Mac's consent in order to obtain financing with respect to advances required to be made by the Servicer under the Guide Updates to Exhibit 33, Acknowledgment Agreement Incorporated Provisions • Updates to Exhibit 33, Acknowledgment Agreement Incorporated Provisions in connection with Servicing Contract Rights financings Updates from previous Bulletins • eMortgage updates for the transfer of control of eNotes • Third-party business continuity planning – October 1, 2020 Additional Guide updates and reminders • Further updates and reminders as described in the Additional Guide updates and reminders section of this Bulletin

EFFECTIVE DATE All of the changes announced in this Bulletin are effective immediately unless otherwise noted.

HOUSING EXPENSE-TO-INCOME (HTI) RATIO CALCULATION Effective September 1, 2020, but Servicers may implement earlier if they are ready to do so We are updating the requirements for calculating a Borrower's monthly housing expense-to-income (HTI) ratio to clarify that projected monthly escrow shortages should not be included in that calculation when evaluating a Borrower for imminent default or when determining a Borrower's ability to make a cash contribution toward a short sale or deed-in-lieu of foreclosure. Servicers should continue to include any escrow shortage that is currently part of a Borrower's contractual monthly payment when assessing a Borrower for imminent default or the Borrower’s ability to make a cash contribution. Guide impacts: Sections 9206.7, 9208.3, 9209.3 and Glossary

PROPERTY INSURANCE REQUIREMENTS As announced in Bulletin 2020-20, we have moved certain property insurance requirements from Chapter 8202 to new Selling Segment Chapter 4703. We are not changing any of the requirements at this time, but minor updates were included for clarification. Servicers must now refer to Chapter 4703 for the following: • Requirements for property insurance insurer licensing and ratings • Property insurance types and amounts, and • Flood insurance requirements We have created new Chapter 4703 and updated Sections 2101.8, 4201.12, 4304.7, 4407.1, 4607.14, 5601.12, 5701.2, 5702.1, 5705.2, 7101.14, 8202.1 through 8202.3, 8202.5 through 8202.8, 8202.10 and Directory 5 to reflect these changes.

CONSENT AGREEMENT If a Servicer wishes to obtain financing to fund advances of delinquent principal and interest, advances of taxes and insurance, and all other advances, including foreclosure and liquidation and related expenses required to be made by Servicer under the Guide and/or the other Purchase Documents, the Servicer must obtain the prior written consent of Freddie Mac by entering into a Consent Agreement with Freddie Mac. We are updating the Guide to include the required Consent Agreement language.. Guide impacts: Section 9701.23, Exhibits 103, 104 and Glossary

UPDATES TO EXHIBIT 33, ACKNOWLEDGMENT AGREEMENT INCORPORATED PROVISIONS We are updating Exhibit 33, Acknowledgment Agreement Incorporated Provisions, to make some clarifying changes in connection with financing transactions involving Servicing Contract Rights. Guide impacts: Section 1101.2 and Exhibit 33

UPDATES FROM PREVIOUS BULLETINS Transfer of Control of eNotes As announced in Bulletin 2020-20, Servicers are now required to deliver Guide Form 1036, Request for Possession or Control of Documents, to their eNote custodian to request the Transfer of Control from Freddie Mac when the Servicer must be the holder of the eNote in a Legal Action as defined in Section 8107.1(b). If Freddie Mac is the eNote custodian, Form 1036 must be sent to [email protected] at least three Business Days before the change of Control is needed. As a result, Guide Exhibit 47, Sample FHLMC eNote Transfer of Control Request, is being deleted. Guide impacts: Section 1402.11, Exhibit 47 and Form 1036

Third-party business continuity planning

Effective October 1, 2020

Chapter 1302 requires that Seller/Servicers have and maintain an information security program and business continuity plan that ensures the Seller/Servicer's ongoing ability to conduct business operations with Freddie Mac. As announced in Bulletin 2020-18, Freddie Mac has updated the Guide to make explicit that a Seller/Servicer's obligation to implement minimum information security program requirements includes requirements to reduce the impact and likelihood of unauthorized access to Freddie Mac proprietary information in the Seller/Servicers' files, records, storage facilities and systems of any Third-party provider (TPP) or other Related Third Party. Specifically, a Seller/Servicer must obligate each

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TPP and any other Related Third Party to comply with certain requirements to safeguard and maintain the security, confidentiality and availability of systems, data and information.

Seller/Servicers have until October 1, 2020 to make sure that these minimum information security program requirements are met. Capitalized terms used above that are not defined in the Glossary are defined in Section 1401.2. Guide impacts: Sections 1302.1, 1302.3, 1401.2 and 2401.1

ADDITIONAL GUIDE UPDATES AND REMINDERS

Loan Level Reporting We are updating Section 8303.30 to remind Servicers that they can access the Response File on a daily basis to review loan level details for each Loan Level Reporting file processed. Guide impact: Section 8303.30

REO Title Vendor Name Change Freddie Mac’s REO outsourcing vendor has changed its name from Green River Capital LLC, to Radian Real Estate Management. Servicers must report the necessary changes to the taxing authority and homeowners association (HOA) for title purposes effective immediately. When the Servicer contacts these organizations, the Servicer must have the REO titled as follows: Federal Home Loan Mortgage Corporation c/o Radian Real Estate Management 7730 South Union Park Avenue, Suite 400 Midvale, UT 84047 Guide impact: Section 9603.10

Form 710, Mortgage Assistance Application We are updating Form 710, Mortgage Assistance Application, to add language to the Borrower Consent and Agreement section that explicitly grants Servicers permission to disclose personal information from the Borrower’s tax return for purposes permitted by applicable law. Guide impact: Form 710

EDR default reason code 032 As announced in Bulletin 2020-7, we have converted default reason code 032 from “Contaminated Drywall” to “National Emergency Declaration.” We are updating Section 8403.1 to reflect this change. Guide impact: Section 8403.1

GUIDE UPDATES SPREADSHEET For a detailed list of the Guide updates associated with this Bulletin and the topics with which they correspond, access the Bulletin 2020-22 (Servicing) Guide Updates Spreadsheet via the Download drop-down available at https://guide.freddiemac.com/app/guide/bulletin/2020-22.

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Bill Maguire Vice President, Servicing Portfolio Management

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TO: Freddie Mac Sellers June 11, 2020 | 2020-23

SUBJECT: UPDATES REGARDING TEMPORARY COVID-19-RELATED REQUIREMENTS FROM PREVIOUS BULLETINS We continue to work closely with Fannie Mae under the guidance and direction of the FHFA to address the ongoing economic implications and uncertainty related to the coronavirus disease (COVID-19) pandemic and its impacts on Borrowers and the Mortgage origination process. This Bulletin provides updates regarding certain temporary COVID-19-related requirements and flexibilities announced in previous Bulletins, including: • The extension of the effective dates for previously announced temporary requirements and flexibilities • The extension of the effective dates for the purchase of Mortgages in forbearance • The extension of the effective date for Sellers’ post-funding quality control requirements • Automated income assessment with Loan Product Advisor®

Extension of temporary changes from previous Bulletins In Bulletin 2020-14, we extended the effective date for some previously announced temporary requirements to Mortgages with Application Received Dates through June 30, 2020. We are further extending the effective date for the temporary requirements and flexibilities for Mortgages with Application Received Dates through July 31, 2020 for the following: • Credit underwriting requirements announced in Bulletins 2020-5 and 2020-8 • Appraisal and GreenCHOICE Mortgage® flexibilities announced in Bulletins 2020-5, 2020-8 and 2020-11 • Condominium Project flexibilities announced in Bulletin 2020-11 • Power of attorney flexibilities announced in Bulletin 2020-8

Extension of temporary requirements for purchase of Mortgages in forbearance We are also extending the temporary requirements for purchase of Mortgages in forbearance announced in Bulletin 2020-12 and extended in Bulletin 2020-17. These requirements are now effective for Mortgages with Note Dates on or after February 1, 2020 and on or before July 31, 2020, and Settlement Dates on or after May 1, 2020 and on or before September 30, 2020. The chart below has been revised to reflect these changes and to update the language in the first column, second row of the chart such that it is applicable to all cash contracts rather than only those for mortgages that are not delinquent.

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Contract type Additional effective date requirements

Guarantor and MultiLender Contracts • Mortgages with Note Dates on or after February 1, 2020 and on or before March 31, 2020 must have Settlement Dates on or before May 31, 2020 Cash Contracts • Mortgages with Note Dates on or after April 1, 2020 and on or before July 31, 2020 must have Settlement Dates on or before September 30, 2020 (Revised)

Additional Requirements for Cash The Cash Settlement Date must be no later than the 20th of the month Contracts: Mortgages that are in after the month the Mortgage became 30 days delinquent (see the forbearance, that are no more than 30 days definition below). delinquent For example: • Notes with a first payment due date of July 1: If the Borrower does not pay the July payment, the Mortgage will become 30 days delinquent at the close of business on July 31. For these loans, the Settlement Date must be on or before August 20. • Notes with first payment due dates of July 2–30: If the Borrower did not pay the July payment, the Mortgage will become 30 days delinquent at the close of business on August 31. For these loans, the Settlement Date must be on or before September 20.

Extension of temporary flexibilities regarding Seller’s post-funding quality control requirements – targeted sampling In Bulletin 2020-11, we announced temporary flexibilities for Sellers related to post-funding quality control reviews. The quality control flexibilities announced in Bulletin 2020-11 were effective immediately for all Mortgages currently in the process of a post-closing Seller in-house quality control review and were to remain in place for all Mortgages selected through June 2020 for post-closing Seller in-house quality control reviews. These flexibilities will now remain in place for all Mortgages selected through July 2020 for post-closing Seller in-house quality control reviews.

Automated income assessment with Loan Product Advisor using tax return data (i.e., AIM for self- employed)

AIM for self-employed and temporary requirements announced in Bulletin 2020-19 We are explaining how the temporary requirements announced in Bulletin 2020-19 for underwriting Borrowers with self- employment income are applicable to Mortgages originated with automated income assessment with Loan Product Advisor using tax return data (i.e., AIM for self-employed). Sellers are required to upload any income documentation obtained for analysis to the participating third-party service provider. For Mortgages with Application Received Dates on or after June 11, 2020, this includes the documentation used to meet the temporary requirements. If, after performing the required additional analysis, the Seller finds a discrepancy between the information reflected on the tax returns and other documentation collected (e.g., income reflected on the unaudited year-to-date (YTD) profit and loss statement and supporting business asset statements is not consistent with the income on the uploaded tax returns), the Seller must update the information in the Income Calculation Report and upload the updated report to the service provider. They must then update the information in Loan Product Advisor and (re)submit the Mortgage for assessment of representation and warranty relief eligibility.

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Updating information in the Income Calculation Report and Loan Product Advisor The Seller must use the Income Calculation Report and Loan Product Advisor to submit the stable monthly income supported by their analysis. The Income Calculation Report can be used to document the analysis, including recording profit and loss information and providing a written analysis of each business with justification that the income amount used to qualify the Borrower is stable. This can be accomplished using the report’s current capabilities: 1. Profit and loss feature: The Seller wishing to use the Income Calculation Report to document the profit and loss statement must change the “Profit-And-Loss Statement Available” field from “No” (the default) to “Yes.” The Seller may then enter information from the audited or unaudited profit and loss statement. Once this information is entered, a monthly income based on the updated information from the YTD profit and loss statement is shown. This may affect the monthly income displayed on the Income Calculation Report as follows: ➢ If the income from the profit and loss statement is less than the income from the tax returns, then the income from the profit and loss statement information replaces the income from the tax returns on the Income Calculation Report ➢ If the income from the profit and loss statement is equal to or greater than the income from the tax returns, then the income on the Income Calculation Report will not change After documenting the profit and loss statement information and performing the analysis, if the Seller determines that the Income Calculation Report accurately reflects the stable monthly income (whether or not the income changed as a result of entering profit and loss information as described above), the Seller may use the “Notes” section to detail the rationale and justification for the income amount used. The Seller must then upload the updated report to the service provider and submit the loan with the stable monthly income amount to Loan Product Advisor for assessment of representation and warranty relief eligibility. 2. Manual adjustment feature: If the Seller determines that the income reflected on the profit and loss statement does not represent the stable monthly income from the business, the Seller may manually adjust the income and other line items (e.g., depletion, depreciation, etc.) in the Income Calculation Report in accordance with the temporary requirements. The adjustments must be made as follows: ➢ The “Profit-and-Loss Statement Available” field must be set to “No,” ➢ The Seller must enter the adjusted figures in the “Manual Overrides” section of the most recent tax year uploaded to the service provider, and ➢ The “What was considered for QI, 2Yr Avg. or CY?” field must be set to “CY” [current year] Once the manual adjustments are made, the monthly income displayed on the Income Calculation Report will change. After performing the required analysis and determining that the adjusted income on the Income Calculation Report accurately reflects the stable monthly income, the Seller may use the “Notes” section to detail the rationale and justification for the income amount used. The Seller must then upload the updated report to the service provider and submit the loan with the stable monthly income amount to Loan Product Advisor for assessment of representation and warranty relief eligibility. All temporary requirements from Bulletin 2020-19 and all other previously announced applicable temporary requirements related to COVID-19 must be met, and documentation used in the required analysis must be uploaded to the service provider. If so, the representation and warranty eligibility decision returned by Loan Product Advisor remains valid. Loan Product Advisor feedback messages will not be updated to reflect temporary requirements. Current messaging specifies that all documentation uploaded to the service provider (e.g., audited YTD profit and loss statement) must be retained in the loan file.

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• The Appraisal Institute’s Coronavirus-related Direction for Appraisers • National Association of Realtors Coronavirus Guide for Realtors

Danny Gardner Senior Vice President, Client and Community Engagement

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TO: Freddie Mac Seller/Servicers June 24, 2020 | 2020-24

SUBJECT: REVISED LIQUIDITY REQUIREMENT FOR MORTGAGES IN COVID-19-RELATED FORBEARANCE Effective June 30, 2020 Under the guidance of the FHFA and in alignment with Fannie Mae, Freddie Mac is updating the liquidity requirements for Seller/Servicers that are not depository institutions in recognition of the reduced Servicing costs associated with Mortgages in COVID-19-related forbearance relative to Servicing costs of other non-performing loans. In lieu of the liquidity requirement in Guide Section 2101.2(c), Seller/Servicers that are not depository institutions must at all times maintain liquidity according to the revised requirements shown in the table below.

Current liquidity requirement in Revised liquidity requirement Section 2101.2(c)

Seller/Servicers that are not depository institutions Seller/Servicers that are not depository institutions must at all times maintain the Acceptable Net Worth must at all times maintain the Acceptable Net Worth requirements applicable to depository institutions in requirements applicable to depository institutions in Section 2101.2(b), and must also maintain the Section 2101.2(b), and must also maintain the following: following: • Tangible Net Worth (as defined in Section • Tangible Net Worth/total assets ratio greater than 2101.2(a))/total assets ratio greater than or equal to or equal to 6%, and 6%, and • Liquidity equal to or exceeding 3.5 basis points • Liquidity (as defined in Section 2101.2(a)) equal to times Agency Mortgage Servicing plus 200 basis or exceeding 3.5 basis points times Agency points times the sum of nonperforming (90 or Mortgage Servicing plus 200 basis points times the more days delinquent) Agency Mortgage sum of the following: Servicing that exceed 6% of Agency Mortgage ➢ The total UPB of nonperforming (90 or more Servicing days delinquent) Agency Mortgage Servicing that is not in forbearance, plus ➢ The total UPB of nonperforming (90 or more days delinquent) Agency Mortgage Servicing that is in forbearance and which were delinquent at the time it entered forbearance, plus ➢ 30% of the UPB of nonperforming (90 or more days delinquent) Agency Mortgage Servicing that is in forbearance and which were current at the time it entered forbearance This liquidity must only be maintained to the extent this sum exceeds 6% of Agency Mortgage Servicing.

Please note that if a Mortgage exits forbearance during a quarter, it will continue to be treated as being in forbearance until the end of that quarter for purposes of the liquidity requirement.

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CONCLUSION We appreciate the support that Seller/Servicers continue to extend to Borrowers coping with hardships attributed to COVID-19. If you have any questions about the changes announced in this Bulletin, please contact your Freddie Mac representative or call the Customer Support Contact Center at 800-FREDDIE. Sincerely,

Bill Maguire Vice President, Servicing Portfolio Management

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TO: Freddie Mac Servicers June 24, 2020 | 2020-25

SUBJECT: TEMPORARY SERVICING GUIDANCE RELATED TO COVID-19 AND EDR CLARIFICATIONS FOR ALL HARDSHIP REASONS Guide Bulletins 2020-4, 2020-7, 2020-10, 2020-15, 2020-16 and 2020-21 provided temporary Servicer guidance in response to the National Emergency Declaration resulting from the outbreak and spread of COVID-19. As we continue to monitor and assess the situation, and in response to Servicer questions, with this Bulletin we are announcing an extension to the COVID-19 foreclosure moratorium. We are also providing the guidance regarding EDR requirements that apply to all eligible hardship reasons, including COVID-19 related hardships for: • EDR reporting of a Mortgage that is current – October 1, 2020 • Required EDR reporting when sending a streamlined offer for a Freddie Mac Flex Modification®

EFFECTIVE DATE All of the changes announced in this Bulletin are effective immediately unless otherwise noted.

EXTENSION OF THE COVID-19 FORECLOSURE MORATORIUM We are extending the foreclosure moratorium announced in Bulletins 2020-4, 2020-10 and 2020-16. Servicers must suspend all foreclosure actions, including foreclosure sales, through August 31, 2020. This includes initiation of any judicial or non-judicial foreclosure process, move for foreclosure judgment or order of sale. This foreclosure suspension does not apply to Mortgages on properties that have been determined to be vacant or abandoned.

EDR Current Mortgages Effective October 1, 2020 In response to Servicer inquiries, we are clarifying that Guide Section 9102.7 requires Servicers to report all alternatives to foreclosures, which includes forbearance plans, via EDR, on all Mortgages, including those that are not delinquent. Additionally, we are updating our reporting requirements to require Servicers to include the reason for default when reporting a forbearance via EDR, regardless of delinquency status or length. These updated requirements apply to all Mortgages regardless of the reason for default. Within the first three Business Days each month, Servicers must report all status and event codes for Mortgages that are on a forbearance plan in the prior month, including Mortgages that are not delinquent. Servicers must include the following information when reporting a forbearance to Freddie Mac: • Default reason code (see Guide Exhibit 82, Electronic Default Reporting Transmission Code List) • Default action code: 09 (Forbearance) • Default action date - Servicers must report the Due Date of the first payment due under the forbearance plan. For Mortgages with Due Dates other than the first day of the month, Servicers must report the default action date as the first day of the month in which the payment is due.

Note: If the Servicer has previously reported Mortgages on forbearance plans that do not reflect the default action date as outlined above, the Servicer must update the default action date in their next EDR submission. For example, the Servicer should report the following for a Borrower who is current on his/her June 2020 payment* and requests the Servicer on June 24, 2020 to be placed on a forbearance plan beginning with his/her July 1, 2020 payment due to COVID-19 related hardship: • Default reason code: 032 (National Emergency Declaration) • Default action code: 09 (Forbearance) • Default action date: 7/1/2020 *If the Borrower has not made his/her June 2020 payment, the Servicer would report 6/1/2020 as the default action date. Servicers must continue to report this information each month until the forbearance plan has ended or until the Mortgage is current and no longer on a forbearance plan. Servicers are encouraged to adopt these reporting requirements immediately but must do so no later than their October 2020 EDR submission, which reflects September 2020 activity. We will update Section 9102.7 and Exhibit 82 in a future Bulletin. Streamlined offer for a Flex Modification In light of the COVID-19 pandemic and potentially higher volumes of Borrowers transitioning from forbearance plans, we are emphasizing to Servicers our EDR reporting requirements pertaining to streamlined offers for a Freddie Mac Flex Modification®. When a Servicer is evaluating or has sent a streamlined offer for a Flex Modification, the Servicer must report default action code HD (Modification in review) to notify Freddie Mac that the Borrower is being evaluated for a modification. Servicers must report this code along with the date they began reviewing the Borrower for the modification. Additionally, we are expanding this requirement so that Servicers must continue to report the “HD” code until the streamlined offer expires, or until the Borrower enters into a Trial Period Plan.

ADDITIONAL RESOURCES We encourage Servicers to review the following COVID-19 resources: • Freddie Mac Single-Family web page on COVID-19 resources • Freddie Mac Servicing FAQs on COVID-19

GUIDE UPDATES The Guide will not be updated at this time to reflect these changes.

Bill Maguire Vice President, Servicing Portfolio Management

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