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All ​Participant Memorandums (APMs)

APMs (All Participant Memoranda) are issued by IPM generally to announce policy and MBS Guide changes accessed by Issuers, Document Custodians and other participants in Ginnie Mae programs.

5 most recent APMS
11/23/2021 - APM 21-08

Due to the continuing impact of the COVID-19 Pandemic National Emergency, Ginnie Mae will extend use of alternative audit procedures originally announced in APM 20-14: “Alternative Procedures Permitted for Certain Aspects of Issuer Annual Audit Report for Fiscal Year 2020”​ for Issuers with a fiscal year ending on or before March 31, 2022 as follows:

Chapter 3 Part 7 § A of the Mortgage-Backed Securities Guide (MBS Guide) requires Issuers to obtain and submit annual audited financial statements and Audit Reports, prepared by an independent auditor, in accordance with Chapter 6 of the HUD Audit Guide, which requires auditors to review the processes and controls of document custodian(s) associated with the Issuer. Ginnie Mae recognizes that, due to the COVID-19 National Emergency, independent auditors may not be able to perform certain document custodian review audit activities for the fiscal year ending on or before March 31, 2022 that require physical inspection and observation.

Ginnie Mae will accept audited financial statements and Audit Reports for Issuers with a fiscal year ending on or before March 31, 2022, where the independent auditor relied on alternative procedures to meet the Issuer’s document custodian annual audited financial statement and Audit Report review objectives requiring physical inspect and observation in lieu of the procedures outlined in the HUD Audit Guide.

Issuers must ensure that the audited financial statement and Audit Report documentation submitted to Ginnie Mae details the condition necessitating the use of an alternative procedure, a description of the alternative procedure used, and the independent auditor’s rationale outlining how the alternative procedures met the original objective of the document custodian review audit.

This APM does not in any way change components of an Issuer’s audited financial statements to be performed by an independent auditor with a fiscal year ending on or before March 31, 2022, nor does it alter any other requirements not expressly addressed by this memorandum. Chapter 3 of the MBS Guide has been modified to incorporate the provisions of this memorandum.

If you have further questions, please contact your Account Executive in the Office of Issuer and Portfolio Management directly.

11/15/2021 - APM 21-07

In consideration of the impact of the COVID-19 pandemic and associated insuring agency guidelines for mortgage servicing, Ginnie Mae understands that certain features of the Digital Collateral Program, namely the ability to use electronic signatures and to adopt remote online notarizations, are flexibilities that would benefit all Issuers and borrowers in the government-backed mortgage segment. Therefore, effective with the publication of this APM, Ginnie Mae hereby permits the use of electronic signatures and remote online notarization for loan modification agreements on “paper” mortgages. Requirements for modifications of eMortgages or eNotes will be addressed in a separate APM.

Effective immediately, all approved Ginnie Mae Issuers are permitted to use electronic signatures when executing loan modification agreements provided that: 

​1) The promissory note is a paper promissory note bearing a wet signature;

2) The electronically signed loan modification agreement complies with the recording jurisdiction's recordation requirements; and

​3) The eClosing platform or other system(s) the Issuer uses to obtain and maintain borrowers’ electronic signatures on the loan modification agreement must:

    • Clearly support the verification of the Borrower’s identity;
    • Clearly identify the symbol or process used as an electronic signature by the borrower and the purpose of the electronic signature;
    • Present the loan modification agreement in compliance with all applicable state and federal requirements concerning the content, display, and format of information and retention (as required for paper records);
    • Clearly identify the loan modification agreement as the electronic record being presented for electronic signature;
    • Capture clear evidence that is compliant with all applicable state and federal requirements (including ESIGN) of the borrower’s agreement to receive electronic records and the borrower’s intent to adopt the electronic signature and to electronically sign the loan modification agreement and other electronic records as applicable, and maintain a record of such agreement;
    • Attach the electronic signature to, or associate the electronic signature with, the loan modification agreement and any other electronic records associated with the loan modification executed by the borrower; • Attribute the electronic signature to the applicable borrower;
    • Include the borrower’s printed name in a visible and legible manner on the loan modification agreement; • Include a date and time stamp on the loan modification indicating when the borrower executed the loan modification agreement;
    • Track and log actions related to the creation and signing of the loan modification agreement;
    • Provide reasonable evidence that loan modification agreements created and maintained by the system are not (and have not been) subject to unauthorized access or alteration;
    • Be capable of accurately reproducing the fonts, styling, margins, and other physical features of the loan modification agreement when electronically displayed and printed post-execution and as required by state and/or federal law; and
    • In all other ways ensure that the document produced is in compliance with insuring agency guidelines and Ginnie Mae’ s guidance on Loan Modifications.

​​4) The electronically signed loan modification agreement is delivered to the Document Custodian in hard copy or delivered via electronic transmission with the express consent of the Document Custodian, bearing evidence of recordation, including information relating to the date and time of recordation. If a Document Custodian accepts an electronic copy in lieu of the hard copy, the Custodian is responsible for producing and placing a hard copy of the Loan Modification Agreement in the pool and loan file. If the Modification Agreement is delivered via electronic submission, it may be delivered as a MISMO Category 1, 2 or 4 Version 1.02 SmartDoc document or Portable Document Format (PDF) document.

Remote Online Notarization (RON)

Ginnie Mae is also permitting the use of Remote Online Notarization (RON) for notarizations associated with Loan Modification Agreements subject to the Notarization Requirements outlined in Section 3250.00 of the Digital Collateral Program Guide, Appendix V-07 of the MBS Guide (eGuid​e).

Please note that the securitization of mortgages where the promissory note is an eNote is reserved for participants in the Digital Collateral program only (approved specifically as eIssuers). This memorandum does not permit Issuers that have not been approved as eIssuers to securitize or deliver for securitization by Ginnie Mae mortgages where the Promissory Note is an eNote. All other loan and pool certification requirements not expressly addressed by this memorandum remain unchanged.

If you have any additional questions about the content of this Memorandum, contact your Account Executive in the Office of Issuer and Portfolio Management.

10/29/2021 - APM 21-06

In APM 19-05, Ginnie Mae announced revisions to its seasoning requirements for VA refinance loans to implement the Protecting Affordable Mortgages for Veterans Act of 2019.

The requirements as implemented in the APM and the MBS Guide impose a seasoning test on refinances of VA loans that have been modified. However, Ginnie Mae is aware that there is some confusion among program participants regarding requirements in Chapter 24 of the MBS Guide and APM 19-05.

Below are the key points in the Guide’s treatment of the intersection of modifications and seasoning:

  • Pooling of Modified loans

Modified Loans are defined in the MBS Guide, and for the purposes of securitization are their own loan type. At pooling, Modified Loans are considered new loans and the modified terms are the basis under which the loans were pooled. In accordance with Chapter 24, Part 2, section (A)(2), Modified VA Loans are not subject to the Chapter 24, Part 2, Section A(3)(d)(i) and (ii) seasoning requirements. The exemption from the seasoning requirement applies only when the loan being pooled is the Modified VA Loan.

  • Pooling of Refinances of Modified VA Loans

Loans that refinance a Modified Loan are subject to the above referenced seasoning requirements. Since the modified loan that is being refinanced is considered a new loan based on the modified terms, the modified loan must be seasoned before it can be refinanced and pooled into Ginnie Mae MBS.

To bring clarity to the requirements in the MBS Guide, Ginnie Mae is defining the term “Refinance of a Modified Loan”, and moving the modification reference in Chapter 24, Part 2, Section A(3)(d)—Refinance Loans to Chapter 24, Part 2, Section A(2)—Special Requirements for Modified FHA-insured, VA and RD Guaranteed Loans.

The definition of “Refinance of a Modified Loan”, and the related requirement for seasoning are being added to Chapter 24, Part 2, section A(3)(d).

The definition of a “Modified Loan” is being updated in Chapter 24, Part 2 section A (2) and added to the Glossary to clarify that Ginnie Mae views a Modified Loan as a new loan, and the modified terms under which it is pooled are used to determine compliance with the seasoning requirements in the event the Modified Loan is refinanced. Additionally, Ginnie Mae is removing language in Chapter 24, section A(2)(c) permitting the loan modification date to be used as the origination date for pooling. In accordance with Appendix III-07 to this guide, the Loan Origination Date should be the Note date, or date the loan was originated.

Recognizing that some adjustment of origination procedures may be necessary to ensure compliance with these definitions, Ginnie Mae is implementing an effective date of January 1, 2022 for the these Guide changes.

If you have any additional questions about the content of this memorandum, please contact your Account Executive in the Office of Issuer and Portfolio Management.

10/29/2021 - APM 21-05

Ginnie Mae is announcing the creation of a new Single Family, fixed rate MBS pool type to provide for securitization of modified loans with terms greater than or equal to 361 but not more than 480 months from the pool issuance date. The new Extended Term (ET) pool is available for pool issuance in December 2021. C ET Pool Parameters

The C ET Pool is a Ginnie Mae II program custom pool that must be comprised exclusively of loans modified pursuant to the insuring or guaranteeing agency’s requirements and that have terms greater than or equal to 361 but not more than 480 months from the pool issuance date. Ginnie Mae is defining these loans as “Extended Remaining Term Modified Loans” in order to differentiate such modified loans from those eligible for Ginnie Mae II Multiple Issuer Pools (MIP).

Extended Remaining Term Modified Loans must meet the requirements for this specific pool type as well as the applicable eligibility requirements in Chapter 9 of the MBS Guide, which is being revised to reflect this new pool type.

Loan amounts for this custom Pool type shall not be limited at pooling, pursuant to Ginnie Mae’s existing requirements. Each C ET pool must have a minimum of one loan and an original principal balance of at least $25,000. Only Extended Remaining Term Modified Loans are eligible for securitization into C ET pools and the Extended Remaining Term Modified Loans are limited to securitization in C ET pools.

Loan and Pool Data Delivery Requirements for C ET Pool

C ET pools must be submitted electronically through GinnieNET. Hard copy submissions will not be accepted by the Pool Processing Agent. Issuers that import loan data into GinnieNET must ensure that their file layout supports inserting “ET” into the file layout position designated for the Pool Type. Only Loan Purpose Code 3--“Mod-HAMP” or 4--“Mod-Non-HAMP” may be associated with each loan in a C ET pool.

When completing form HUD 11705, all Issuers must check the box displaying the following attestation:

“With respect to each mortgage loan, all modifications of the mortgage loan after the origination of such mortgage loan must be occasioned by default or reasonably foreseeable default on such mortgage loan within the meaning of Treasury Regulations section 1.860G-2(b)(3)(i).”

GinnieNET will accept submission of C ET pools beginning in December 2021.

Issuers may refer any questions relating to the requisite GinnieNET file layout to the Ginnie Mae helpdesk at 1-833-GNMA HELP or by contacting ginniemae1@bnymellon.com.

Consistent with this memorandum, Ginnie Mae is updating Chapter 1, Chapter 9, Chapter 10, Chapter 12, Chapter 18, Chapter 24, Appendix III-06, Appendix IV-20, Appendix IV-25, Appendix IV-27, Appendix V-01 (DCM Glossary), and the MBS Guide Glossary. All MBS Guide updates are effective immediately.

If you have any additional questions about the content of this memorandum, please contact your Account Executive in the Office of Issuer and Portfolio Management. ​​

9/13/2021 - APM 21-04

Due to the continuing impact of the COVID-19 Pandemic National Emergency on forbearance levels and delinquency rates, Ginnie Mae is further extending the exemptions that were announced in the APM 20-06: "Treatment of Mortgage Delinquency Ratios for Issuers Affected by COVID-19", extended in the APM 20-17: “Extension of Temporary Relief from the Acceptable Delinquency Threshold Requirement​” and re-extended in the APM 21-01: “Extension of Temporary Relief from the Acceptable Delinquency Threshold Requirement​” from January 31, 2022 through July 31, 2022 (June 2022 investor reporting).

Ginnie Mae will continue to exclude any delinquencies occurring on or after April 2020 for the purposes of enforcing the provisions in Ch. 18, Part 3, §§ C & D. Ginnie Mae will provide this exclusion automatically through July 31, 2022 to Issuers that were compliant with Ginnie Mae’s delinquency rate thresholds as demonstrated by their April 2020 investor accounting report, reflecting March 2020 servicing data. Issuers do not need to change any aspect of their monthly report to benefit from this exclusion and must continue to report loans in forbearance as delinquent in accordance with established procedures.

If you have further questions, please contact your Account Executive in the Office of Issuer and Portfolio Management directly.


Last Modified: 10/14/2020 2:13 PM