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.
In 2020, Ginnie Mae published its Digital Collateral Program Guide (eGuide), Appendix V-07 of the MBS Guide, via APM 20-10, announcing the launch of the pilot phase of its Digital Collateral Program, which permits approved Issuers to securitize loans containing electronic promissory notes (eNotes) and other digitized loan documents. Since then, Ginnie Mae has continued to assess and develop its Digital Collateral Program, to provide our eIssuers with an updated and enhanced eGuide. While some of the key features of the new eGuide are highlighted below, please read the revised eGuide for full program guidance. The changes are effective beginning June 1st, 2022.
Revised requirement for Remote Online Notarization recording storage
The length of time an eIssuer is required to either maintain the recording of a notarial ceremony or maintain the ability to access and reproduce the recording of a notarial ceremony has been revised from the life of the loan to the greater of 10 years or the minimum period required by applicable law. Please see “Notarization Requirements” (3250.00) in the eGuide,
Revised procedures related to MERS® eRegistry addition of the Transfer of Control and Location with Secured Party transaction
Ginnie Mae will permit the use of the Transfer of Control and Location with Secured Party transaction by a warehouse lender at the direction of an eIssuer to add Ginnie Mae as Secured Party on an eNote. Please see “General Requirements for Delivery of eNotes” (4400.00) in the eGuide.
Revised requirements and procedures for the release of documents, including the release of Secured Party, due to a loan buyout from a pool
The eGuide is updated to include procedures for the eCustodian to notify Ginnie Mae after it has duly executed a Form HUD 11708 with certain reason codes. For buyout types related to payment in full, completion of a foreclosure, satisfaction through hazard or flood insurance, eminent domain, or condemnation, Ginnie Mae does not need to release its Secured Party designation prior to the eIssuer deactivating the eNote on the eRegistry.
The eGuide is also updated to include details on the information necessary for requests to remove or reverse Secured Party. Please see “Release of eDocs and Loan Files Received in Hard Copy” (5610.00), “Transfers of Location of Authoritative Copy of eNote” (5620.00), “Removal of Ginnie Mae from the Secured Party Field Due to Loan Liquidations” (6210.01), “Issuer Responsibility for MERS® eRegistry Transaction After a Buyout” (6240.00), and “Format for Requests to Remove or Reverse Ginnie Mae from the Secured Party Field” (6210.03) in the eGuide.
Updates to extend the changes announced in APM 21-07 (eSignatures and Remote Online Notarization on Loan Modification Agreements) to eNotes
As announced in APM 21-07, Ginnie Mae permits the use of electronic signatures and electronic notarization, including Remote Online Notarization (RON), when executing Loan Modification Agreements to “paper” notes. The eGuide has been updated to allow eModifications to eNotes. The “Prohibition on Electronic Loan Modifications” (5720.00) and “Prohibition on Electronic Loan Modifications” (6220.04) sections of the eGuide have been removed. Please see “Electronically Signed Modification Agreements” (4640.00), “Electronically Recorded Security Instruments and Modification Agreements” (5210.00), “Required Documents” (5420.00), “Required Documents” (5530.00), “Document Review Procedures for Recertification” (5540.00), ”Loan Modification Agreements” (5710.00), “eMortgage Loan Modifications Subject to a Trial Payment Period” (6220.01), “eMortgage Loan Modifications occurring without a Trial Payment Plan” (6220.02), and “Securitization of eMortgage Loan Modifications” (6220.02) in the eGuide.
Added procedures for refinancing an original loan containing an eNote using a New York Consolidation Extension and Modification Agreement (NY CEMA)
The eGuide is updated to include procedures for an eIssuer to use when an eNote is being bought out because it is being consolidated into a NY CEMA. These changes do not allow for the origination of a NY CEMA as an eNote. Please see “New York Consolidation Extension and Modification Agreement (NY CEMA)” (6260.00) in the eGuide.
Added requirements and procedures for eNotes executed using a Power of Attorney
The eGuide is updated to include policy and procedures for the acceptance of eNotes executed using a Power of Attorney. Please see “Other Exclusions” (3240.00), “Delivery Requirements for eNotes Executed by an Attorney-in-Fact” (4410.00), “General Requirements for the Receipt and Storage of eNotes” (5100.00), and “Required Documents” (5310.00) in the eGuide.
Added procedures for making minor corrections to eNotes
The eGuide is updated to include procedures for corrections to eNotes, with Ginnie Mae approval, where a minor, clerical error is detected after the eNote is executed and registered on the eRegistry. Please see “Defects related to eNote” (5820.00) in the eGuide.
The changes listed above are not an exhaustive list and should not be relied on for compliance. Issuers should read the full eGuide to ensure they comply with the updated requirements. If you have further questions, please contact your Account Executive in the Office of Issuer and Portfolio Management directly.
Ginnie Mae is transitioning from Single Family and Manufactured Housing Program pooling in
GinnieNET to the new Single Family Pool Delivery Module (SFPDM) in MyGinnieMae. This
modernized application will give the Single Family and Manufactured Housing Program Issuer
community several new capabilities, including more insight into the progress of pool
submissions through an intuitive and user-friendly interface to enhance the user
experience. SFPDM has been built to leverage the MISMO-compliant (v3.3) Pool Delivery
Dataset (PDD) for the delivery of Single Family issuance data and to align with mortgage
industry standards. The latest PDD specifications can be found on GinnieMae.gov under the
“Modernization Initiatives” page under the “SFPDM-MISMO” dropdown.
To remain compliant in Ginnie Mae’s Single Family and Manufactured Housing Programs,
Issuers must transition to SFPDM over an 18-month Adoption Period, ending approximately in
July 2023. Issuers will be required to deliver pools to SFPDM using the MISMO-compliant PDD
or by manually entering pool and loan data. Ginnie Mae has a dedicated team of data and
technical experts ready to help Issuers and associated software vendors transition to the new
MISMO-compliant PDD and SFPDM. Training sessions and materials will be held throughout
the 18-month Adoption Period to help users onboard and use SFPDM.
Initiating 18-Month Transition Period to the PDD and SFPDM
Ginnie Mae has outlined an 18-month Adoption Period that initiates with the publication of this
APM. Issuers are currently expected to begin planning, developing, and testing a PDD in the
Validation and Testing Tool (VTT) presently available in the MyGinnieMae portal. In the coming
months, a separate communication will be provided to Issuers once SFPDM is available. Once
the Issuers transition to SFPDM and start using it to submit pools, Ginnie Mae expects that the
Issuers will use the new SFPDM application exclusively, without reverting back to GinnieNET.
However, GinnieNET will remain available to Issuers during the Adoption Period as a backup
option to ensure smooth business operations as they transition at their own pace.
At the end of the 18-month Adoption Period, GinnieNET will no longer be used for Single Family
and Manufactured Housing Program pooling and only SFPDM will be available to Issuers. Only
Issuers in Ginnie Mae’s Single Family and Manufactured Housing Programs will be impacted by
this transition. A subsequent APM, along with corresponding MBS Guide Changes, will
announce the end of the transition from GinnieNET. Ginnie Mae’s SFPDM and PDD Adoption
Timeline can be found in Modernization Bulletin #10.
Ginnie Mae understands that this is a large and complex transition that affects multiple business
processes within Issuer organizations. Many Issuers have already started working on PDD
development, and we encourage each Issuer to begin working with their IT teams and software
vendors on the impacts to loan origination and investor reporting workflows. The information
your organization needs to plan for this transition can be found in the PDD Implementation Guide, its associated Appendices, and related Frequently Asked Questions. Additional
information can be found on the Modernization Initiatives webpage under the “SFPDM-MISMO”
Please note that Reperforming Loan (RG) and Extended Term (ET) Pool Types are not
currently supported by SFPDM and must continue to be submitted through GinnieNET at this
time. Ginnie Mae intends to make these pool types available in SFPDM prior to the end of the
transition from GinnieNET. More information on these pools and other upcoming SFPDM
enhancements will be available in the coming months.
Changes to Pool Attestation Workflow
As Issuers transition to pooling in SFPDM, the Attestation process will remain in GinnieNET.
Ginnie Mae has enhanced the Attestation Workflow so that Issuers must view and attest to each
HUD-11705 and HUD-11706 Form per pool. During the 18-month Adoption Period, either
GinnieNET or SFPDM-generated HUD-11705 and HUD-11706 Forms will be considered the
documents of record. Additional communications and training will be conducted on the
enhanced workflow as the SFPDM Rollout approaches.
Other Important Information
For questions regarding the transition to SFPDM and the PDD, please reach out to
Ginnie Mae’s dedicated support team at GinnieMae_MISMO_Support@hud.gov. Additionally,
you may call Ginnie Mae Customer Support at 1-833 GNMA HELP / 1-833-466-2435 and select
option 3, then option 6 for inquiries related to this transition.
In support of the goal of achieving broad economic recovery following the pandemic, the Federal Housing Administration (FHA) established the Advance Loan Modification (ALM) which is proactively offered to eligible delinquent borrowers (Mortgagee Letter 2021-15). The proactive nature of the ALM, and the timeline associated with it, make it difficult for Issuers to comply both with FHA’s requirements to offer the ALM, and Ginnie Mae’s requirements for recordation and title insurance. Therefore, Ginnie Mae is streamlining its documentation requirements for FHA’s ALM loans to eliminate the requirement for recordation and title insurance except as provided below. This guidance is applicable only to ALMs, but also applies to all ALMs, even if executed prior to the publication of this APM. All other loan modifications must meet Ginnie Mae’s existing requirements in Chapter 24, part 2, Section A(2), which includes recordation.
The Issuer remains responsible for ensuring the ALM loan retains its first lien position and remains enforceable in accordance with its terms at the time of modification, throughout its modified term, and during any bankruptcy or foreclosure proceeding. In some cases, that may require recordation, such as when the modification agreement contains assignment of leases or rents provisions.
The Issuer is required to provide the following documentation to the Document Custodian:
Document custodians will not be required to verify that the ALM is recorded, unless the loan modification agreement contains provisions for assignment of leases or rents, or title insurance is present. However, if the ALM loan modification agreement is recorded, title insurance that meets the requirements of Chapter 24, Section 2 is required. A copy of an ALM loan modification agreement will only be acceptable if it contains clear evidence of recordation.
Concurrently with this APM Ginnie Mae is updating Chapter 34 and Appendix V-01, Chapter 3 of the Mortgage-Backed Securities Guide, HUD Handbook 5500.1, REV-1 (MBS Guide) to reflect these exceptions.
The streamlined documentation requirements for ALM loans will sunset with June 1, 2023 pool issuances. ALMs in pool issuances on or after July 1, 2023, must meet Ginnie Mae’s standard requirements for recording and title insurance.
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.
Additional information on conforming loan limits for the Commonwealth of the Northern Mariana Islands may be obtained directly from FHFA. High Balance Loans are eligible for Ginnie Mae MBS subject to the restrictions detailed in Ch. 9, Part 2, § B and Ch. 24 Part 2, § A(1) of the Mortgage Backed Securities Guide, HUD Handbook 5500.3, Rev-1 (MBS Guide).
If you have any questions regarding this announcement, please contact your Account Executive in the Office of Issuer and Portfolio Management directly or at (202) 708-1535.