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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
8/4/2022 - APM 22-08

To ensure that Mortgage-Backed Securities program requirements appropriately reflect the risk associated with different Issuer profiles, Ginnie Mae is revising the Institution-wide Capital Requirements in the Mortgage-Backed Securities Guide, 5500.3 Rev-1 (“MBS Guide”), Chapters 2 and 3 for financial institutions seeking approval as Ginnie Mae Single-Family, Multifamily, Manufactured Home and Home Equity Conversion Mortgage MBS (“HMBS”) Issuers (“Applicants”) as well as existing Ginnie Mae Single-Family, Multifamily, Manufactured Home and HMBS Issuers (“Issuers”). In addition, Ginnie Mae is revising Program Risk Parameters in Chapter 3 for all Issuers. All the changes announced in this APM will be effective beginning with Issuer fiscal year end December 31, 2022, and thereafter.

Revised Institution-Wide Capital Requirements

  • Applicants and Issuers that are subject to federal regulation by the Board of Governors of the Federal Reserve System (“the Fed”), Federal Deposit Insurance Corporation (“FDIC”), Office of the Comptroller of the Currency (“OCC”), National Credit Union Administration (“NCUA”) or Federal Housing Finance Agency (“FHFA”) must meet all regulatory capital requirements to be considered at least “well-capitalized” or its equivalent. Applicants and Issuers in this category include but are not limited to bank holding companies (“BHCs”), banks, wholly owned subsidiaries of BHCs that are consolidated for purposes of regulatory oversight, thrifts, savings and loan holding companies, credit unions and Federal Home Loan Banks. Non-depository mortgage companies that are not subject to federal prudential regulation are not included in this category. 
  • Applicants and Issuers that are instrumentalities of a U.S. state or territory, including but not limited to State Housing Finance Authorities or Agencies, are not subject to institution-wide capital requirements.

Applicants and Issuers that are not covered by the requirements for financial institutions described above (see MBS Guide Chapter 2, Part 9, §§ B(2)(a) and (b) for Applicants, and MBS Guide Chapter 3, Part 8, §§ A (3) (a) and (b) for Issuers) must continue to maintain a “Leverage Ratio” of at least 6% as set forth in MBS Guide Chapter 2 Part 9 §§ B (2) (c) for Applicants and MBS Guide Chapter 3, Part 8, §A (3) (c) for Issuers. For purposes of calculating the Leverage Ratio (Total Adjusted Net Worth divided by Total Assets), Total Assets do not include Ginnie Mae Loans Eligible for Repurchase (GMLERs). GMLERs are delinquent loans that are eligible to be bought out of a pool but that have not yet been bought out, consistent with MBS Guide Chapter 18, Part 3 § B (1). GMLERs are not applicable to the HMBS program.

Revised Program Risk Parameters

If an approved Issuer is reliant on support from a corporate parent to maintain its compliance with Ginnie Mae requirements, as determined by factors including the Issuer’s financial history, the Issuer’s current financial standing, and corporate family or affiliate matters, the corporate parent’s financial standing should be such that it could meet the financial requirements as a Ginnie Mae Issuer. If the information regarding the corporate parent’s financial standing is not publicly available, the corporate parent may be required to provide it to Ginnie Mae no more frequently than on a quarterly basis. For more information, see MBS Guide Chapter 3, Part 21 § B (1) (e).

Effective December 31, 2022, Chapters 2 and 3 of the MBS Guide will be amended in accordance with this Memorandum. Chapter 6 of the HUD Consolidated Audit Guide (“Audit Guide”) will be updated to direct independent auditors to the MBS Guide for the current Institution-wide Capital Requirements for Applicants and Issuers. Until the Audit Guide update takes place, the requirements in the MBS guide supersede the requirements in the Audit Guide if the requirements in these two guidance documents conflict.

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

6/17/2022 - APM 22-07

Ginnie Mae initiated a pilot Digital Collateral Program (DCP) in July of 2020. During the pilot, approved participants (“eIssuers”) securitized over $8 billion of Ginnie Mae MBS backed by digital notes (“eNotes”). The DCP pilot was successful operationally and affirmed Ginnie Mae’s belief that providing for digitalization of the collateral underlying guaranteed securities provides greater efficiencies and security for homeowners and program participants. Ginnie Mae is therefore opening the program to new applicants beginning June 20th, 2022.

All active Ginnie Mae Issuers in good standing may apply to participate as eIssuers that securitize government-backed mortgages comprised of eNotes. The eligibility requirements, procedures for application, and participation requirements for the DCP for both eIssuers and eCustodians are detailed in the Digital Collateral Program Guide (eGuide), Appendix V-07 of the Mortgage Backed Securities Guide, HUD Handbook 5500.1, Rev.3 (MBS Guide). Both the eIssuer Application to Participate in the DCP and the eCustodian Application to Participate in the DCP are published as Appendix V-08 and Appendix V-09 of the MBS Guide, respectively, and are available on the Ginnie Mae website.

Please note that all Issuers seeking approval, will need to have an established relationship, evidenced by a duly executed Form HUD-11715 Master Custodial Agreement, with a Document Custodian that is also approved by Ginnie Mae to serve as an eCustodian. Interested Issuers and Document Custodians may submit their applications individually or jointly. All applications to participate in the Digital Collateral Program must be submitted to Ginnie Mae via email at DCPA@hud.gov -- no hard copy submissions will be accepted.

Ginnie Mae will begin reviewing applications on a rolling basis beginning on June 21, 2022. If applicants meet the eligibility and application requirements, they will initially be granted conditional approval. At that time, eIssuers and their eCustodian will need to complete a series of test eNote transactions with Ginnie Mae. Upon successful completion of the test transactions, Ginnie Mae will grant, in writing, full approval to participate in the DCP, along with eMortgage Issuance Authority.

The Digital Collateral Program Guide, Appendix V-07, was updated on May 23, 2022. Please ensure that you are reviewing the May 2022 release of the eGuide for full eligibility and participation requirements. All questions or concerns about the DCP or this announcement may be sent to DCPA@hud.gov.

If you have further questions, please contact your Account Executive in the Office of Issuer and Portfolio Management directly, send an email to DCPA@hud.gov​.

6/16/2022 - APM 22-06

Due to the continuing impact of the COVID-19 Pandemic National Emergency, Ginnie Mae is extending the 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” and extended in the APM 21-08: “Extension of Permitting Alternative Procedures for Certain Aspects Issuer Annual Audit Report”​ for Issuers with a fiscal year ending on or before September 30, 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 September 30, 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 September 30, 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 September 30, 2022, nor does it alter any other requirements not expressly addressed by this memorandum. The temporary flexibilities extended in this APM are expected to be discontinued as soon as practicable for Issuers whose fiscal years end beyond September 30, 2022. 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.

6/16/2022 - APM 22-05
Due to the continuing impact of the COVID-19 Pandemic National Emergency on forbearance levels and delinquency rates, Ginnie Mae is continuing the exemptions that were originally announced in APM 20-06: “Treatment of Mortgage Delinquency Ratios for Issuers Affected by COVID-19", and most recently extended in APM 21-04: “Extension of Temporary Relief from the Acceptable Delinquency Threshold requirement”​, from July 31, 2022 through January 31, 2023 (December 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 January 31, 2023, 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.

5/23/2022 - APM 22-04

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.

Other Changes

  • ​Updates to prohibit eCustodians from using an eIssuer’s eVault. Please see “eVaults by Third Parties” (2640.00), “General Requirements for the Receipt and storage of eNotes” (5100), eNote (5330.03), and “Transfer of Issuer Responsibility that also Require a Transfer of Custodial Responsibility” (6440.00) in the eGuide.
  • Included Reversal transactions of Loan Modifications, Assumptions, and Deactivations as required eServicing functions. Please see “eServicing Requirements” (2170.00) in the eGuide,
  • Revised procedures for reviewing the MERS® eRegistry Master Servicer and Subservicer fields. Please see “eNote” (5330.03) in the eGuide.
  • Removed the requirement that eIssuer makes available a certified printed copy of the original eNote to the Document Custodian when delivering an eNote with a loan modification agreement. Please see “Securitization of eMortgage Loan Modifications” (6220.03) in the eGuide.
  • Included the requirement that an eCustodian notify Ginnie Mae and the eIssuer in the event of identified system deficiencies. Please see “Required Notifications Related to System Deficiencies” (7100.00) 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.


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