|11/9/2020 - APM 20-14|
Due to the impact of the COVID-19 Pandemic National Emergency, Ginnie Mae is allowing the use of alternative audit procedures for Issuers with a fiscal year ending on or before December
31, 2020 as follows.
Chapter 3 Part 7 § A of the Mortgage-Backed Securities Guide (MBS Guide) requires Issuers to obtain and submit an independent public audit prepared in accordance with Chapter 6 of the HUD Audit Guide, which itself 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 2020 that require physical inspection and observation.
For this reason, Ginnie Mae will accept independent public audits for Issuers with a 2020 fiscal year ending on or before December 31, 2020, where the independent auditor relied on alternative procedures to meet the Issuer’s document custodian independent public audit review objectives requiring physical inspect and observation in lieu of the procedures outlined in the HUD Audit Guide.
Issuers must ensure that the independent public audit 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.
For the avoidance of doubt, this APM does not in any way change components of an Issuer’s audited financial statements to be performed by an independent public auditor with a fiscal year ending in 2020, 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.
|9/24/2020 - APM 20-13|
In support of the relief and loss mitigation options made available to borrowers affected by COVID-19, VA Circular 26-20-33 “Deferment as a COVID-19 Loss Mitigation Option for CARES Act Forbearance Cases” clarifies the circumstances under which a deferment may be exercised as a loss mitigation option after a forbearance period. In light of this circular, Ginnie Mae is hereby reminding Issuers that existing MBS Program requirements may impact the pooling eligibility of loans where a deferment is exercised as a loss mitigation option or as part of an informal workout agreement.
Considerations for Pooled Loans
For any pooled loan, the deferment loss mitigation option can be exercised without repurchasing the loan from the pool. Repurchasing the loan from the pool prior to exercising the deferment will subject the loan to existing re-pooling restrictions. Once a deferment is exercised, Ginnie Mae allows the Issuer to treat the loan as current for investor accounting as well as pool and loan reporting purposes. Any new delinquency that occurs after the deferment must be treated as a regular delinquency going forward.
Considerations for Non-Pooled Loans
Any loan that is not pooled at the time the deferment option is exercised becomes a Re-Performing Loan within the meaning of Chapter 18 of the MBS Guide and is subject to the restrictions announced in APM 20-07. Please note that Ginnie Mae’s MBS Program pooling eligibility requirements prohibit Issuers from delivering mortgages that combine the deferment option with a loan modification. For example, a loan modification agreement that reflects the deferment as a lump sum payment due at maturity is not considered a level-payment loan and is therefore ineligible for inclusion in any Ginnie Mae single-family MBS.
Chapter 24 Part 2 § A (2) has been modified in accordance with this memorandum and is effective immediately. If you have further questions, please contact your Account Executive in the Office of Issuer and Portfolio Management directly.
|9/21/2020 - APM 20-12|
In July 2017, the United Kingdom’s Financial Conduct Authority (FCA) announced that it would cease requiring the submission of quotes supporting the London Interbank Offered Rate (LIBOR) by December 31, 2021. As a result, it is unclear whether LIBOR will continue to be published after that date. Ginnie Mae has worked closely with key stakeholders, including other federal agencies, to identify and implement a course of action that transitions the Ginnie Mae program away from LIBOR while minimizing disruption to the MBS Program and its participants. To that end, Ginnie Mae is announcing restrictions to the pooling eligibility of LIBOR-based adjustable rate loans as detailed below.
Restrictions on LIBOR-Based Single-Family Forward Adjustable Rate Mortgages (ARM)
Effective with security issuances dated on or after January 1, 2021, Ginnie Mae will stop accepting the delivery of loans for securitization into any pool type comprised of loans with any interest term based on LIBOR, including pool types “C RL”, “C TL”, “C FL”, “C FB”, “C SL”, “C XL”, “M RL”, “M QL”, “M TL”, “M FL”, “M FB”, “M SL”, and “M XL”. Consequently, all single-family forward ARM loans that rely on LIBOR, including LIBOR-based ARM-to-ARM loan modifications and re-performing LIBOR-based ARMs, will become ineligible for pooling into any Ginnie Mae I or Ginnie Mae II security as of the effective date.
Restrictions on LIBOR-Based Adjustable Rate Reverse Mortgages [HECM/HMBS]
Effective with HMBS issuances dated on or after January 1, 2021, Ginnie Mae will restrict the eligibility of adjustable rate Home Equity Conversion Mortgage loans for securitization into any HMBS pool type that relies on LIBOR, including pool types “C AL” and “C ML”. LIBOR-Based adjustable rate HECM loans that are not securitized as of January 1, 2021, will be ineligible for pooling without regard to their date of origination or the date in which the corresponding FHA case number was assigned. Participations associated with a HECM loan that is backing HMBS with an issuance date on or before December 1, 2020, will continue to be eligible for securitization without restriction until further notice.
Chapter 26 and Chapter 35 of the MBS Guide, 5500.3, Rev-1, have been amended in accordance with this memorandum.
Forward and reverse adjustable rate mortgage loans that rely on the Constant Maturity Treasury (CMT) index continue to be eligible without restriction.
Ginnie Mae is ready to facilitate the creation of Single-Class MBS collateralized by pools containing Secured Overnight Financing Rate (SOFR) ARM and HECM loans when those loans become authorized by the insuring agencies.
Please contact your Ginnie Mae Account Executive in the Office of Issuer and Portfolio Management directly or at (202) 708-1535 with any questions you may have.
|7/29/2020 - APM 20-11|
Ginnie Mae continues to modernize its Securitization Platform technology, processes, and related policies to provide increased transparency and improved service delivery to its Issuers. To support this goal, in January 2020, Ginnie Mae launched the MyGinnieMae (MGM) portal, a comprehensive platform that integrates functional and technological capabilities into a common infrastructure.
The MGM portal provides enhanced security and a single entry point to all approved applications for individual users, as well as a seamless user registration and access request process, for both the user and the approving authority. With the adoption of MGM, one account and one single username and password will provide users access to all systems, applications and Organization IDs/Issuer IDs. MGM houses existing Ginnie Mae legacy systems (i.e. GMEP 1.0, GinnieNET), modernized portal applications (i.e. MFPDM, AMC), and resources that boost efficiency for our business partners.
Requisite MGM Roles and Responsibilities
Organization Administrators (formerly known as Security Officers and Enrollment Administrators). Organization Administrators (OAs) have the system authority to invite end users to register for an MGM account, approve user registration, initiate access request via functional role assignment to user, and approve the access request within their organizations. To register for access to the Ginnie Mae Systems, including the MGM and systems and applications contained therein, multiple OAs will be required to complete the registration and access workflows for onboarding users into MGM. Each OA for any Ginnie Mae Issuer must be listed as an authorized signatory in the organization’s form HUD-11702. OAs for Document Custodians are not subject to the HUD-11702 requirement. However, please note that Document Custodians should only assign individuals who are officers or have managerial and oversight responsibility for custodial operations as OAs. For details regarding the new OA adding process, please see revised Appendix III-29 that is attached to this APM.
Please note that separation of duties guidelines within the registration and access request workflows prohibit the same OAs from initiating a registration and approving that same registration and from initiating request access via functional role assignment and approving such requests. For each Issuer, Ginnie Mae requires a minimum of three OAs, but we strongly encourage you to have more than the minimum as a safeguard against operational challenges.
End Users. End Users include Ginnie Mae employees, business partners, program participants and contractors who will require access to the business applications and information within the Portal, including various self-service functions. A full list of the functional roles available to external end users may be found here.
New Requirements for Users of Ginnie Mae Systems
Effective September 1, 2020, all Issuers must meet the following two requirements.
- Each organization must have a minimum of three OAs with active MGM credentials.
- Users of all Ginnie Mae Systems, including the Ginnie Mae Enterprise Portal and GinnieNET, are required to have active credentials to access MGM in order to be able to transact on Ginnie Mae Systems.
Effective December 1, 2020, MGM will become the sole avenue to access all Ginnie Mae systems. After December 1, 2020, Issuers will no longer be able to access GinnieNET or GMEP directly through their Uniform Resource Locator (URL) web address.
For more information and resources, please visit the Modernization Page on the Ginnie Mae website.
For general questions about the MGM portal or its release activities, please contact CXG@hud.gov or your Account Executive in the Office of Issuer and Portfolio Management directly.
|7/16/2020 - APM 20-10|
In June 2018, Ginnie Mae announced it would start developing and implementing the policy, technology, and operational capabilities necessary to accept electronic promissory notes and other digitized loan files as collateral for Ginnie Mae securities (Digital Collateral). To that end, Ginnie Mae collaborated extensively with industry stakeholders in developing the policies and processes governing the securitization of Digital Collateral in the government-backed industry segment. Ginnie Mae also recognizes that allowing Digital Collateral for its MBS is necessary more than ever as a key strategic initiative that is responsive to the impacts of the COVID-19 pandemic. Today, Ginnie Mae is announcing the launch of the initial phase of its Digital Collateral Program.
As part of this initial phase, Issuers may apply to participate as eIssuers and begin securitizing government-backed mortgages comprised of Digital Collateral with Ginnie Mae approval. The requirements and processes that govern participation in the Digital Collateral Program are detailed in the Digital Collateral Program Guide (eGuide), Appendix V-07 of the MBS Guide. Ginnie Mae will work closely with approved eIssuers to identify MBS Program updates that may be needed to achieve greater industry adoption of eMortgages and instruct subsequent phases of its Digital Collateral Program.
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. Both the eIssuer Application to Participate in the Digital Collateral Program and the eCustodian Application to Participate in the Digital Collateral Program have been published as Appendix V-08 and Appendix V-09 of the MBS Guide, respectively. Interested Issuers and Document Custodians may submit their applications individually or jointly. All applications to participate in this phase of the Digital Collateral Program must be submitted to Ginnie Mae via email at DCPA@hud.gov no later than August 15, 2020.
Ginnie Mae will begin reviewing applications on a rolling basis beginning on July 20, 2020. If approved, 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 eMortgage Issuance Authority, which will govern and limit the number of eMortgages (regardless of the principal balance associated with each loan) that may be securitized by that eIssuer during the initial phase of the Digital Collateral Program. Please note that there will not be costs or fees associated with the provision of eMortgage Issuance Authority.
The Digital Collateral Program Guide, Appendix V-07, the eIssuer Application to Participate in the Digital Collateral Program, Appendix V-08, and the eCustodian Application to Participate in the Digital Collateral Program, Appendix V-09 of the MBS Guide have been published and are effective immediately. Please submit any questions or concerns you may have about this announcement to DCPA@hud.gov.