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Meeting Delivery Requirements for FHFA-Required Loan-Level Origination Data

We continue to work with the Federal Housing Finance Agency (FHFA) to implement FHFA's new loan-level origination data requirements. Specifically, we will be required to collect the following unique identifiers for mortgages with application dates on or after July 1, 2010:

  • Loan originator identifier – The loan originator's unique identifier as assigned by the Nationwide Mortgage Licensing System (NMLS) and required based on Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (S.A.F.E. Mortgage Licensing Act)
  • Loan origination company identifier – The loan origination company's identifier as assigned by NMLS. The loan origination company is the company the loan originator is employed by or is representing as an independent contractor.
  • Appraiser's state license number – The field appraiser's state license number (or state certification number in the absence of a license number) issued by the state in which the subject property is located.
  • Supervisory appraiser's state license number/certification number – The supervisory appraiser's state license number (or state certification number in the absence of a license number) issued by the state in which the subject property is located.

Delivering the Unique Identifiers

We have updated Form 11, Mortgage Submission Schedule, and Form 13SF, Mortgage Submission Voucher, to enable you to include the following data in the appropriate fields:

  • The loan originator identifier and loan origination company identifier are up to 12 numeric characters.
  • The appraiser's state license number and the supervisory appraiser's state license number, if applicable, are up to 21 alphanumeric characters. In cases where an automated valuation model is permitted and used, the word "Other" must be delivered in the appraiser's state license number field.

In addition to updating Form 11 and Form 13SF, we have updated Form 65, Uniform Residential Loan Application, to include fields for the loan originator identifier and the loan origination company identifier. This form is available for immediate use. However, you are required to use this revised form for mortgages with application dates on or after July 1, 2010.

Selling System Enhancements

On December 14, 2009, we updated the selling system to allow you to begin delivering the four unique identifiers for all mortgages with application dates on or after July 1, 2010. Specifically, there are new fields for these data elements on the "Create Loan" and "Modify Loans" screens in the system. We encourage you to deliver the unique identifiers as soon as you have them available and your systems have been updated.

State Requirements for Obtaining a Loan Originator and Loan Origination Company Identifier

The Conference of State Bank Supervisors (CSBS) can provide guidance on obtaining unique identifiers through NMLS. If you are originating loans in a state that requires you to obtain unique identifiers, you must provide the identifiers on Form 65 and deliver the identifiers on Form 11 or Form 13SF to Freddie Mac for mortgages with application dates on or after July 1, 2010.

If you are originating loans in a state that has not yet required loan originators or loan origination companies to obtain identifiers, you will not be required to deliver this information. Once the state requires loan originators and loan origination companies to obtain unique identifiers, you must deliver this data for mortgages with application dates on and after the date the requirement becomes effective.

Appraisal numbers must be delivered regardless of whether state law requires you to have a loan originator identifier or loan origination company identifier.

Federal Requirements for Obtaining a Loan Originator and Loan Origination Company Identifier

The Federal banking agencies and the Farm Credit Administration are expected to publish guidance for institutions under their supervision on obtaining a loan originator identifier and loan origination company identifier. If your federal regulator has not yet required your institution to register a loan originator or loan origination company identifier, you will not be required to provide the identifiers on Form 65 or deliver this information on Form 11 or Form 13SF. Once the loan originator and loan origination company identifiers are required, you must deliver this data for mortgages with application dates on or after the date the requirement becomes effective.

Appraisal numbers must be delivered regardless of whether you have received federal agency guidance that requires you to have a loan originator identifier or loan origination company identifier.

Updating Your Loan Origination System (LOS) to Deliver the Four Data Elements

  • If you use a LOS vendor, please contact your vendor to find out when the system build to include the required updates to Form 11 and Form 13SF will be available.
  • If your organization designs its own system interface, please contact 800-FREDDIE or your selling system representative for details on technical specifications for updating your LOS system.

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