Loan Repurchase and Rescission Policy Manual

Loan repurchase requests to lenders have increased in recent years, highlighting the need for an improved approach to deliver loans that meet industry standards for quality and compliance. The pushback from parties, including Government Servicing Entities (GSEs) such as Fannie Mae and Freddie Mac, began in earnest in the second half of 2009. In addition to Fannie Mae and Freddie Mac, the pushback is fueled by demands from private investors, mortgage insurers, and mono-line financial guarantors. These companies are looking to limit their own losses from defaulted mortgages through loan put-backs to originators and also by denying claims on mortgage insurance for issues ranging from eligibility, omission of a material fact, or fraud.


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Policy Manual
Loan Repurchase and Rescission
Section Title Priority Action
1.1 Goals and Objectives Mandatory Review Include the point of view or culture of your organization in this section, if applicable.
1.2 Required Review Mandatory Review Be sure this accurately reflects your company’s annual policy review process.
2.1 Quality Control Program Optional Enhancement Consider revising this to reflect and reference the actual quality control program in place.
2.2 Internal Controls Mandatory Review Include or reference related procedures in this section.
3 Staff and Training Mandatory Review Include the means by which your organization provides and tracks required training.
5 Transactional Considerations Mandatory Review Timeframes and tolerances reflected within this section are general industry recommendations. You should update this, as required, to reflect your organization’s operations.
7 Repurchase Requests and Rebuttal Process Recommended Best Practice Providing a high level overview of the rebuttal process by topic, this section offers many opportunities for expansion with your specific procedures. Consider detailing steps to be followed or appending checklists that aid in the process.
9 Loss Mitigation, Valuation and Indemnity Optional Enhancement It would be appropriate in this section to cross-reference to your existing Loss Mitigation Policy.
10 Servicing Optional Enhancement Seller servicers may wish to reference their existing Servicing policy here.