Freddie Mac Single-Family Seller/Servicer Guide 2401.1 — Master Systems License

(D) Except to the extent otherwise permitted by Freddie Mac in writing, to not distribute to or otherwise share any Output with, a party not otherwise licensed by Freddie Mac to access such Output, except with respect to a consumer to whom such Output relates, upon his or her request (v) Licensed Materials Regarding Licensed Materials, the Seller/Servicer shall:

(A) Not make any representation, statement or suggestion to a third party regarding any capability of any Licensed Materials that purport to be, or might reasonably be construed to be, made on behalf of Freddie Mac

(B) Not issue any press release regarding its use of the Licensed Materials, or otherwise use Freddie Mac’s name or marks in any marketing or promotional materials without the prior written consent of a duly authorized officer of Freddie Mac; and

(C) Permit Freddie Mac, from time to time upon reasonable notice, to audit facilities and systems used in conjunction with the Licensed Materials to confirm compliance with the requirements of this Master Systems License and any System-Specific License (e) System access; interface development and maintenance; Related Third Parties (i) System access The Seller/Servicer may access a System by means of a: (A) Web server hosted by or on behalf of Freddie Mac (B) System-to-system interface between the System and the Seller/Servicer’s platform which is developed and maintained by the Seller/Servicer and approved in writing by Freddie Mac; and/or (C) System interface with a Related Third Party-provided loan origination or other loan manufacturing tool or Servicing Tool (ii) Interface development and maintenance With respect to its System access under Section 2401.1(e)(i)(B), Freddie Mac may provide the Specifications to the Seller/Servicer pursuant to Section 2402.1 to facilitate the Seller/Servicer’s design, development and maintenance of the system-to-system interface with such System. With respect to its System access under Section 2401.1(e)(i)(C), Freddie Mac may have conducted limited testing on Related Third Party interfaces with loan origination or other loan manufacturing tools or Servicing Tools, and those interfaces which have been deemed to be compatible with identified Systems are listed on Freddie Mac’s website. Notwithstanding any Freddie Mac-conducted testing or website identification, and, without limiting the application of any other provision of this Master Systems License or a SystemSpecific License, Freddie Mac assumes no responsibility for, and shall bear no liability whatsoever arising out of or related to any interface identified in Sections 2401.1(e)(i)(B) or 2401.1(e)(i)(C), despite the fact that such an interface provides access to a System, or that Freddie Mac may have conducted limited testing or provided Support Services or other assistance with respect to the same. (iii) Related Third Parties As permitted under Section 2401.1(c), the Seller/Servicer may engage Related Third Parties to assist it in its furtherance of the Purpose. Freddie Mac does not endorse any Related Third Party or sanction any engagement by the Seller/Servicer of any Related Third Party. The Seller/Servicer shall maintain a separate, independent contract with each Related Third Party concerning the Seller/Servicer’s use of such party’s platform, product or service. As part of such contract, the Seller/Servicer may appoint a Related Third Party to act as the Seller/Servicer’s agent for purposes of gaining access to a System, including entering data into the System, ordering and receiving consumer credit data through the System, and obtaining Output, in each instance on behalf of its principal, the Seller/Servicer. The Seller/Servicer shall be responsible for and bear all liability arising out of or related to any act or omission of its Related Third Parties, including any act or omission that causes a Seller/Servicer to violate any applicable law and/or any provision of the Guide or other Purchase Document. Under no circumstances shall Freddie Mac assume any responsibility or bear any liability whatsoever arising out of or related to any act or omission of a Related Third Party, notwithstanding that Freddie Mac may have facilitated the relationship between the Seller/Servicer and such Related Third Party. The Seller/Servicer shall include in its separate, independent contracts with Related Third Parties provisions that (1) bind each Related Third Party to the terms and conditions of this Master Systems License and each applicable System-Specific License and (2) specifically designate Freddie Mac as an express, intended third-party beneficiary of each such contract solely for the purpose of enforcing Freddie Mac’s rights under such contract. Additionally, the Seller/Servicer shall monitor the performance of its Related Third Parties so as to ensure the compliance of each with this Master Systems License and each applicable System-Specific License. Freddie Mac may also maintain separate, independent contracts with Related Third Parties regarding their respective provision of platforms and services to other entities, including the Seller/Servicer. Freddie Mac may from time to time and in its sole discretion terminate any such contract, which termination could result in the need for the Seller/Servicer to obtain an alternate platform, product and/or service from an alternative provider. Freddie Mac will attempt to notify the Seller/Servicer of such termination, but shall have no liability arising out of or in connection with any such termination, whether or not prior notice is provided to the Seller/Servicer. (f) Authorized User registration; access management and security; requirements for Excluded Servicing Tools (i) Authorized User registration To facilitate its provision of System access to a Related Third Party for use on its behalf as provided hereunder, the Seller/Servicer may share Authorized Users’ identification codes (“User IDs”) and passwords, PIN or other access codes, including system-level access codes (“Sys-to-Sys Credentials”), together with User IDs, the “Authentication Credentials,” with such Related Third Party. In addition, Freddie Mac may provide or make available to the Seller/Servicer: ■ An electronic registration form for the provisioning of Authentication Credentials and Authorized Users (“Form”) and/or ■ Access Manager, an automated access and credential management application designed to facilitate the Seller/Servicer’s management of Authentication Credentials and its Authorized Users, which may also include one or more Forms (collectively, “Access Manager”) (ii) Access Manager The Seller/Servicer shall, and, if applicable, shall cause each Related Third Party to, specifically identify each Authorized User for the System in Access Manager. Access Manager may require the designation of one or more Authorized Users to perform administrative functions for the particular System (each, an “Administrator”) such as: ■ Identifying other Authorized Users to whom Freddie Mac may grant System(s) access ■ Receiving the Authentication Credentials from Freddie Mac; and ■ Adding or deleting Authorized Users and modifying or submitting new User IDs and completing additional Forms in accordance with the Documentation. (iii)Security and safeguarding requirements Without limiting the application of any information security or other similar requirement of a Purchase Document including, without limitation, any contained in Chapter 1302, the Seller/Servicer shall safeguard and protect all information it provides to Access Manager, as well as all Authentication Credentials and other Confidential Means of Access (as that term is defined in Section 1401.1(b)), and shall adopt security measures to prevent the loss, theft, unauthorized access, disclosure, compromise or use of any of the foregoing. Such measures shall include the maintenance of up-to-date virus detection software to protect against malware and other malicious software. As soon as practicable, and, in any event, no later than within one Business Day of an Administrator’s name change, or an employee’s or contractor’s termination, the Seller/Servicer shall either: ■ Utilize Access Manager to register the Administrator name change, or remove or otherwise delete such employee or contract worker as an Authorized User; or ■ Notify Freddie Mac of such name change or termination so that Freddie Mac may register the name change or revoke the employee’s or contractor’s access to each System (iv) Required notifications to Freddie Mac The Seller/Servicer shall notify Freddie Mac as soon as practicable and, in any event, no later than within one Business Day in the event: ■ Of any actual or suspected loss, theft or unauthorized access, disclosure, compromise or use of any System, Authentication Credential, or any other Confidential Means of Access ■ The Seller/Servicer has reason to believe that an Administrator’s access to a System, including Access Manager, is no longer secure for any reason ■ An unauthorized User has gained access to a System ■ An Authorized User has gained access to a System that he or she is not authorized to access or use; or ■ An Authorized User has used a System for purposes other than the Purpose (v) Recertification and credential management From time to time an Administrator may be required by Access Manager to engage in campaigns to recertify the authorizations and roles of Authorized Users. The Administrator shall comply with all reasonable instructions, including any provided through Access Manager, for any such campaign. The Seller/Servicer shall reset Authentication Credentials no less than once every 90 days, except with respect to Sys-to-Sys Credentials, which shall be reset no less than once every 365 days. In the event such resets do not occur, or if Authentication Credentials have not been used for a period of at least 90 days, or Sys-to-Sys Credentials have not been used for a period of at least 365 days, then, in any such event, Freddie Mac may, in its sole discretion, deactivate System access associated with any such Authentication Credential. (vi) Security best practices and responsibility Without limiting the application of any other provision of this Section 2401.1(f) or a Purchase Document, the Seller/Servicer agrees to implement and maintain industry best practices with respect to the security of, and access to, each System, including the imposition and enforcement of requirements against sharing of Authentication Credentials between and among Users, and accepts all risks and liability resulting from any failure to adopt and maintain such industry best practices. (vii) Excluded Servicing Tools The Seller/Servicer shall manage each of its Authorized Users’ access to those Excluded Servicing Tools that Freddie Mac designates from time to time in accordance with the Authorized User registration, access management, and security requirements set forth in this Section 2401.1(f). The Seller/Servicer shall not permit a Related Third Party to access an Excluded Servicing Tool unless otherwise permitted by Freddie Mac in writing (e.g., under another section of the Guide, other Purchase Document, applicable user agreement, system license or related system documentation). Until Freddie Mac designates an Excluded Servicing Tool as subject to this Section 2401.1(f), including through the issuance of a Form identifying such Excluded Servicing Tool, the Seller/Servicer must continue to follow the user access and security requirements applicable to such Excluded Servicing Tool. (g) Ownership of the Licensed Materials; rights in data (i) Ownership and confidentiality The Licensed Materials are the sole and exclusive property of Freddie Mac (or, as applicable, its third-party licensors). The Seller/Servicer acknowledges that it has no ownership or other rights or interests in the Licensed Materials, except to the extent of the rights expressly granted in this Master Systems License and any System-Specific License, and covenants that it will treat all nonpublic information and data concerning the Licensed Materials and any Support Services as strictly confidential in accordance with Section 1201.8. The Seller/Servicer will not modify, enhance, disassemble or reverse engineer any Licensed Materials in any manner or for any reason. All rights in and to copyrights, trade secrets, patents, trademarks and other rights in and to the Licensed Materials shall be the property of and remain with Freddie Mac (or, as applicable, its third-party licensors). (ii) Restrictions on use; Enhancements; and proprietary notices The Seller/Servicer agrees that Freddie Mac shall be the sole and exclusive owner of any actual or proposed changes, modifications, upgrades or enhancements in functionality, design or otherwise, to the Licensed Materials and any successor products or systems (collectively, the “Enhancements”). The Seller/Servicer hereby assigns, and agrees to assign, to Freddie Mac all rights in the Enhancements, without any recourse to the Seller/Servicer. The Seller/Servicer understands and acknowledges that Freddie Mac shall not be under any obligation to consider or implement any Enhancements it may suggest or recommend to Freddie Mac. The Seller/Servicer shall reproduce without modification on any copy of the Output, Specifications or Documentation all copyright, confidentiality and other proprietary notices included on the original version or otherwise provided or made available by the System or Freddie Mac. (iii)Use of System data The Seller/Servicer acknowledges and agrees that Freddie Mac may use, modify, reproduce and retain all data: (A) Submitted by a User to any System (B) Generated in the utilization of a System that pertains to the functionality or performance of the System; and/or (C) Necessary or useful in assisting Freddie Mac in the provision of Support Services (all such data collectively referenced in this Section 2401.1(g)(iii) as the “System Data”) for all purposes related to such System, the underlying software and models, and any actual or potential Mortgage to which such data relate, including, without limitation, for analytic, statistical, quality control and similar purposes (iv) Use of System Data or Aggregate Data Freddie Mac may provide statistical, comparative and summary information derived from the System Data (i.e., the “Aggregate Data”) to Freddie Mac’s customers and other third parties; provided, however, that except to the extent permitted or required by applicable law, Aggregate Data shall be anonymized and shall not specifically identify or be linked to any consumer. Notwithstanding the foregoing, Freddie Mac will not disclose System Data or Aggregate Data in a manner that either associates the Seller/Servicer with a particular Mortgage file, or enables the recipient of any such data to determine that the Seller/Servicer submitted such Mortgage file to the System, in either case unless: (A) Required by applicable law, a subpoena or a court order; or (B) Consented to by the Seller/Servicer. Notwithstanding anything to the contrary contained in this Master Systems License or any System-Specific License, Freddie Mac may provide System Data and Aggregate Data to: ■ FHFA ■ Any agency of the federal government ■ Any State government; or ■ As otherwise permitted by the Purchase Documents As set forth in Sections 1201.9 and 3301.1(a), and notwithstanding anything to the contrary contained in this Master Systems License or any System-Specific License, all System Data, Aggregate Data and other data and information associated with a Mortgage that is purchased or guaranteed by Freddie Mac shall be the sole and exclusive property of Freddie Mac, which it may use for any purpose including, but not limited to, such purposes set forth in this Section 2401.1(g). (h) Representations and warranties; indemnification This Master Systems License details the obligations and responsibilities of the Seller/Servicer concerning compliance with laws and representations made through data and documentation, including indemnification and warranty requirements, as outlined below: (i) General representations and warranties The Seller/Servicer acknowledges and agrees that: (A) All of the representations and warranties it is deemed to make under applicable Purchase Documents with respect to loan documentation, data and other information it provides to Freddie Mac shall apply to any such materials it or any User provides to Freddie Mac through any System, as well as to the Seller/Servicer’s use of the Licensed Materials; and (B) Freddie Mac will have all rights and remedies available to it under the Purchase Documents with respect to a breach by the Seller/Servicer of any such representation or warranty or any Seller/Servicer misrepresentation (ii) Legal compliance In addition to the provisions of Sections 2401.1(h)(i)-(iii) or any other provision of a Purchase Document pertaining to its compliance with laws including, without limitation, Section 1301.2 and Chapter 4202, the Seller/Servicer represents, warrants and agrees that it has obtained or, if applicable, will obtain, legal counsel and has developed policies, systems and procedures to ensure that its use of the Licensed Materials is, and, at all times relevant to this Master Systems License and any System-Specific License, shall remain, in full compliance with: (A) All federal, State and local laws, rules and regulations applicable to its activities in connection with which any Licensed Materials are used, including, without limitation, the Real Estate Settlement Procedures Act, the Truth in Lending Act, the Fair Credit Reporting Act, the Equal Credit Opportunity Act and the Home Mortgage Disclosure Act, and each of their implementing regulations and commentary, as applicable; and (B) All applicable laws, rules, regulations and conventions relating to data privacy, international communications and the importation and exportation of software and data The Seller/Servicer bears sole responsibility for complying with all laws, rules, regulations and conventions referenced in the preceding Section 2401.1(h)(ii), and shall not rely on the Licensed Materials in connection with its compliance efforts. The Seller/Servicer acknowledges and agrees that: (A) The Licensed Materials do not analyze compliance with laws, regulations, or ordinances, or with any requirements that may be imposed by any regulator; and (B) The Seller/Servicer’s compliance obligations shall in no event be imposed upon, assumed or shared by Freddie Mac as a result of the Seller/Servicer’s (or any Related Third Party’s) use of the Licensed Materials (iii)User and Administrator representations In addition to the provisions of Sections 2401.1(h)(i)-(ii), the Seller/Servicer further represents, warrants and agrees that: (A) Each Administrator is an officer of the Seller/Servicer or is otherwise specifically authorized by the Seller/Servicer to perform such administrative functions (B) Each User is duly authorized to act on behalf of, and has full authority to legally bind the Seller/Servicer by such User’s acts and omissions (C) Freddie Mac is entitled to rely on the truth, accuracy and completeness of all data and information submitted by each Administrator and any other User to each System, including any data and information submitted through a Form; and