Freddie Mac Single-Family Seller/Servicer Guide 3201.2 — Fraud and other Suspicious Activity reporting requirements

This section contains requirements related to: ■ Procedures for detecting, identifying and reporting fraud, suspected fraud and Suspicious Activity ■ Requirement to report fraud, suspected fraud and Suspicious Activity ■ Required reporting timelines ■ Use of the Tip Referral Tool ■ Fraud types and trends The Seller/Servicer must take measures to ensure that Mortgages sold to, or serviced for, Freddie Mac are free from any fraud, suspected fraud, Suspicious Activity, potential Suspicious Activity, misrepresentation, misstatement or omission, and the Seller/Servicer must report impacted Mortgage(s) in accordance with the requirements outlined in this section. Mortgages involving any misstatement, misrepresentation or omission by the Borrower or any other party in the Mortgage and/or real estate transaction are not eligible for sale to Freddie Mac.

(a) Procedures for detecting, identifying and reporting fraud, suspected fraud and Suspicious Activity The Seller/Servicer must have a documented program with procedures for detecting, identifying and reporting fraud, suspected fraud and other Suspicious Activity in connection with a Mortgage sold to, or serviced for, Freddie Mac and discovered at any time, including, but not limited to, during origination, quality control reviews, Servicing activities or loss mitigation efforts. Before reporting to Freddie Mac, a Seller/Servicer must perform due diligence to establish whether there is a reasonable basis to believe that fraud, suspected fraud or Suspicious Activity may have occurred.

(b) Requirement to report fraud, suspected fraud and Suspicious Activity The Seller/Servicer must report to Freddie Mac when the Seller/Servicer has a reasonable belief that one of the following is occurring or has occurred during the origination, sale or Servicing of a Mortgage (including, but not limited to, any loss mitigation activity) regardless of whether (i) it had an impact on the eligibility of the Mortgage for sale to Freddie Mac or (ii) there was a breach of the Guide: ■ Any misrepresentation, misstatement or omission related to the Mortgage, the Borrower, the Mortgaged Premises or underlying real estate transaction ■ Involvement of a person or entity on the Freddie Mac Exclusionary List is involved or was involved in the origination, sale or Servicing of the Mortgage or the underlying real estate transaction in violation of Section 3101.1. (Note: For reporting the discovery of any possible breach of warranties regarding the Exclusionary List, refer to instructions in Section 3101.1(c)(i).) ■ Involvement of a person or entity on the FHFA Suspended Counterparty Program list in the origination, sale or Servicing of the Mortgage or the related real estate transactions in violation of Section 3101.2 ■ Termination or denial of mortgage insurance based on fraud

(c) Required reporting timelines The Seller/Servicer must report any reportable activity as defined in Section 3201.2(a) through Freddie Mac’s Tip Referral Tool, accessible via Freddie Mac Gateway, within the time frames outlined in the table below. Required reporting timelines Required time frame for reporting Discovery of reportable activity Within 30 days ■ Reportable activity discovered during a quality control review: The Seller/Servicer must notify Freddie Mac within 30 days after the date the quality control results are reported in writing to the Seller/Servicer’s Senior Management, in accordance with the reporting requirements in Section 3402.3(b) ■ Reportable activity discovered through any means other than a quality control review: The Seller/Servicer must notify Freddie Mac within 30 days after discovery Immediate (within one Business Day) In addition to the above 30-day reporting requirements, the Seller/Servicer must notify Freddie Mac within one Business Day after: ■ Becoming aware of theft of custodial funds, lack of collateral, non-remittance of pay-off funds or multiple deliveries of the same Mortgage ■ Determining there is a substantial likelihood that the fraud, suspected fraud or other Suspicious Activity will receive significant public exposure or publicity ■ Receiving notification of the entry of a civil judgment, guilty plea or criminal conviction indicating lack of integrity and relating to a participant in a Mortgage or the underlying real estate transaction or relating to a board member, officer, employee or contractor of the Seller/Servicer ■ Receiving notification from law enforcement or another governmental authority that such authority is conducting an investigation or prosecution of fraud relating to Mortgages owned by, or serviced for, Freddie Mac or relating to a board member, officer, employee or contractor of the Seller/Servicer ■ Identifying a possible fraud scheme or pattern of Suspicious Activity involving (i) more than five Mortgages sold to, or serviced for, Freddie Mac or (ii) Mortgages sold Required reporting timelines Required time frame for reporting Discovery of reportable activity to, or serviced for, Freddie Mac with an aggregate UPB of at least $1 million ■ Identifying actual or possible terrorist financing or ongoing or possible money laundering schemes or activity Seller/Servicers are not required to, and must not, disclose to Freddie Mac any Financial Crimes Enforcement Network Suspicious Activity Reports (SARs) or draft SARs, documents or information revealing the existence of a SAR or indicating whether a SAR has been filed, or where disclosure of Suspicious Activity would otherwise be prohibited by law.

(d) Use of the Tip Referral Tool Seller/Servicers must report all Mortgage fraud, suspected Mortgage fraud and other Suspicious Activity using the Tip Referral Tool. Referrals made through the Tip Referral Tool must include: ■ Freddie Mac loan number ■ Property address ■ Mortgage fraud/Suspicious Activity type and category ■ Parties involved ■ Supporting documentation ■ A detailed narrative description of the activity, including why it has been deemed suspicious or fraudulent. (Seller/Servicers should not include protected personal information, such as Social Security numbers, in the narrative description.) ■ Any other required information as identified in the Tip Referral Tool

(e) Fraud types and trends In connection with the Seller/Servicer’s fraud tracking procedures required in Section 3201.3(b), the Seller/Servicer must maintain and, upon request, provide Freddie Mac with aggregated records and reporting detailing fraud types and trends, including the number of fraud cases and positive Exclusionary List hits.