Freddie Mac Single-Family Seller/Servicer Guide 9101.2 — Evaluation requirements and appeals process in response to the First Complete Borrower Response Package

This section describes the requirements a Servicer must undertake to facilitate an appeals process when the Borrower is denied a Trial Period Plan based on the Servicer’s evaluation of the First Complete Borrower Response Package. The appeals process described in this section does not apply to evaluation decisions that are offered based on a review of an incomplete or no Borrower Response Package. This section contains requirements related to: ■ Evaluation timing and communication to Borrower ■ Managing the Borrower’s response to an evaluation decision ■ Borrower acceptance of an original offer after an appeal decision ■ Trial Period payment due date ■ Document retention

(a) Evaluation timing and communication to Borrower Within five days of an evaluation decision, but no later than 30 days following receipt of the First Complete Borrower Response Package, the Servicer must provide the appropriate Borrower Evaluation Notice as set forth in Section 9101.2(a). If the Servicer receives a complete Borrower Response Package 90 or more days before a scheduled foreclosure sale date or prior to the sale date being set, the Servicer must provide the appropriate Borrower Evaluation Notice, which informs the Borrower of: ■ The option to either accept or reject an offer of an alternative to foreclosure and the additional option to appeal within 14 days of the date of the evaluation notice ■ The right to accept an offer of an alternative to foreclosure and simultaneously appeal a denial of a Trial Period Plan ■ The right to accept any offer of an alternative to foreclosure for which the Borrower is approved as a result of the appeal or to accept or indicate an intent to accept any original offer of an alternative to foreclosure, which will still be available as an option up to 14 days after the appeal decision has been sent to the Borrower ■ Any determination of ineligibility for the Freddie Mac Flex Modification® upon review of a complete Borrower Response Package; and ■ The right to appeal a denial of a Trial Period Plan and the process and timeline, including: ❑ The address to which the Borrower must submit the appeal, which must be in writing and must include the Borrower’s name, property address and Mortgage loan number ❑ A statement that the Servicer’s appeal determination is not subject to further appeal ❑ A statement that the foreclosure process will be suspended during the appeals process The Servicer must send the Borrower the appropriate Borrower Evaluation Notice communicating the decision with one of the following outcomes: ■ Offer reinstatement ■ Offer a repayment plan (with or without a partial reinstatement offer)* ■ Offer a forbearance plan ■ Offer a Trial Period Plan as set forth in Chapter 9206 (e.g., Freddie Mac Flex Modification) ■ Offer a short sale as set forth in Chapter 9208 (i.e., Freddie Mac Standard Short Sale) ■ Offer a deed-in-lieu of foreclosure as set forth in Chapter 9209 (i.e., Freddie Mac Standard Deed-in-Lieu of Foreclosure) ■ Non-Approval, Ineligible for Mortgage Assistance – Mortgage is Current ■ Non-Approval, Ineligible for Mortgage Assistance – Mortgage is Delinquent Model letters describing each of these responses are included in Exhibit 93, Evaluation Notices. Use of the model letters is optional; however, they illustrate the level of specificity that is deemed to be in compliance with the requirements of this section. The model letters may be altered at the Servicer’s discretion to meet the requirements of this chapter and Chapters 8404, 9203, 9206, 9208 and 9209 and must be altered by the Servicer as necessary to comply with applicable federal, State and local law. Servicers must ensure that the model letters are revised as necessary to include denial reasons and information about the Borrower’s right to appeal the Servicer’s decision when the Borrower is denied a Trial Period Plan based on an evaluation of the First Complete Borrower Response Package. Exhibit 93 includes a list of denial reasons for use with the model letters. As a reminder, impermissible denial reasons include, but are not limited to, the following: ■ Full lender recourse or indemnification – In situations where the Servicer chose not to repurchase the Mortgage from Freddie Mac or, in the case of indemnification, chose not to modify the Mortgage, the Servicer must disclose the reason it will not modify the Mortgage, which must be based on its own requirements. Servicers are reminded that they may repurchase any Mortgage subject to full lender recourse or indemnification in accordance with the requirements set forth in Bulletin 2012-10 and may choose to modify a Mortgage subject to indemnification in accordance with the requirements in Bulletins 2016-5 and 2021-14. ■ FHA, RHS or VA Mortgage – The Servicer must determine eligibility for a loan modification under applicable agency requirements A Servicer may combine the relevant contents of the Borrower Evaluation Notice for a reinstatement offer with the contents of the notice for a repayment plan offer when offering the Borrower a partial reinstatement of the Mortgage coupled with a repayment plan in accordance with the requirements of Chapter 9203. Furthermore, if the offer for a foreclosure alternative is made 37 days or less prior to a scheduled foreclosure sale as set forth in Section 9301.7(a), a Borrower’s intent to accept the offer may not be communicated verbally but must be in writing. Therefore, the Servicer must delete the reference “at [SERVICER PHONE NUMBER] or” and otherwise amend the Evaluation Notice as appropriate. Servicers must comply with applicable law when obtaining a complete Borrower Response Package. Additional requirements related to forbearance, modifications, short sales and deedsin-lieu of foreclosure Topic Guide location Servicing Mortgages impacted by a disaster Reinstatements and relief options Freddie Mac workout options Modifications Freddie Mac Standard Short Sale Freddie Mac Standard Deed-in-Lieu of Foreclosure

(b) Managing the Borrower’s response to an evaluation decision The Servicer may only accept and review a valid appeal of the denial of any Trial Period Plan based on the evaluation of the First Complete Borrower Response Package within 14 days from the date of the Servicer’s offer or denial notice. A valid appeal requires the Borrower to provide the following: ■ An appeal of the denial for a Trial Period Plan in writing with his or her name ■ Property address; and ■ Mortgage loan number Any Borrower appeal must be reviewed by different Servicer personnel than those responsible for the initial evaluation decision. The Borrower may, but is not required to, submit any supporting documentation at the time he or she notifies the Servicer of an appeal. Servicers must adhere to the following guidelines regarding the submission and evaluation of supporting documentation: ■ If the Borrower submits supporting documentation within 14 days of the date the Servicer sent the Borrower Evaluation Notice, the Servicer must evaluate the supporting documentation during the appeal review ■ If documentation presented causes the Borrower to no longer be eligible for an original alternative to foreclosure, then the Servicer must inform the Borrower that the Borrower is no longer eligible for that original alternative to foreclosure. The model clauses in Exhibit 93 include language that conditions the offers on continuing eligibility based on information known to the Servicer. ■ If the Borrower submits new information or documentation after the 14-day Borrower response period, the new information or documentation is not subject to the right of appeal process in this section and must be evaluated in accordance with Section 9201.2. However, the Servicer may consider such new information as part of the appeal process within the time frames described in this section if it is feasible to do so. ■ The Servicer must have a policy applied consistently to all Mortgages to determine whether any new information received after the appeal decision is a material change in circumstance that warrants another review. Servicers must treat any new information and documentation received after the 14-day Borrower response period as a new Borrower Response Package. ■ If the Servicer concludes that a review of the updated complete Borrower Response Package is warranted, the Servicer must provide a decision to the Borrower within 30 days of receipt of the new information as provided under Section 9102.5(c) ■ The Servicer must provide the Borrower with an appeal decision notice within 30 days of receipt of the Borrower’s appeal. The appeal decision must include the original offer, if any, provided the Borrower remains eligible for the original offer. ■ If the Borrower is eligible for a Trial Period Plan with different terms or that was not part of the original offer, the Servicer must provide the new Trial Period Plan to that Borrower. The Servicer must provide the Borrower with 14 days (from the date the Servicer sends the appeal decision notice) to accept either the original offer, if the Borrower remains eligible, or indicate an intent to accept the new Trial Period Plan offer. ■ If a payment is required under an offer, then the Servicer must follow the relevant requirements under Chapters 9203, 9205, 9206, 9208 and 9209 concerning legal acceptance for that offer. However, the Servicer must continue to suspend foreclosure until the deadline for submission of the first payment under that offer has passed.

(c) Borrower acceptance of an original offer after an appeal decision If the Borrower accepts the original offer after receiving the appeal decision and remains eligible for the original offer, the Servicer must: ■ Reissue the original offer extended in the initial Borrower Evaluation Notice ■ Reissue the original offer with a new first Trial Period Plan due date, if applicable, and ❑ Inform the Borrower that unpaid interest and other amounts that continue to accrue during the appeal, such as Escrows for taxes and insurance, will result in the Mortgage becoming more delinquent; and ❑ Inform the Borrower that if the Trial Period Plan is successfully completed, then, at the time of modification, any additional arrearages will be capitalized into the modified UPB, if permitted by applicable law When the original offer is reissued to the Borrower, the Servicer may either revise the Trial Period payment amount or keep it the same provided it applies the same method consistently to all similarly situated Borrowers for the Freddie Mac Mortgages it services. However, the Servicer must ensure the final terms of the modification reflect all arrearages, including any additional delinquent amounts accrued during the appeal review process.

(d) Trial Period payment due date If a new Trial Period Plan offer is made with the appeal decision, the Trial Period payment due date must be set in accordance with Section 9206.2(b), assuming that there is a new Trial Period Plan offer being made. The period for the Borrower to indicate an intent to accept the new Trial Period Plan offer is extended until 14 days following the new Trial Period Plan offer, and legal acceptance via payment, as required under the Trial Period Plan, remains unchanged. The Trial Period payment due date of a new Trial Period Plan offer or revised payment due date for an original Trial Period Plan offer is based on when the appeals decision is sent by the Servicer to the Borrower. The Servicer must determine the Trial Period Plan Effective Date and the due date of the first Trial Period payment in accordance with the following instructions: ■ If the Servicer sends the appeal decision on or before the 15th of the month, then the Trial Period Plan Effective Date and the due date of the first Trial Period payment is the first day of the next month ■ If the Servicer sends the appeal decision after the 15th of the month, then the Trial Period Plan Effective Date and the Due Date of the first Trial Period payment is the first day of the month after the next month For example, if the Servicer sends the appeal decision notice to the Borrower between June 1 and June 15, the Trial Period Plan Effective Date and first Trial Period payment due date are both July 1. If the Servicer sends the appeal decision notice to the Borrower between June 16 and June 30, the Trial Period Plan Effective Date and the first Trial Period payment due date are both August 1. In response to the Servicer’s decision, the Borrower’s notification to the Servicer that he or she intends to accept an offer may be demonstrated as follows: ■ Verbal notification, as permitted in Sections 9101.3 and 9301.7(a) ■ Written notification; or ■ Remittance of payment due under the offer of an alternative to foreclosure that requires payment (e.g., a Trial Period Plan) Note: See also foreclosure postponement requirements in Section 9101.3 in response to an evaluation decision.

(e) Document retention The Servicer must maintain in the Mortgage file documentation of all communications relating to appeals. The Servicer must provide appeal case files or aggregated information to Freddie Mac for review upon request.

Package (Future effective date 11/16/26) Refer to Bulletins 2026-G and 2026-11, which announced updates related to Freddie Mac’s new event-based default related reporting requirements. Beginning November 16, 2026, Servicers may implement the new requirements if they are operationally ready to do so. If a Servicer adopts the new event-based default related reporting standards before the mandatory effective date of September 27, 2027, it must comply with the associated Guide requirements that will be effective on September 27, 2027 and, upon such adoption, must discontinue monthly EDR reporting. This section describes the requirements a Servicer must undertake to facilitate an appeals process when the Borrower is denied a Trial Period Plan based on the Servicer’s evaluation of the First Complete Borrower Response Package. The appeals process described in this section does not apply to evaluation decisions that are offered based on a review of an incomplete or no Borrower Response Package. This section contains requirements related to: ■ Evaluation timing and communication to Borrower ■ Managing the Borrower’s response to an evaluation decision ■ Borrower acceptance of an original offer after an appeal decision ■ Trial Period payment due date ■ Document retention

(a) Evaluation timing and communication to Borrower Within five days of an evaluation decision, but no later than 30 days following receipt of the First Complete Borrower Response Package, the Servicer must provide the appropriate Borrower Evaluation Notice as set forth in Section 9101.2(a). If the Servicer receives a complete Borrower Response Package 90 or more days before a scheduled foreclosure sale date or prior to the sale date being set, the Servicer must provide the appropriate Borrower Evaluation Notice, which informs the Borrower of: ■ The option to either accept or reject an offer of an alternative to foreclosure and the additional option to appeal within 14 days of the date of the evaluation notice ■ The right to accept an offer of an alternative to foreclosure and simultaneously appeal a denial of a Trial Period Plan ■ The right to accept any offer of an alternative to foreclosure for which the Borrower is approved as a result of the appeal or to accept or indicate an intent to accept any original offer of an alternative to foreclosure, which will still be available as an option up to 14 days after the appeal decision has been sent to the Borrower ■ Any determination of ineligibility for the Freddie Mac Flex Modification® upon review of a complete Borrower Response Package; and ■ The right to appeal a denial of a Trial Period Plan and the process and timeline, including: ❑ The address to which the Borrower must submit the appeal, which must be in writing and must include the Borrower’s name, property address and Mortgage loan number ❑ A statement that the Servicer’s appeal determination is not subject to further appeal ❑ A statement that the foreclosure process will be suspended during the appeals process The Servicer must send the Borrower the appropriate Borrower Evaluation Notice communicating the decision with one of the following outcomes: ■ Offer reinstatement ■ Offer a repayment plan (with or without a partial reinstatement offer)* ■ Offer a forbearance plan ■ Offer a Trial Period Plan as set forth in Chapter 9206 (e.g., Freddie Mac Flex Modification) ■ Offer a short sale as set forth in Chapter 9208 (i.e., Freddie Mac Standard Short Sale) ■ Offer a deed-in-lieu of foreclosure as set forth in Chapter 9209 (i.e., Freddie Mac Standard Deed-in-Lieu of Foreclosure) ■ Non-Approval, Ineligible for Mortgage Assistance – Mortgage is Current ■ Non-Approval, Ineligible for Mortgage Assistance – Mortgage is Delinquent Model letters describing each of these responses are included in Exhibit 93, Evaluation Notices. Use of the model letters is optional; however, they illustrate the level of specificity that is deemed to be in compliance with the requirements of this section. The model letters may be altered at the Servicer’s discretion to meet the requirements of this chapter and Chapters 8404, 9203, 9206, 9208 and 9209 and must be altered by the Servicer as necessary to comply with applicable federal, State and local law. Servicers must ensure that the model letters are revised as necessary to include denial reasons and information about the Borrower’s right to appeal the Servicer’s decision when the Borrower is denied a Trial Period Plan based on an evaluation of the First Complete Borrower Response Package. Exhibit 93 includes a list of denial reasons for use with the model letters. As a reminder, impermissible denial reasons include, but are not limited to, the following: ■ Full lender recourse or indemnification – In situations where the Servicer chose not to repurchase the Mortgage from Freddie Mac or, in the case of indemnification, chose not to modify the Mortgage, the Servicer must disclose the reason it will not modify the Mortgage, which must be based on its own requirements. Servicers are reminded that they may repurchase any Mortgage subject to full lender recourse or indemnification in accordance with the requirements set forth in Bulletin 2012-10 and may choose to modify a Mortgage subject to indemnification in accordance with the requirements in Bulletins 2016-5 and 2021-14. ■ FHA, RHS or VA Mortgage – The Servicer must determine eligibility for a loan modification under applicable agency requirements A Servicer may combine the relevant contents of the Borrower Evaluation Notice for a reinstatement offer with the contents of the notice for a repayment plan offer when offering the Borrower a partial reinstatement of the Mortgage coupled with a repayment plan in accordance with the requirements of Chapter 9203. Furthermore, if the offer for a foreclosure alternative is made 37 days or less prior to a scheduled foreclosure sale as set forth in Section 9301.7(a), a Borrower’s intent to accept the offer may not be communicated verbally but must be in writing. Therefore, the Servicer must delete the reference “at [SERVICER PHONE NUMBER] or” and otherwise amend the Evaluation Notice as appropriate. Servicers must comply with applicable law when obtaining a complete Borrower Response Package. Additional requirements related to forbearance, modifications, short sales and deedsin-lieu of foreclosure Topic Guide location Servicing Mortgages impacted by a disaster Reinstatements and relief options Freddie Mac workout options Modifications Freddie Mac Standard Short Sale Freddie Mac Standard Deed-in-Lieu of Foreclosure

(b) Managing the Borrower’s response to an evaluation decision The Servicer may only accept and review a valid appeal of the denial of any Trial Period Plan based on the evaluation of the First Complete Borrower Response Package within 14 days from the date of the Servicer’s offer or denial notice. A valid appeal requires the Borrower to provide the following: ■ An appeal of the denial for a Trial Period Plan in writing with his or her name ■ Property address; and ■ Mortgage loan number Any Borrower appeal must be reviewed by different Servicer personnel than those responsible for the initial evaluation decision. The Borrower may, but is not required to, submit any supporting documentation at the time he or she notifies the Servicer of an appeal. Servicers must adhere to the following guidelines regarding the submission and evaluation of supporting documentation: ■ If the Borrower submits supporting documentation within 14 days of the date the Servicer sent the Borrower Evaluation Notice, the Servicer must evaluate the supporting documentation during the appeal review ■ If documentation presented causes the Borrower to no longer be eligible for an original alternative to foreclosure, then the Servicer must inform the Borrower that the Borrower is no longer eligible for that original alternative to foreclosure. The model clauses in Exhibit 93 include language that conditions the offers on continuing eligibility based on information known to the Servicer. ■ If the Borrower submits new information or documentation after the 14-day Borrower response period, the new information or documentation is not subject to the right of appeal process in this section and must be evaluated in accordance with Section 9201.2. However, the Servicer may consider such new information as part of the appeal process within the time frames described in this section if it is feasible to do so. ■ The Servicer must have a policy applied consistently to all Mortgages to determine whether any new information received after the appeal decision is a material change in circumstance that warrants another review. Servicers must treat any new information and documentation received after the 14-day Borrower response period as a new Borrower Response Package. ■ If the Servicer concludes that a review of the updated complete Borrower Response Package is warranted, the Servicer must provide a decision to the Borrower within 30 days of receipt of the new information as provided under Section 9102.5(c) ■ The Servicer must provide the Borrower with an appeal decision notice within 30 days of receipt of the Borrower’s appeal. The appeal decision must include the original offer, if any, provided the Borrower remains eligible for the original offer. ■ If the Borrower is eligible for a Trial Period Plan with different terms or that was not part of the original offer, the Servicer must provide the new Trial Period Plan to that Borrower. The Servicer must provide the Borrower with 14 days (from the date the Servicer sends the appeal decision notice) to accept either the original offer, if the Borrower remains eligible, or indicate an intent to accept the new Trial Period Plan offer. ■ If a payment is required under an offer, then the Servicer must follow the relevant requirements under Chapters 9203, 9205, 9206, 9208 and 9209 concerning legal acceptance for that offer. However, the Servicer must continue to suspend foreclosure until the deadline for submission of the first payment under that offer has passed.

(c) Borrower acceptance of an original offer after an appeal decision If the Borrower accepts the original offer after receiving the appeal decision and remains eligible for the original offer, the Servicer must: ■ Reissue the original offer extended in the initial Borrower Evaluation Notice ■ Reissue the original offer with a new first Trial Period Plan due date, if applicable, and ❑ Inform the Borrower that unpaid interest and other amounts that continue to accrue during the appeal, such as Escrows for taxes and insurance, will result in the Mortgage becoming more delinquent; and ❑ Inform the Borrower that if the Trial Period Plan is successfully completed, then, at the time of modification, any additional arrearages will be capitalized into the modified UPB, if permitted by applicable law When the original offer is reissued to the Borrower, the Servicer may either revise the Trial Period payment amount or keep it the same provided it applies the same method consistently to all similarly situated Borrowers for the Freddie Mac Mortgages it services. However, the Servicer must ensure the final terms of the modification reflect all arrearages, including any additional delinquent amounts accrued during the appeal review process.

(d) Trial Period payment due date If a new Trial Period Plan offer is made with the appeal decision, the Trial Period payment due date must be set in accordance with Section 9206.2(b), assuming that there is a new Trial Period Plan offer being made. The period for the Borrower to indicate an intent to accept the new Trial Period Plan offer is extended until 14 days following the new Trial Period Plan offer, and legal acceptance via payment, as required under the Trial Period Plan, remains unchanged. The Trial Period payment due date of a new Trial Period Plan offer or revised payment due date for an original Trial Period Plan offer is based on when the appeals decision is sent by the Servicer to the Borrower. The Servicer must determine the Trial Period Plan Effective Date and the due date of the first Trial Period payment in accordance with the following instructions: ■ If the Servicer sends the appeal decision on or before the 15th of the month, then the Trial Period Plan Effective Date and the due date of the first Trial Period payment is the first day of the next month ■ If the Servicer sends the appeal decision after the 15th of the month, then the Trial Period Plan Effective Date and the Due Date of the first Trial Period payment is the first day of the month after the next month For example, if the Servicer sends the appeal decision notice to the Borrower between June 1 and June 15, the Trial Period Plan Effective Date and first Trial Period payment due date are both July 1. If the Servicer sends the appeal decision notice to the Borrower between June 16 and June 30, the Trial Period Plan Effective Date and the first Trial Period payment due date are both August 1. In response to the Servicer’s decision, the Borrower’s notification to the Servicer that he or she intends to accept an offer may be demonstrated as follows: ■ Verbal notification, as permitted in Sections 9101.3 and 9301.7(a) ■ Written notification; or ■ Remittance of payment due under the offer of an alternative to foreclosure that requires payment (e.g., a Trial Period Plan) Note: See also foreclosure postponement requirements in Section 9101.3 in response to an evaluation decision.

(e) Document retention The Servicer must maintain in the Mortgage file documentation of all communications relating to appeals. The Servicer must provide appeal case files or aggregated information to Freddie Mac for review upon request.

Package (Future effective date 09/27/27) This section describes the requirements a Servicer must undertake to facilitate an appeals process when the Borrower is denied a Trial Period Plan based on the Servicer’s evaluation of the First Complete Borrower Response Package. The appeals process described in this section does not apply to evaluation decisions that are offered based on a review of an incomplete or no Borrower Response Package. This section contains requirements related to: ■ Evaluation timing and communication to Borrower ■ Managing the Borrower’s response to an evaluation decision ■ Borrower acceptance of an original offer after an appeal decision ■ Trial Period payment due date ■ Reporting of receipt of a complete Borrower Response Package ■ Document retention

(a) Evaluation timing and communication to Borrower Within five days of an evaluation decision, but no later than 30 days following receipt of the First Complete Borrower Response Package, the Servicer must provide the appropriate Borrower Evaluation Notice as set forth in Section 9101.2(a). If the Servicer receives a complete Borrower Response Package 90 or more days before a scheduled foreclosure sale date or prior to the sale date being set, the Servicer must provide the appropriate Borrower Evaluation Notice, which informs the Borrower of: ■ The option to either accept or reject an offer of an alternative to foreclosure and the additional option to appeal within 14 days of the date of the evaluation notice ■ The right to accept an offer of an alternative to foreclosure and simultaneously appeal a denial of a Trial Period Plan ■ The right to accept any offer of an alternative to foreclosure for which the Borrower is approved as a result of the appeal or to accept or indicate an intent to accept any original offer of an alternative to foreclosure, which will still be available as an option up to 14 days after the appeal decision has been sent to the Borrower ■ Any determination of ineligibility for the Freddie Mac Flex Modification® upon review of a complete Borrower Response Package; and ■ The right to appeal a denial of a Trial Period Plan and the process and timeline, including: ❑ The address to which the Borrower must submit the appeal, which must be in writing and must include the Borrower’s name, property address and Mortgage loan number ❑ A statement that the Servicer’s appeal determination is not subject to further appeal ❑ A statement that the foreclosure process will be suspended during the appeals process The Servicer must send the Borrower the appropriate Borrower Evaluation Notice communicating the decision with one of the following outcomes: ■ Offer reinstatement ■ Offer a repayment plan (with or without a partial reinstatement offer)* ■ Offer a forbearance plan ■ Offer a Trial Period Plan as set forth in Chapter 9206 (e.g., Freddie Mac Flex Modification) ■ Offer a short sale as set forth in Chapter 9208 (i.e., Freddie Mac Standard Short Sale) ■ Offer a deed-in-lieu of foreclosure as set forth in Chapter 9209 (i.e., Freddie Mac Standard Deed-in-Lieu of Foreclosure) ■ Non-Approval, Ineligible for Mortgage Assistance – Mortgage is Current ■ Non-Approval, Ineligible for Mortgage Assistance – Mortgage is Delinquent Model letters describing each of these responses are included in Exhibit 93, Evaluation Notices. Use of the model letters is optional; however, they illustrate the level of specificity that is deemed to be in compliance with the requirements of this section. The model letters may be altered at the Servicer’s discretion to meet the requirements of this chapter and Chapters 8404, 9203, 9206, 9208 and 9209 and must be altered by the Servicer as necessary to comply with applicable federal, State and local law. Servicers must ensure that the model letters are revised as necessary to include denial reasons and information about the Borrower’s right to appeal the Servicer’s decision when the Borrower is denied a Trial Period Plan based on an evaluation of the First Complete Borrower Response Package. Exhibit 93 includes a list of denial reasons for use with the model letters. As a reminder, impermissible denial reasons include, but are not limited to, the following: ■ Full lender recourse or indemnification – In situations where the Servicer chose not to repurchase the Mortgage from Freddie Mac or, in the case of indemnification, chose not to modify the Mortgage, the Servicer must disclose the reason it will not modify the Mortgage, which must be based on its own requirements. Servicers are reminded that they may repurchase any Mortgage subject to full lender recourse or indemnification in accordance with the requirements set forth in Bulletin 2012-10 and may choose to modify a Mortgage subject to indemnification in accordance with the requirements in Bulletins 2016-5 and 2021-14. ■ FHA, RHS or VA Mortgage – The Servicer must determine eligibility for a loan modification under applicable agency requirements A Servicer may combine the relevant contents of the Borrower Evaluation Notice for a reinstatement offer with the contents of the notice for a repayment plan offer when offering the Borrower a partial reinstatement of the Mortgage coupled with a repayment plan in accordance with the requirements of Chapter 9203. Furthermore, if the offer for a foreclosure alternative is made 37 days or less prior to a scheduled foreclosure sale as set forth in Section 9301.7(a), a Borrower’s intent to accept the offer may not be communicated verbally but must be in writing. Therefore, the Servicer must delete the reference “at [SERVICER PHONE NUMBER] or” and otherwise amend the Evaluation Notice as appropriate. Servicers must comply with applicable law when obtaining a complete Borrower Response Package. Additional requirements related to forbearance, modifications, short sales and deedsin-lieu of foreclosure Topic Guide location Servicing Mortgages impacted by a disaster Reinstatements and relief options Freddie Mac workout options Modifications Freddie Mac Standard Short Sale Freddie Mac Standard Deed-in-Lieu of Foreclosure

(b) Managing the Borrower’s response to an evaluation decision The Servicer may only accept and review a valid appeal of the denial of any Trial Period Plan based on the evaluation of the First Complete Borrower Response Package within 14 days from the date of the Servicer’s offer or denial notice. A valid appeal requires the Borrower to provide the following: ■ An appeal of the denial for a Trial Period Plan in writing with his or her name ■ Property address; and ■ Mortgage loan number Any Borrower appeal must be reviewed by different Servicer personnel than those responsible for the initial evaluation decision. The Borrower may, but is not required to, submit any supporting documentation at the time he or she notifies the Servicer of an appeal. Servicers must adhere to the following guidelines regarding the submission and evaluation of supporting documentation: ■ If the Borrower submits supporting documentation within 14 days of the date the Servicer sent the Borrower Evaluation Notice, the Servicer must evaluate the supporting documentation during the appeal review ■ If documentation presented causes the Borrower to no longer be eligible for an original alternative to foreclosure, then the Servicer must inform the Borrower that the Borrower is no longer eligible for that original alternative to foreclosure. The model clauses in Exhibit 93 include language that conditions the offers on continuing eligibility based on information known to the Servicer. ■ If the Borrower submits new information or documentation after the 14-day Borrower response period, the new information or documentation is not subject to the right of appeal process in this section and must be evaluated in accordance with Section 9201.2. However, the Servicer may consider such new information as part of the appeal process within the time frames described in this section if it is feasible to do so. ■ The Servicer must have a policy applied consistently to all Mortgages to determine whether any new information received after the appeal decision is a material change in circumstance that warrants another review. Servicers must treat any new information and documentation received after the 14-day Borrower response period as a new Borrower Response Package. ■ If the Servicer concludes that a review of the updated complete Borrower Response Package is warranted, the Servicer must provide a decision to the Borrower within 30 days of receipt of the new information as provided under Section 9102.5(c) ■ The Servicer must provide the Borrower with an appeal decision notice within 30 days of receipt of the Borrower’s appeal. The appeal decision must include the original offer, if any, provided the Borrower remains eligible for the original offer. ■ If the Borrower is eligible for a Trial Period Plan with different terms or that was not part of the original offer, the Servicer must provide the new Trial Period Plan to that Borrower. The Servicer must provide the Borrower with 14 days (from the date the Servicer sends the appeal decision notice) to accept either the original offer, if the Borrower remains eligible, or indicate an intent to accept the new Trial Period Plan offer. ■ If a payment is required under an offer, then the Servicer must follow the relevant requirements under Chapters 9203, 9205, 9206, 9208 and 9209 concerning legal acceptance for that offer. However, the Servicer must continue to suspend foreclosure until the deadline for submission of the first payment under that offer has passed.

(c) Borrower acceptance of an original offer after an appeal decision If the Borrower accepts the original offer after receiving the appeal decision and remains eligible for the original offer, the Servicer must: ■ Reissue the original offer extended in the initial Borrower Evaluation Notice ■ Reissue the original offer with a new first Trial Period Plan due date, if applicable, and ❑ Inform the Borrower that unpaid interest and other amounts that continue to accrue during the appeal, such as Escrows for taxes and insurance, will result in the Mortgage becoming more delinquent; and ❑ Inform the Borrower that if the Trial Period Plan is successfully completed, then, at the time of modification, any additional arrearages will be capitalized into the modified UPB, if permitted by applicable law When the original offer is reissued to the Borrower, the Servicer may either revise the Trial Period payment amount or keep it the same provided it applies the same method consistently to all similarly situated Borrowers for the Freddie Mac Mortgages it services. However, the Servicer must ensure the final terms of the modification reflect all arrearages, including any additional delinquent amounts accrued during the appeal review process.

(d) Trial Period payment due date If a new Trial Period Plan offer is made with the appeal decision, the Trial Period payment due date must be set in accordance with Section 9206.2(b), assuming that there is a new Trial Period Plan offer being made. The period for the Borrower to indicate an intent to accept the new Trial Period Plan offer is extended until 14 days following the new Trial Period Plan offer, and legal acceptance via payment, as required under the Trial Period Plan, remains unchanged. The Trial Period payment due date of a new Trial Period Plan offer or revised payment due date for an original Trial Period Plan offer is based on when the appeals decision is sent by the Servicer to the Borrower. The Servicer must determine the Trial Period Plan Effective Date and the due date of the first Trial Period payment in accordance with the following instructions: ■ If the Servicer sends the appeal decision on or before the 15th of the month, then the Trial Period Plan Effective Date and the due date of the first Trial Period payment is the first day of the next month ■ If the Servicer sends the appeal decision after the 15th of the month, then the Trial Period Plan Effective Date and the Due Date of the first Trial Period payment is the first day of the month after the next month For example, if the Servicer sends the appeal decision notice to the Borrower between June 1 and June 15, the Trial Period Plan Effective Date and first Trial Period payment due date are both July 1. If the Servicer sends the appeal decision notice to the Borrower between June 16 and June 30, the Trial Period Plan Effective Date and the first Trial Period payment due date are both August 1. In response to the Servicer’s decision, the Borrower’s notification to the Servicer that he or she intends to accept an offer may be demonstrated as follows: ■ Verbal notification, as permitted in Sections 9101.3 and 9301.7(a) ■ Written notification; or ■ Remittance of payment due under the offer of an alternative to foreclosure that requires payment (e.g., a Trial Period Plan) Note: See also foreclosure postponement requirements in Section 9101.3 in response to an evaluation decision.

(e) Reporting of receipt of a complete Borrower Response Package Servicers must report the complete Borrower Response Package Received default related reporting event in accordance with Section 9102.6 and Exhibit 82, Default Reporting Dataset Guidelines, each time a complete Borrower Response Package is received.

(f) Document retention The Servicer must maintain in the Mortgage file documentation of all communications relating to appeals. The Servicer must provide appeal case files or aggregated information to Freddie Mac for review upon request.