Freddie Mac Single-Family Seller/Servicer Guide 9101.3 — Foreclosure suspension obligations and additional short sale and deed-in-lieu of foreclosure requirements once the First Complete Borrower

Response Package is received (09/10/25) This section contains information related to: ■ General foreclosure suspension obligations ■ Acceptance of offer requirements ■ Freddie Mac Standard Short Sale (“short sale”) evaluations and foreclosure suspension obligations ■ Freddie Mac Standard Deed-in-Lieu of foreclosure (“DIL”) evaluations and foreclosure suspension obligations

(a) General foreclosure suspension obligations Servicers must comply with the following foreclosure suspension requirements for the First Complete Borrower Response Package received more than 37 days prior to a scheduled foreclosure sale. However, existing foreclosure suspension requirements set forth in Section 9301.7(a) still apply when: ■ The First Complete Borrower Response Package is received 37 days or less prior to a scheduled foreclosure sale date ■ The Mortgage is not secured by a Primary Residence; or ■ The Mortgage is secured by a Primary Residence and the Servicer is reviewing a complete Borrower Response Package received after the First Complete Borrower Response Package The Servicer must delay or ensure that foreclosure counsel delays filing the first legal action (as defined in Section 9301.5(b)), the motion for judgment or order of sale or (if the motion has been filed) request the court to delay a hearing or ruling as permitted under State or local law, unless: ■ The First Complete Borrower Response Package was received 90 or more days prior to a scheduled foreclosure sale or received at any time prior to a foreclosure sale date being set, and: ❑ The Servicer has reviewed the First Complete Borrower Response Package ❑ The Servicer notified the Borrower of its decision, and ❑ The Borrower has not requested an appeal within 14 days of the Servicer’s evaluation decision or the Borrower’s appeal has been denied ■ The Servicer has reviewed the First Complete Borrower Response Package received less than 90 days prior to the foreclosure sale date and notified the Borrower of a denial decision. In this instance, the Servicer’s decision is not subject to an appeal. ■ The Borrower rejects an alternative to foreclosure offered by the Servicer; or ■ The Borrower fails to perform under the terms of an alternative to foreclosure, such as missing a Trial Period Plan payment

(b) Acceptance of offer requirements A Borrower’s notification to the Servicer that he or she intends to accept an offer may be demonstrated as follows: ■ Verbal notification ■ Written notification Additionally, if a payment is required to accept an alternative to foreclosure offer and the Borrower does not communicate a verbal or written rejection of the offer, the Servicer must postpone foreclosure actions where legally permitted until after the last day of the month in which the first payment is due under the terms of the alternative to foreclosure offer. If the Servicer receives the first payment timely in accordance with the terms of a Trial Period Plan, repayment plan or forbearance plan, the Servicer must delay the next legal action unless the Borrower breaches the plan.

(c) Freddie Mac Standard Short Sale (“short sale”) evaluations and foreclosure suspension obligations The following requirements describe the actions a Servicer must take when the First Complete Borrower Response Package is received more than 37 days prior to a scheduled foreclosure sale and results in an offer to proceed with a short sale: ■ The Servicer must provide a decision to the Borrower within five days of an evaluation decision but no later than 30 days from the Servicer’s receipt of the complete Borrower Response Package ■ The Servicer must include in the evaluation notice a date by which the Borrower must respond to the short sale offer (including a counteroffer to the purchase offer received), which must be 14 days from the date of the Borrower Evaluation Notice ■ If a purchase offer was not submitted with the First Complete Borrower Response Package: ❑ The Servicer must require the Borrower to provide a purchase offer no later than 45 days from the date of the Borrower Evaluation Notice or the date of an appeal decision, if applicable, for purposes of delaying the next legal action in the foreclosure process ❑ The Servicer must communicate to the Borrower that if a purchase contract is not received by the due date, which is 45 days from the date of the Borrower Evaluation Notice, the Borrower can continue to market the property after the expiration of the due date; however, foreclosure legal actions will commence or recommence ❑ Once a purchase offer is received within 45 days from the date of a Borrower Evaluation Notice, the Servicer must complete its review and provide a decision to the Borrower within 15 days of receipt of the purchase offer and, if the Servicer sends a counteroffer, it must require the Borrower to respond to the counteroffer within five Business Days of the date the Borrower receives the counteroffer The Servicer must delay or ensure that foreclosure counsel delays filing the first legal action, the motion for judgment or order of sale or (if the motion has been filed) request the court to delay a hearing or ruling as permitted under State or local law during the following: ■ The evaluation of the First Complete Borrower Response Package ■ The Borrower response period to the Servicer’s evaluation decision (i.e., 14 days from the date of the Borrower Evaluation Notice) ■ The 45-day response period in which the Borrower must provide a purchase offer to the Servicer, provided the Borrower responded timely to the Servicer’s evaluation decision ■ The Servicer review period (up to 15 days) to provide a decision on a purchase offer received within 45 days from the date of a Borrower Evaluation Notice ■ The appeal period, if applicable, if the Borrower exercises his or her right to appeal a denial of a loan modification. The Servicer must delay the next legal action during its review of the Borrower’s appeal and up to an additional 14 days for the Borrower to respond to the appeal decision. In cases where a purchase offer was not submitted with the First Complete Borrower Response Package, the Servicer must adjust the time frame in which the purchase offer must be submitted, which is 45 days from the date of the appeal decision. If the Servicer approves a purchase offer received within 45 days of the date of the Borrower Evaluation Notice, it must continue to delay filing the first legal action, the motion for judgment or order of sale or foreclosure sale to permit settlement of the short sale. If the purchase offer is rejected and the Borrower does not assert his or her right to appeal for a loan modification or the purchase offer is not received within 45 days from the date of the Borrower Evaluation Notice, the Servicer must proceed with the next legal action in the foreclosure process. However, the Borrower may continue to market the property while foreclosure legal actions commence or recommence. If a purchase offer is eventually received, the Servicer must provide a decision within 30 days of receipt. Note: Refer to Sections 9208.1(b) through 9208.3 for additional requirements for completing a short sale and requirements specific to situations where the Servicer is not evaluating the First Complete Borrower Response Package received more than 37 days prior to a scheduled foreclosure sale date.

(d) Freddie Mac Standard Deed-in-Lieu of foreclosure (“DIL”) evaluations and foreclosure suspension obligations The following requirements describe the actions a Servicer must take when the First Complete Borrower Response Package is received more than 37 days prior to a scheduled foreclosure sale and results in an offer to proceed with a DIL: ■ The Servicer must provide a decision to the Borrower within five days of an evaluation decision but no later than 30 days from the Servicer’s receipt of the complete Borrower Response Package ■ The Servicer must include in the evaluation notice a date by which the Borrower must respond to the DIL offer, which must be 14 days from the date of the Borrower Evaluation Notice ■ If the Borrower is approved to proceed with the DIL and accepts the offer, the Servicer must receive all necessary approvals (e.g., title, secondary lien(s), MI) and execute the DIL within 60 days of the date the Borrower’s communication to accept the offer was received by the Servicer The Servicer must ensure that foreclosure counsel delays filing the first legal action, the motion for judgment or order of sale or (if the motion has been filed) request the court to delay a hearing or ruling as permitted under State or local law during: ■ The evaluation of the complete Borrower Response Package in which the Servicer must provide a decision within five days of an evaluation decision but no later than 30 days from receipt of the Borrower Response Package ■ The Borrower response period to the Servicer’s evaluation decision (14 days from the date of the Borrower Evaluation Notice) ■ The appeal period, if applicable, if the Borrower exercises his or her right to appeal for a loan modification. The Servicer must delay the next legal action during its review of the Borrower’s appeal (up to 30 days) and up to an additional 14 days for the Borrower to respond to the appeal decision. The Servicer must adjust the time frame in which to delay foreclosure actions for up to 60 days to complete the DIL, to be based on the date of the Borrower acceptance of an offer after an appeal decision has been communicated. ■ Completion of the DIL transaction within 60 days of the date the Borrower communicated acceptance of the DIL offer. The Servicer must continue to delay the next legal action in the foreclosure process to complete the DIL provided that the Borrower did not previously accept a short sale offer that was not viable and then subsequently accepts the DIL offer. If the Servicer is unable to complete the DIL transaction within 60 days of the date of Borrower acceptance, the Servicer must proceed with the next legal action in the foreclosure process. The Servicer will be allocated an additional 30 days to complete the DIL transaction and must only delay the next legal action in the foreclosure process upon receipt of the executed deed and all required DIL documents. In addition, if the Borrower was previously approved for a short sale and transitioned to a DIL because the short sale transaction was not successful, the Servicer must not delay the next legal action in the foreclosure process until the Servicer has received the executed deed and all required DIL documents. Note: Refer to Sections 9209.1 through 9209.6 for additional requirements related to the completion of a DIL, and requirements specific to situations where the Servicer is not evaluating the First Complete Borrower Response Package received more than 37 days prior to a scheduled foreclosure sale date.