Freddie Mac Single-Family Seller/Servicer Guide 9301.11 — State foreclosure timelines and performance

This section contains requirements related to: ■ State foreclosure timelines ■ Allowable delays in completing a foreclosure ■ State foreclosure timeline performance assessment

(a) State foreclosure timelines A foreclosure timeline is the time it takes to process a foreclosure. The timeline is measured in days from the DDLPI to the date of the foreclosure sale. Therefore, the timeline consists of the time it should take from the DDLPI to the date the Mortgage is referred to foreclosure counsel (see Sections 9301.2(a) through 9301.2(d)), plus the time it takes from the referral date of foreclosure to the foreclosure sale date. The timeline does not include any post-sale redemption or confirmation periods. Freddie Mac has a timeline for each State which is the number of days it should take to process a foreclosure in the State under most circumstances. For conventional Mortgages, the Servicer must complete the foreclosure sale within the foreclosure timeline (from DDLPI to foreclosure sale) for the State in which the property is located, as listed in Exhibit 83, Freddie Mac State Foreclosure Timelines. The Servicer must comply with FHA, VA and RHS timelines for all Mortgages insured by the FHA or guaranteed by the VA or RHS. If the foreclosure sale was delayed due to one of the allowable State foreclosure timeline delays listed in Section 9301.11(b), the timeline from DDLPI to the foreclosure sale date will be increased to account for the allowable delay based on the information the Servicer reports to Freddie Mac via EDR. Refer to Exhibit 83A, Determining State Foreclosure Timeline Compensatory Fees, for details on how Freddie Mac determines the additional time to be granted for allowable delays. The Servicer must have procedures and processes in place to manage its State foreclosure timeline performance. To assist with monitoring performance, the Servicer may access reports, accessible via the “Foreclosures” tile of the Servicer’s Servicer Performance Profile (SPP) (see Exhibit 88, Servicing Tools), on foreclosure sales completed. The reports in the SPP will be based on information and data the Servicer reported to Freddie Mac. Servicers should review the reports regularly to ensure the information and data they reported was complete and accurate. Reduction in timelines At any time and in its sole discretion, Freddie Mac may reduce a State’s foreclosure timeline set forth in Exhibit 83 and further, may subject loans to revised timelines and associated compensatory fee calculations that were referred to foreclosure as of the effective date of the reduced timeline.

(b) Allowable delays in completing a foreclosure Exhibit 83, Freddie Mac State Foreclosure Timelines, sets forth Freddie Mac’s foreclosure timeline for each State. Freddie Mac’s State foreclosure timeline (DDLPI to foreclosure sale) will be extended for a Mortgage under the following circumstances, provided the Servicer complies with the applicable EDR requirements (refer to Section 9102.6 for information on EDR reporting requirements): ■ When a Borrower files for bankruptcy protection ■ Delays due to probate, military indulgence and contested foreclosures ■ Delays caused by the Borrower being offered or entering into a Freddie Mac Flex Modification Trial Period plan but failing to comply with the terms of the plan ■ Delays caused by the Borrower entering into an unemployment forbearance plan ■ Delays caused by the Borrower exercising his or her right to appeal a modification denial, pursuant to Section 9101.2 Refer to Exhibit 83A, Determining State Foreclosure Timeline Performance Compensatory Fees, for information on how Freddie Mac calculates the additional time granted for each of the allowable delays listed above. Moreover, a Servicer may delay completing the foreclosure, if necessary, when the delay is required due to: ■ Applicable federal, State or local law, but only if the delay was necessary or inevitable despite the Servicer’s best efforts to incorporate such laws into its foreclosure procedures and timelines ■ Emergency, exigent or unusual circumstances that do not occur in the regular course of business and that are both unforeseeable and outside the control of the Servicer (this includes delays resulting from Eligible Disasters, pursuant to Section 8404.1(d)) ■ The Servicer waiting for instructions from Freddie Mac on how to proceed with a distressed property (see Section 8403.1(a) and (b) for an explanation of a distressed property) ■ The Servicer being unable to complete the foreclosure sale due to the Borrower being approved for, or performing under, the terms of an alternative to foreclosure ■ The Borrower’s approval for a Freddie Mac Standard Short Sale or Freddie Mac Standard Deed-in-Lieu of Foreclosure being based on a review of a First Complete Borrower Response Package, pursuant to Section 9101.3 ■ The Borrower being conditionally approved for mortgage assistance under the State Housing Finance Agency program in accordance with Section 9211.1 Regardless of a delay for any of the above reasons, the Servicer’s State foreclosure timeline performance will be measured against Freddie Mac’s State foreclosure timeline and compensatory fees. The Servicer may appeal the decision and must provide to Freddie Mac at the time of appeal any and all information and documentation supporting the claim that the delay was necessary and required.

(c) State foreclosure timeline performance assessment For Mortgages that resulted in a foreclosure sale on or after January 1, 2019: (i) Determination of State foreclosure timeline performance Freddie Mac will evaluate the Servicer’s State foreclosure timeline performance on a calendar year basis. Based on all foreclosures the Servicer completes in the year being evaluated, Freddie Mac will determine a Servicer’s State foreclosure timeline performance for each Mortgage that went to foreclosure sale in the year being evaluated on a national basis. Freddie Mac will determine how long it took the Servicer to complete each foreclosure sale based on the information that the Servicer reports to Freddie Mac via the monthly EDR submissions and the foreclosure sale transmission after the completion of the foreclosure sale. Freddie Mac will calculate the amount of compensatory fees, if any, in addition to any actual losses, costs or damages caused by Servicer non-compliance with the Guide, including State foreclosure timeline requirements. To determine the Servicer’s overall State foreclosure timeline performance, Freddie Mac will complete the following steps: Step 1 – Calculating actual foreclosure timeline performance for each Mortgage: Freddie Mac will determine how many days it took the Servicer to complete each foreclosure sale during the calendar year and whether the number of days exceeded or were managed under the applicable State foreclosure timeline standard as listed in Exhibit 83, Freddie Mac State Foreclosure Timelines. Freddie Mac will then calculate the compensatory fee amount for each individual foreclosure sale to determine whether each Mortgage will result in a compensatory fee or credit. The amounts calculated in this step on an individual foreclosure sale basis will be negative (a credit) for those foreclosure sales that were managed under that State’s foreclosure timeline and will be positive (a compensatory fee) for those foreclosure sales that exceeded that State’s foreclosure timeline. Step 2 – Calculating the aggregate compensatory fee on a national basis: Freddie Mac will calculate the Servicer’s aggregate State foreclosure timeline compensatory fee amount by netting the compensatory fees and credits determined in Step 1 for all foreclosure sales that were completed in the calendar year. Step 3 – Determining whether to assess a compensatory fee: If the Servicer’s aggregate compensatory fee calculated in Step 2 is $300,000 or less, then no compensatory fee will be assessed. However, if the Servicer’s aggregate compensatory fee calculated in Step 2 is greater than $300,000, and the Servicer is not otherwise exempt under Section 9301.11(c)(ii), a compensatory fee will be assessed. Refer to Exhibit 83A, Determining State Foreclosure Timeline Performance Compensatory Fees, for additional details regarding how Freddie Mac calculates compensatory fees. The State foreclosure timelines used in determining the Servicer’s performance will be adjusted for the period of time for which the foreclosures were delayed due to any of the allowable delays in Section 9301.11(b), provided the Servicer complied with the applicable EDR requirement and/or the appeals process in Section 9301.11(c)(iii). (ii) Compensatory fee process If the Servicer’s performance exceeded Freddie Mac’s State foreclosure timeline requirements as outlined in Section 9301.10(c)(i), then the compensatory fee process is as follows: ■ Step 1: Freddie Mac will automatically waive a Servicer’s potential State foreclosure timeline compensatory fees if its exposure amount is $300,000 or less for that calendar year. This is considered the de minimis billing exception. (Note: $300,000 = previous monthly de minimis threshold of $25,000 x 12 months.) ■ Step 2: For those Servicers that did not receive a waiver under Step 1, Freddie Mac will calculate the Servicer’s overall Servicer Success Scorecard ranking for that calendar year against the respective rank group the Servicer belongs to on December 31 of that calendar year (see Section 3501.2(b) regarding Servicer performance results). If a Servicer’s overall ranking for that year is in the top 75% of its rank group on December 31 (i.e., not in the bottom 25% of that rank group), its State foreclosure timeline compensatory fees will automatically be waived. Note: This step does not apply to a Servicer where an overall ranking is not provided, whether because no Servicers in that Servicer’s rank group are provided an overall ranking or the individual Servicer did not receive an overall ranking within its rank group. Additional information on rankings and the Servicer Success Scorecard is available through Freddie Mac Gateway®. ■ Step 3: If a Servicer remains subject to the assessment of State foreclosure timeline compensatory fees after steps 1 and 2, the Servicer may be placed into a performance monitoring plan. If the Servicer is placed into a performance monitoring plan, the assessment of its compensatory fee exposure balance will be suspended until Freddie Mac determines whether the Servicer met the terms of the plan. If Freddie Mac determines that a Servicer complied with the required terms of the plan, its State foreclosure timeline compensatory fee assessment will be waived automatically. If the Servicer is not eligible for a performance monitoring plan, the Servicer will be assessed its compensatory fee exposure balance. ■ Step 4: If a Servicer still remains subject to the assessment of State foreclosure timeline compensatory fees after steps 1 through 3, the Servicer will be assessed its compensatory fee exposure balance if not previously assessed. The Servicer will have 90 days to submit any loan-level appeals in accordance with Section 9301.11(c)(iii). If after the appeals process is completed a Servicer continues to have a compensatory fee exposure balance of greater than $300,000, then the Servicer will be billed for such fees in accordance with Section 9301.11(c)(iv). (iii)Servicer appeal process for State foreclosure timeline compensatory fees The Servicer may appeal a pending compensatory fee prior to Freddie Mac billing the compensatory fee. The calendar year’s estimated State foreclosure timeline compensatory fees will be available in the Foreclosure Timeline Compensatory Fees Overview report, accessible via the “Foreclosures” tile of the Servicer’s Servicer Performance Profile (SPP) (see Exhibit 88, Servicing Tools). This report will be updated monthly, on the fifth Business Day of each month to reflect the year-to-date State foreclosure timeline performance through the end of the prior month. Servicers are not required to submit appeals and it is recommended that Servicers do not submit any appeals until all steps outlined in Section 9301.11(c)(ii) have been completed and the Servicer has been notified that the compensatory fees are now assessed and subject to billing. Servicers must submit, in their original appeal, a description of all delays along with all related documentation. Any information that is received after the original appeal is submitted will not be considered. The Servicer has 90 days to submit an appeal to Freddie Mac using the Freddie Mac Default Fee Appeal System (which can be accessed through Freddie Mac Gateway). (iv) Billing process for compensatory fees Compensatory fees to be billed will appear on the Servicer’s Monthly Non-Performing Loans Billing Statement in the first monthly cycle after the date in which all appeals have been submitted to, and decisioned by, Freddie Mac. Refer to Section 9102.1 for information on the payment of Servicing Non-Performing Loans Invoices via an Automated Clearing House draft.

(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 contains requirements related to: ■ State foreclosure timelines ■ Allowable delays in completing a foreclosure ■ State foreclosure timeline performance assessment

(a) State foreclosure timelines A foreclosure timeline is the time it takes to process a foreclosure. The timeline is measured in days from the DDLPI to the date of the foreclosure sale. Therefore, the timeline consists of the time it should take from the DDLPI to the date the Mortgage is referred to foreclosure counsel (see Sections 9301.2(a) through 9301.2(d)), plus the time it takes from the referral date of foreclosure to the foreclosure sale date. The timeline does not include any post-sale redemption or confirmation periods. Freddie Mac has a timeline for each State which is the number of days it should take to process a foreclosure in the State under most circumstances. For conventional Mortgages, the Servicer must complete the foreclosure sale within the foreclosure timeline (from DDLPI to foreclosure sale) for the State in which the property is located, as listed in Exhibit 83, Freddie Mac State Foreclosure Timelines. The Servicer must comply with FHA, VA and RHS timelines for all Mortgages insured by the FHA or guaranteed by the VA or RHS. If the foreclosure sale was delayed due to one of the allowable State foreclosure timeline delays listed in Section 9301.11(b), the timeline from DDLPI to the foreclosure sale date will be increased to account for the allowable delay based on the information the Servicer reports to Freddie Mac via EDR. Refer to Exhibit 83A, Determining State Foreclosure Timeline Compensatory Fees, for details on how Freddie Mac determines the additional time to be granted for allowable delays. The Servicer must have procedures and processes in place to manage its State foreclosure timeline performance. To assist with monitoring performance, the Servicer may access reports, accessible via the “Foreclosures” tile of the Servicer’s Servicer Performance Profile (SPP) (see Exhibit 88, Servicing Tools), on foreclosure sales completed. The reports in the SPP will be based on information and data the Servicer reported to Freddie Mac. Servicers should review the reports regularly to ensure the information and data they reported was complete and accurate. Reduction in timelines At any time and in its sole discretion, Freddie Mac may reduce a State’s foreclosure timeline set forth in Exhibit 83 and further, may subject loans to revised timelines and associated compensatory fee calculations that were referred to foreclosure as of the effective date of the reduced timeline.

(b) Allowable delays in completing a foreclosure Exhibit 83, Freddie Mac State Foreclosure Timelines, sets forth Freddie Mac’s foreclosure timeline for each State. Freddie Mac’s State foreclosure timeline (DDLPI to foreclosure sale) will be extended for a Mortgage under the following circumstances, provided the Servicer complies with the applicable EDR requirements (refer to Section 9102.6 for information on EDR reporting requirements): ■ When a Borrower files for bankruptcy protection ■ Delays due to probate, military indulgence and contested foreclosures ■ Delays caused by the Borrower being offered or entering into a Freddie Mac Flex Modification Trial Period plan but failing to comply with the terms of the plan ■ Delays caused by the Borrower entering into an unemployment forbearance plan ■ Delays caused by the Borrower exercising his or her right to appeal a modification denial, pursuant to Section 9101.2 Refer to Exhibit 83A, Determining State Foreclosure Timeline Performance Compensatory Fees, for information on how Freddie Mac calculates the additional time granted for each of the allowable delays listed above. Moreover, a Servicer may delay completing the foreclosure, if necessary, when the delay is required due to: ■ Applicable federal, State or local law, but only if the delay was necessary or inevitable despite the Servicer’s best efforts to incorporate such laws into its foreclosure procedures and timelines ■ Emergency, exigent or unusual circumstances that do not occur in the regular course of business and that are both unforeseeable and outside the control of the Servicer (this includes delays resulting from Eligible Disasters, pursuant to Section 8404.1(d)) ■ The Servicer waiting for instructions from Freddie Mac on how to proceed with a distressed property (see Section 8403.1(a) and (b) for an explanation of a distressed property) ■ The Servicer being unable to complete the foreclosure sale due to the Borrower being approved for, or performing under, the terms of an alternative to foreclosure ■ The Borrower’s approval for a Freddie Mac Standard Short Sale or Freddie Mac Standard Deed-in-Lieu of Foreclosure being based on a review of a First Complete Borrower Response Package, pursuant to Section 9101.3 ■ The Borrower being conditionally approved for mortgage assistance under the State Housing Finance Agency program in accordance with Section 9211.1 Regardless of a delay for any of the above reasons, the Servicer’s State foreclosure timeline performance will be measured against Freddie Mac’s State foreclosure timeline and compensatory fees. The Servicer may appeal the decision and must provide to Freddie Mac at the time of appeal any and all information and documentation supporting the claim that the delay was necessary and required.

(c) State foreclosure timeline performance assessment For Mortgages that resulted in a foreclosure sale on or after January 1, 2019: (i) Determination of State foreclosure timeline performance Freddie Mac will evaluate the Servicer’s State foreclosure timeline performance on a calendar year basis. Based on all foreclosures the Servicer completes in the year being evaluated, Freddie Mac will determine a Servicer’s State foreclosure timeline performance for each Mortgage that went to foreclosure sale in the year being evaluated on a national basis. Freddie Mac will determine how long it took the Servicer to complete each foreclosure sale based on the information that the Servicer reports to Freddie Mac via the monthly EDR submissions and the foreclosure sale transmission after the completion of the foreclosure sale. Freddie Mac will calculate the amount of compensatory fees, if any, in addition to any actual losses, costs or damages caused by Servicer non-compliance with the Guide, including State foreclosure timeline requirements. To determine the Servicer’s overall State foreclosure timeline performance, Freddie Mac will complete the following steps: Step 1 – Calculating actual foreclosure timeline performance for each Mortgage: Freddie Mac will determine how many days it took the Servicer to complete each foreclosure sale during the calendar year and whether the number of days exceeded or were managed under the applicable State foreclosure timeline standard as listed in Exhibit 83, Freddie Mac State Foreclosure Timelines. Freddie Mac will then calculate the compensatory fee amount for each individual foreclosure sale to determine whether each Mortgage will result in a compensatory fee or credit. The amounts calculated in this step on an individual foreclosure sale basis will be negative (a credit) for those foreclosure sales that were managed under that State’s foreclosure timeline and will be positive (a compensatory fee) for those foreclosure sales that exceeded that State’s foreclosure timeline. Step 2 – Calculating the aggregate compensatory fee on a national basis: Freddie Mac will calculate the Servicer’s aggregate State foreclosure timeline compensatory fee amount by netting the compensatory fees and credits determined in Step 1 for all foreclosure sales that were completed in the calendar year. Step 3 – Determining whether to assess a compensatory fee: If the Servicer’s aggregate compensatory fee calculated in Step 2 is $300,000 or less, then no compensatory fee will be assessed. However, if the Servicer’s aggregate compensatory fee calculated in Step 2 is greater than $300,000, and the Servicer is not otherwise exempt under Section 9301.11(c)(ii), a compensatory fee will be assessed. Refer to Exhibit 83A, Determining State Foreclosure Timeline Performance Compensatory Fees, for additional details regarding how Freddie Mac calculates compensatory fees. The State foreclosure timelines used in determining the Servicer’s performance will be adjusted for the period of time for which the foreclosures were delayed due to any of the allowable delays in Section 9301.11(b), provided the Servicer complied with the applicable EDR requirement and/or the appeals process in Section 9301.11(c)(iii). (ii) Compensatory fee process If the Servicer’s performance exceeded Freddie Mac’s State foreclosure timeline requirements as outlined in Section 9301.10(c)(i), then the compensatory fee process is as follows: ■ Step 1: Freddie Mac will automatically waive a Servicer’s potential State foreclosure timeline compensatory fees if its exposure amount is $300,000 or less for that calendar year. This is considered the de minimis billing exception. (Note: $300,000 = previous monthly de minimis threshold of $25,000 x 12 months.) ■ Step 2: For those Servicers that did not receive a waiver under Step 1, Freddie Mac will calculate the Servicer’s overall Servicer Success Scorecard ranking for that calendar year against the respective rank group the Servicer belongs to on December 31 of that calendar year (see Section 3501.2(b) regarding Servicer performance results). If a Servicer’s overall ranking for that year is in the top 75% of its rank group on December 31 (i.e., not in the bottom 25% of that rank group), its State foreclosure timeline compensatory fees will automatically be waived. Note: This step does not apply to a Servicer where an overall ranking is not provided, whether because no Servicers in that Servicer’s rank group are provided an overall ranking or the individual Servicer did not receive an overall ranking within its rank group. Additional information on rankings and the Servicer Success Scorecard is available through Freddie Mac Gateway®. ■ Step 3: If a Servicer remains subject to the assessment of State foreclosure timeline compensatory fees after steps 1 and 2, the Servicer may be placed into a performance monitoring plan. If the Servicer is placed into a performance monitoring plan, the assessment of its compensatory fee exposure balance will be suspended until Freddie Mac determines whether the Servicer met the terms of the plan. If Freddie Mac determines that a Servicer complied with the required terms of the plan, its State foreclosure timeline compensatory fee assessment will be waived automatically. If the Servicer is not eligible for a performance monitoring plan, the Servicer will be assessed its compensatory fee exposure balance. ■ Step 4: If a Servicer still remains subject to the assessment of State foreclosure timeline compensatory fees after steps 1 through 3, the Servicer will be assessed its compensatory fee exposure balance if not previously assessed. The Servicer will have 90 days to submit any loan-level appeals in accordance with Section 9301.11(c)(iii). If after the appeals process is completed a Servicer continues to have a compensatory fee exposure balance of greater than $300,000, then the Servicer will be billed for such fees in accordance with Section 9301.11(c)(iv). (iii)Servicer appeal process for State foreclosure timeline compensatory fees The Servicer may appeal a pending compensatory fee prior to Freddie Mac billing the compensatory fee. The calendar year’s estimated State foreclosure timeline compensatory fees will be available in the Foreclosure Timeline Compensatory Fees Overview report, accessible via the “Foreclosures” tile of the Servicer’s Servicer Performance Profile (SPP) (see Exhibit 88, Servicing Tools). This report will be updated monthly, on the fifth Business Day of each month to reflect the year-to-date State foreclosure timeline performance through the end of the prior month. Servicers are not required to submit appeals and it is recommended that Servicers do not submit any appeals until all steps outlined in Section 9301.11(c)(ii) have been completed and the Servicer has been notified that the compensatory fees are now assessed and subject to billing. Servicers must submit, in their original appeal, a description of all delays along with all related documentation. Any information that is received after the original appeal is submitted will not be considered. The Servicer has 90 days to submit an appeal to Freddie Mac using the Freddie Mac Default Fee Appeal System (which can be accessed through Freddie Mac Gateway). (iv) Billing process for compensatory fees Compensatory fees to be billed will appear on the Servicer’s Monthly Non-Performing Loans Billing Statement in the first monthly cycle after the date in which all appeals have been submitted to, and decisioned by, Freddie Mac. Refer to Section 9102.1 for information on the payment of Servicing Non-Performing Loans Invoices via an Automated Clearing House draft.

(Future effective date 09/27/27) This section contains requirements related to: ■ State foreclosure timelines ■ Allowable delays in completing a foreclosure ■ State foreclosure timeline performance assessment

(a) State foreclosure timelines A foreclosure timeline is the time it takes to process a foreclosure. The timeline is measured in days from the DDLPI to the date of the foreclosure sale. Therefore, the timeline consists of the time it should take from the DDLPI to the date the Mortgage is referred to foreclosure counsel (see Sections 9301.2(a) through 9301.2(d)), plus the time it takes from the referral date of foreclosure to the foreclosure sale date. The timeline does not include any post-sale redemption or confirmation periods. Freddie Mac has a timeline for each State which is the number of days it should take to process a foreclosure in the State under most circumstances. For conventional Mortgages, the Servicer must complete the foreclosure sale within the foreclosure timeline (from DDLPI to foreclosure sale) for the State in which the property is located, as listed in Exhibit 83, Freddie Mac State Foreclosure Timelines. The Servicer must comply with FHA, VA and RHS timelines for all Mortgages insured by the FHA or guaranteed by the VA or RHS. If the foreclosure sale was delayed due to one of the allowable State foreclosure timeline delays listed in Section 9301.11(b), the timeline from DDLPI to the foreclosure sale date will be increased to account for the allowable delay based on the information the Servicer reports in Resolve (e.g., forbearance and Freddie Mac Flex Modification information and/or default related reporting events). (See Section 9102.6 and Exhibit 82, Default Reporting Dataset Guidelines, for additional details on default related reporting events.) Refer to Exhibit 83A, Determining State Foreclosure Timeline Compensatory Fees, for details on how Freddie Mac determines the additional time to be granted for allowable delays. The Servicer must have procedures and processes in place to manage its State foreclosure timeline performance. To assist with monitoring performance, the Servicer may access reports, accessible via the “Foreclosures” tile of the Servicer’s Servicer Performance Profile (SPP) (see Exhibit 88, Servicing Tools), on foreclosure sales completed. The reports in the SPP will be based on information and data the Servicer reported to Freddie Mac. Servicers should review the reports regularly to ensure the information and data they reported was complete and accurate. At any time and in its sole discretion, Freddie Mac may reduce a State’s foreclosure timeline set forth in Exhibit 83 and further, may subject loans to revised timelines and associated compensatory fee calculations that were referred to foreclosure as of the effective date of the reduced timeline.

(b) Allowable delays in completing a foreclosure Exhibit 83, Freddie Mac State Foreclosure Timelines, sets forth Freddie Mac’s foreclosure timeline for each State. Freddie Mac’s State foreclosure timeline (DDLPI to foreclosure sale) will be extended for a Mortgage under the following circumstances, provided the Servicer complies with the applicable default related event reporting requirements (see Section 9102.6 and Exhibit 82 for information on default related event reporting requirements): ■ When a Borrower files for bankruptcy protection ■ Delays due to probate, military indulgence and contested foreclosures ■ Delays caused by the Borrower being offered or entering into a Freddie Mac Flex Modification Trial Period plan but failing to comply with the terms of the plan ■ Delays caused by the Borrower entering into an unemployment forbearance plan ■ Delays caused by the Borrower exercising his or her right to appeal a modification denial, pursuant to Section 9101.2 Refer to Exhibit 83A, Determining State Foreclosure Timeline Performance Compensatory Fees, for information on how Freddie Mac calculates the additional time granted for each of the allowable delays listed above. Moreover, a Servicer may delay completing the foreclosure, if necessary, when the delay is required due to: ■ Applicable federal, State or local law, but only if the delay was necessary or inevitable despite the Servicer’s best efforts to incorporate such laws into its foreclosure procedures and timelines ■ Emergency, exigent or unusual circumstances that do not occur in the regular course of business and that are both unforeseeable and outside the control of the Servicer (this includes delays resulting from Eligible Disasters, pursuant to Section 8404.1(d)) ■ The Servicer waiting for instructions from Freddie Mac on how to proceed with a distressed property (see Section 8403.1(a) and (b) for an explanation of a distressed property) ■ The Servicer being unable to complete the foreclosure sale due to the Borrower being approved for, or performing under, the terms of an alternative to foreclosure ■ The Borrower’s approval for a Freddie Mac Standard Short Sale or Freddie Mac Standard Deed-in-Lieu of Foreclosure being based on a review of a First Complete Borrower Response Package, pursuant to Section 9101.3 ■ The Borrower being conditionally approved for mortgage assistance under the State Housing Finance Agency program in accordance with Section 9211.1 Regardless of a delay for any of the above reasons, the Servicer’s State foreclosure timeline performance will be measured against Freddie Mac’s State foreclosure timeline and compensatory fees. The Servicer may appeal the decision and must provide to Freddie Mac at the time of appeal any and all information and documentation supporting the claim that the delay was necessary and required.

(c) State foreclosure timeline performance assessment For Mortgages that resulted in a foreclosure sale on or after January 1, 2019: (i) Determination of State foreclosure timeline performance Freddie Mac will evaluate the Servicer’s State foreclosure timeline performance on a calendar year basis. Based on all foreclosures the Servicer completes in the year being evaluated, Freddie Mac will determine a Servicer’s State foreclosure timeline performance for each Mortgage that went to foreclosure sale in the year being evaluated on a national basis. Freddie Mac will determine how long it took the Servicer to complete each foreclosure sale based on the information that the Servicer reports to Freddie Mac via default related event reporting and the foreclosure sale transmission after the completion of the foreclosure sale. Freddie Mac will calculate the amount of compensatory fees, if any, in addition to any actual losses, costs or damages caused by Servicer non-compliance with the Guide, including State foreclosure timeline requirements. To determine the Servicer’s overall State foreclosure timeline performance, Freddie Mac will complete the following steps: Step 1 – Calculating actual foreclosure timeline performance for each Mortgage: Freddie Mac will determine how many days it took the Servicer to complete each foreclosure sale during the calendar year and whether the number of days exceeded or were managed under the applicable State foreclosure timeline standard as listed in Exhibit 83, Freddie Mac State Foreclosure Timelines. Freddie Mac will then calculate the compensatory fee amount for each individual foreclosure sale to determine whether each Mortgage will result in a compensatory fee or credit. The amounts calculated in this step on an individual foreclosure sale basis will be negative (a credit) for those foreclosure sales that were managed under that State’s foreclosure timeline and will be positive (a compensatory fee) for those foreclosure sales that exceeded that State’s foreclosure timeline. Step 2 – Calculating the aggregate compensatory fee on a national basis: Freddie Mac will calculate the Servicer’s aggregate State foreclosure timeline compensatory fee amount by netting the compensatory fees and credits determined in Step 1 for all foreclosure sales that were completed in the calendar year. Step 3 – Determining whether to assess a compensatory fee: If the Servicer’s aggregate compensatory fee calculated in Step 2 is $300,000 or less, then no compensatory fee will be assessed. However, if the Servicer’s aggregate compensatory fee calculated in Step 2 is greater than $300,000, and the Servicer is not otherwise exempt under Section 9301.11(c)(ii), a compensatory fee will be assessed. Refer to Exhibit 83A, Determining State Foreclosure Timeline Performance Compensatory Fees, for additional details regarding how Freddie Mac calculates compensatory fees. The State foreclosure timelines used in determining the Servicer’s performance will be adjusted for the period of time for which the foreclosures were delayed due to any of the allowable delays in Section 9301.11(b), provided the Servicer complied with the applicable default related event reporting requirements and/or the appeals process in Section 9301.11(c)(iii). (ii) Compensatory fee process If the Servicer’s performance exceeded Freddie Mac’s State foreclosure timeline requirements as outlined in Section 9301.10(c)(i), then the compensatory fee process is as follows: ■ Step 1: Freddie Mac will automatically waive a Servicer’s potential State foreclosure timeline compensatory fees if its exposure amount is $300,000 or less for that calendar year. This is considered the de minimis billing exception. (Note: $300,000 = previous monthly de minimis threshold of $25,000 x 12 months.) ■ Step 2: For those Servicers that did not receive a waiver under Step 1, Freddie Mac will calculate the Servicer’s overall Servicer Success Scorecard ranking for that calendar year against the respective rank group the Servicer belongs to on December 31 of that calendar year (see Section 3501.2(b) regarding Servicer performance results). If a Servicer’s overall ranking for that year is in the top 75% of its rank group on December 31 (i.e., not in the bottom 25% of that rank group), its State foreclosure timeline compensatory fees will automatically be waived. Note: This step does not apply to a Servicer where an overall ranking is not provided, whether because no Servicers in that Servicer’s rank group are provided an overall ranking or the individual Servicer did not receive an overall ranking within its rank group. Additional information on rankings and the Servicer Success Scorecard is available through Freddie Mac Gateway®. ■ Step 3: If a Servicer remains subject to the assessment of State foreclosure timeline compensatory fees after steps 1 and 2, the Servicer may be placed into a performance monitoring plan. If the Servicer is placed into a performance monitoring plan, the assessment of its compensatory fee exposure balance will be suspended until Freddie Mac determines whether the Servicer met the terms of the plan. If Freddie Mac determines that a Servicer complied with the required terms of the plan, its State foreclosure timeline compensatory fee assessment will be waived automatically. If the Servicer is not eligible for a performance monitoring plan, the Servicer will be assessed its compensatory fee exposure balance. ■ Step 4: If a Servicer still remains subject to the assessment of State foreclosure timeline compensatory fees after steps 1 through 3, the Servicer will be assessed its compensatory fee exposure balance if not previously assessed. The Servicer will have 90 days to submit any loan-level appeals in accordance with Section 9301.11(c)(iii). If after the appeals process is completed a Servicer continues to have a compensatory fee exposure balance of greater than $300,000, then the Servicer will be billed for such fees in accordance with Section 9301.11(c)(iv). (iii)Servicer appeal process for State foreclosure timeline compensatory fees The Servicer may appeal a pending compensatory fee prior to Freddie Mac billing the compensatory fee. The calendar year’s estimated State foreclosure timeline compensatory fees will be available in the Foreclosure Timeline Compensatory Fees Overview report, accessible via the “Foreclosures” tile of the Servicer’s Servicer Performance Profile (SPP) (see Exhibit 88, Servicing Tools). This report will be updated monthly, on the fifth Business Day of each month to reflect the year-to-date State foreclosure timeline performance through the end of the prior month. Servicers are not required to submit appeals and it is recommended that Servicers do not submit any appeals until all steps outlined in Section 9301.11(c)(ii) have been completed and the Servicer has been notified that the compensatory fees are now assessed and subject to billing. Servicers must submit, in their original appeal, a description of all delays along with all related documentation. Any information that is received after the original appeal is submitted will not be considered. The Servicer has 90 days to submit an appeal to Freddie Mac using the Freddie Mac Default Fee Appeal System (which can be accessed through Freddie Mac Gateway). (iv) Billing process for compensatory fees Compensatory fees to be billed will appear on the Servicer’s Monthly Non-Performing Loans Billing Statement in the first monthly cycle after the date in which all appeals have been submitted to, and decisioned by, Freddie Mac. Refer to Section 9102.1 for information on the payment of Servicing Non-Performing Loans Invoices via an Automated Clearing House draft. Freddie Mac Single-Family Seller/Service Guide