Extinguishment SOP_Transfer to MSS_Q4_2020.pdf

Extinguishment

Standard Operating Procedure

Monitoring and Asset Management Division, Office of Issuer and Portfolio Management

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 2

SOP 6030.03.0003

DISCLAIMER. Deloitte & Touche LLP assisted Ginnie Mae’s Office of Issuer and Portfolio

Management (OIPM) in documenting this operating procedure. Ginnie Mae is responsible for the development and executing of the extinguishment procedures.

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 3

SOP 6030.03.0003

SUBJECT. Extinguishment Standard Operating Procedure (SOP).

OVERVIEW. This document is intended to provide an overview of the process for extinguishing an Issuer from Ginnie Mae’s Mortgage-Backed Securities (MBS) Program. The extinguishment process is divided into four key sections to reflect the following extinguishment phases: Organize, Pre-Site Visit, Site Visit, and Site Visit Closeout. The Organize phase initiates the extinguishment process by gathering and distributing preliminary extinguishment information to appropriate stakeholders and establishing the Ginnie Mae stakeholder coordination strategy. Next is the Pre-

Site Visit phase, where Ginnie Mae communicates the decision to extinguish and identifies the required data/documentation, as well as proactively coordinate stakeholder involvement and extinguishment efforts. OIPM, the Monitoring and Asset Management (M&AM) Division, the Office of Enterprise Risk (OER), the Office of Securities Operations (OSO), and the Master Sub-

Servicer(s) (MSS) Contracting Officer’s Representatives (COR) are key stakeholders in the extinguishment phase of the Issuer Default Lifecycle. The Site Visit phase is when extinguishment teams are deployed to required locations to execute the Default Playbook steps and obtain data and documentation. The final extinguishment phase is Site Visit Closeout, where the extinguished

Issuer’s portfolio is transferred to the MSS and efforts relating to the extinguishment, lessons learned, and system updates to reflect the new Default Issuer ID are documented. The extinguishment phases establish a repeatable framework to assist Ginnie Mae through the lifecycle of removing an Issuer from the MBS Program and transitioning the extinguished Issuer’s portfolio to the MSS(s), if applicable.

PURPOSE. This document is intended to provide a detailed overview of the Extinguishment process.

SCOPE. The scope of this document is isolated to the extinguishment process, which may, but is not required to, occur following the Enhanced Monitoring & Management (EMM) and/or the

Special Situation processes.

POLICY. Ginnie Mae MBS Guide, Guaranty Agreements, and the Office of Management and

Budget (OMB) Circular A-123: Management’s Responsibility for Internal Control in Federal

Agencies.

INTERNAL CONTROLS. There are 27 unique Internal Controls identified within this SOP.

Reference Sections 2.4, 3.4, 4.4, 5.4 on Key Internal Controls for detail.

EFFECTIVE DATE. SOP 6030.03.0003 Extinguishment is effective as of February 08, 2021.

FREQUENCY OF REVIEW. The SOP is reviewed on an as-needed basis and, at minimum, annually to ensure consistency and accurate reflection of the current procedures employed in conducting the extinguishment process.

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 4

CERTIFICATION.

Owner – Rene Mondonedo

Director, Monitoring and Asset

Management Division

Required Approver – Leslie Meaux

Pordzik

Senior Vice President, Office of Issuer and Portfolio Management

Date Date

2/08/21 2/11/2021

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 5

DOCUMENT HISTORY

Revision History

Version Date Author Description

Insert

Version Number

Date of Revision

Author of Revision Describe what was modified and/or updated from the previous version.

1.00 06/10/2019 OIPM

Initial SOP for Extinguishment – Transfer to MSS.

2.00 08/25/2020 OIPM

Revised SOP for Extinguishment – Transfer to MSS, based on Q3 2020 change control cycle. See Change

Control Log in Salesforce for details on specific changes.

3.00 02/08/2021 OIPM

Revised SOP for Extinguishment – Transfer to MSS, based on Q4 2020 change control cycle. See Change Control Log in Salesforce for details on specific changes.

SOP Extinguishment

SOP Number 6030.03.0003

Version Number 3.00

Date Approved February 08, 2021

Effective Date February 08, 2021

Owner Rene Mondonedo, Director

Monitoring and Asset Management Division

Approver Rene Mondonedo, Director

Monitoring and Asset Management Division

Required Approver Leslie Meaux Pordzik, Senior Vice President

Office of Issuer and Portfolio Management

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 6

TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 PURPOSE

1.2 SYSTEMS

1.3 SUMMARY OF PHASES

1.4 ACTIVITY TIMELINE

1.5 ROLES AND RESPONSIBILITIES

2.0 ORGANIZE

2.1 SCOPE

2.2 BUSINESS PROCESS DOCUMENTATION

2.3 ROLES AND RESPONSIBILITIES

2.4 PROCEDURES

2.5 KEY INTERNAL CONTROLS

2.6 EVIDENTIAL MATTER

2.7 APPENDICES

3.0 PRE-SITE VISIT

3.1 SCOPE

3.2 BUSINESS PROCESS DOCUMENTATION

3.3 ROLES AND RESPONSIBILITIES

3.4 PROCEDURES

3.5 KEY INTERNAL CONTROLS

3.6 EVIDENTIAL MATTER

3.7 APPENDICES

4.0 SITE VISIT

4.1 SCOPE

4.2 BUSINESS PROCESS DOCUMENTATION

4.3 ROLES AND RESPONSIBILITIES

4.4 PROCEDURES

4.5 KEY INTERNAL CONTROLS

4.5 EVIDENTIAL MATTER

4.6 APPENDICES

5.0 SITE VISIT CLOSEOUT

5.1 SCOPE

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 7

5.2 BUSINESS PROCESS DOCUMENTATION

5.3 ROLES AND RESPONSIBILITIES

5.4 PROCEDURES

5.5 KEY INTERNAL CONTROLS

5.6 EVIDENTIAL MATTER

5.7 APPENDICES

6.0 REFERENCE MATERIAL

6.1 DEFINITIONS

6.2 ACRONYMS

6.3 EXHIBITS

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 8

1.0 INTRODUCTION

1.1 PURPOSE

The purpose of this document is to provide an understanding of the business processes involved in extinguishment, conducted by M&AM.

In accordance with OMB Circular A-123: Management’s Responsibility to Internal

Control, an assessment was conducted to evaluate current business processes with the objective of establishing and documenting formal business processes for implementation.

The procedures detailed in this document were developed as part of the internal controls that have been created to achieve the goals of effective and efficient operations, reliable financial reporting, and compliance with applicable laws and regulations.

1.2 SYSTEMS

Name Description

Data Analysis & Reporting Tool (DART)

DART is a data querying tool utilizing Business Objects that enables users to easily retrieve historical pool and loan data to gain a better understanding of past performance of mortgage-backed securities and answer questions from Issuers and Investors. The tool provides access to information on pool level, loan level, pool disclosure, and loan disclosure data with basic and advanced reporting capabilities.

Ginnie Mae Enterprise Portal (GMEP)

System which acts as the entry point for Issuers, subservicers, and document custodians for accessing Ginnie Mae’s systems for monthly reporting, pool transfers, managing master agreements, etc.

Ginnie Mae Portfolio Analysis Database System

(GPADS)

System used to track counterparty risk using portfolio statistics and performance of Issuers relative to their peer group.

GinnieNET Front end pooling system for pool creation prior to reporting to

RFS.

HMBS Reporting and Administration Module

(HRA)

System of record for monthly collection of HMBS (HECM mortgage-backed securities) data; serves as the single point for electronic reporting of monthly pool, loan, and various data related to the HMBS Program.

Integrated Pool Management System (IPMS)

Electronic system established by Ginnie Mae for the disbursement and management of commitment authority (CA) to guarantee MBS, enabling Ginnie Mae to monitor the eligibility status and the CA accounts of all Issuers.

Master Agreement Management System

(MAMS)

System that provides Issuers with an automated method for creating, searching, viewing, and certifying agreements.

Pool Transfer System (PTS)

PTS provides an automated means for the Issuer to initiate and update pool transfer request information, import and update pool numbers being transferred, view and receive the associated approval documentation, approve or reject pool transfer requests from the Selling Issuer, access and view reports, and confirm associated transfer fees. PTS also provides electronic

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 9

Name Description notifications of transfer requests and reports to Ginnie Mae Account Executives and the Pool Processing Agent (PPA).

Reporting and Feedback System (RFS)

Centralized data collection and processing system for Ginnie Mae Monthly Investor Reporting and related functions, serving as the single point for electronic reporting of monthly pool, loan, and various data related to the MBS Program.

Salesforce Application used for tracking Issuer status and document repository from the point of application to the Ginnie Mae MBS program through extinguishment or another program exit.

1.3 SUMMARY OF PHASES

PHASE 1 – ORGANIZE

During the Organize phase, Ginnie Mae initiates pre-extinguishment activities. This includes gathering and distributing preliminary extinguishment information to appropriate stakeholders, establishing Ginnie Mae’s stakeholder coordination strategy, and providing a “soft” notification to key external stakeholders.

PHASE 2 – PRE-SITE VISIT

Once Ginnie Mae makes the decision to extinguish an Issuer, OIPM is responsible for restricting the extinguished Issuer’s access to CA and ability to facilitate pool transfers, if applicable. Identification of the collateral, documentation, and data associated with the extinguished Issuer’s Ginnie Mae portfolio is also performed during this phase. Ginnie Mae must proactively coordinate stakeholder involvement and extinguishment activities to facilitate efforts during the Site Visit phase.

PHASE 3 – SITE VISIT

During the Site Visit, Ginnie Mae will successfully deploy extinguishment teams to required locations, execute on-site Default Playbook steps and obtain data and documentation listed in the Integrated Data Collection Plan (IDCP), and effectively coordinate across multiple stakeholder teams. The key responsibility of the extinguishment team is to secure data and documentation associated with the Ginnie Mae portfolio to promote the continuity of servicing operations and to minimize impact to the borrowers once the portfolio is transferred to its MSS(s).

PHASE 4 – SITE VISIT CLOSEOUT

After the Site Visit, Ginnie Mae confirms the portfolio was successfully onboarded, documents the extinguishment and lessons learned, and makes all required system updates to reflect the new Default Issuer ID.

1.4 ACTIVITY TIMELINE

The extinguishment process is unique for each Issuer and its situation; as such, the timeframe for the extinguishment process will vary for each Issuer.

1.5 ROLES AND RESPONSIBILITIES

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 10

A RACI Matrix is a tool used to identify stakeholder participation and roles in interdepartmental processes. Responsible parties complete the task. Accountable parties delegate work to the Responsible parties and must approve the work that

Responsible parties complete. Consulted parties are those whose input and opinions are sought. Informed parties are kept apprised on progress against key milestones in the process.

Each phase of this process has its own respective RACI Matrix, which is used to provide additional detail as to who will be involved in each of the below steps, and in what capacity.

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 11

2.0 ORGANIZE

2.1 SCOPE

An Issuer may enter the extinguishment process if:

The Issuer did not cure the violation(s) cited in a Notice of Violation (NOV);

The trigger(s) identified in Enhanced Monitoring and Management (EMM) is severe enough to warrant immediate extinguishment;

The Issuer meets the criteria for Immediate Default per Section 10.01(a) of the

Guaranty Agreement and Ginnie Mae determines extinguishment is in the best interest of Ginnie Mae and the MBS program;

An external party (e.g., Federal Deposit Insurance Corporation [FDIC]) places the Issuer in receivership, conservatorship, etc.

During Organize, Ginnie Mae initiates extinguishment activities. The purpose of these activities is to gather critical information on the Issuer, aggregate agreements related to the Issuer, and identify key stakeholders that may be involved in the extinguishment, such as regulatory bodies and insuring agencies. Outputs from this process include the Extinguishment Justification Memo, Pre-Extinguishment Worksheet, Communication Plan, Soft MSS Notification Letter, and a Portfolio Valuation performed by OER.

2.2 BUSINESS PROCESS DOCUMENTATION

Phase 1:

Organize Process Flows

Phase 1 - Organize -

Business Process Documentation.pdf

PROCESS DURATION

The estimated process duration of the Organize Phase is contingent upon the amount of lead time Ginnie Mae has available. In certain circumstances, Ginnie Mae may have ample lead time (e.g., 7-8 days) to complete Organize activities, whereas other circumstances may dictate an expedited Organize process (e.g., 3-4 days). Therefore, the duration will vary on a case-by-case basis depending on the Issuer that is being extinguished.

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 12

2.3 ROLES AND RESPONSIBILITIES

Phase 1:

Organize RACI Matrix

Phase 1 - Organize -

RACI Matrix.pdf

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 13

2.4 PROCEDURES

A. Procedures B. Inputs: EMM/Special Situation outputs will be leveraged as inputs for Phase 1

(i.e. Issuer information and agreements, Extinguishment Justification Memo, etc.)

Outputs: Extinguishment Justification Memo, Pre-Extinguishment Worksheet, Communication Plan, Soft MSS Notification Letter, VAPE Portfolio Valuation Systems: Salesforce, GPADS, IPMS, MAMS, GMEP, RFS, DART

Note: The following Procedure steps correspond to Extinguishment Phase 1:

Organize as referenced in the Business Process Documentation in 2.2 and reflect the typical extinguishment process. However, in certain circumstances, the sequencing of procedure steps listed below may vary in duration and become “trailing items” completed during the Pre-Site Visit Phase.

1. Gather all relevant documentation compiled during EMM and Special

Situation (1.01)

The Mortgage Banking Analyst (MBA) assigned to the Issuer consults with the Default & Extinguishment Support Contractor (DESC) and the Account Executive (AE) to compile EMM/Special Situation documentation.

Documentation can include, but is not limited to, the Enhanced Monitoring Plan, Remediation Plan Tracker, or Special Situation Justification Memo. If EMM and/or Special Situation documentation exists, the MBA and AE will consult with DESC to make relevant updates to the information, as needed.

The MBA researches whether the Issuer facing extinguishment has a valid Acknowledgement Agreement (AA) by utilizing the current AA Inventory Tracker maintained by the M&AM MBA on Microsoft OneDrive. The MBA also checks the Issuer's record in Salesforce for a copy of the AA to confirm the existence of an AA.

2. Draft Soft MSS Notification Letter (1.02)

OIPM’s MSS COR drafts the Soft MSS Notification Letter, which is the notification used to notify the MSS/HMBS Sub-Contractor of impending portfolio transfer.

A template for the Soft MSS Notification Letter is included in Exhibit E-1.

a. Identify Soft MSS Notification Letter Template (1.02.1)

The MSS COR retrieves the most recent Soft MSS Notification Letter template.

b. Draft the Soft MSS Notification Letter (1.02.2)

The MSS COR coordinates with the MBA to draft the “Soft Notification” to the MSS, withholding specific Issuer information (Until after the signing of the Justification Memo).

c. Submit the Soft MSS Notification Letter (1.02.3)

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 14

The MSS COR submits the draft MSS Notification Letter to the M&AM Director of OIPM for review and approval.

3. Approve Soft MSS Notification Letter (1.03)

a. Is the Soft MSS Notification Letter Approved? (1.03.1)

The MSS COR submits the draft Soft MSS Notification Letter to the

M&AM Director for review and approval. If the Soft MSS Notification

Letter is approved, proceed to Step 1.04. If revisions to the Letter are necessary, proceed to Step 1.03.2.

b. Revise Soft MSS Notification Letter (1.03.2)

The MSS COR incorporates and/or addresses the M&AM Director’s comments and prepares a revised Soft MSS Notification Letter. Proceed to Step 1.02.2.

c. Submit the Soft MSS Notification Letter (1.03.3)

The MSS COR submits the approved MSS Notification Letter to the MSS(s).

4. Receive Soft MSS Notification Letter (1.04)

The MSS(s) receives the approved MSS Notification Letter from the MSS COR.

5. Prepare Extinguishment Justification Memo (1.05)

a. Draft Extinguishment Justification Memo (1.05.1)

The purpose of the Extinguishment Justification Memo is to provide a formal document supporting Ginnie Mae’s decision to extinguish an Issuer from the MBS Program. Additionally, the Extinguishment Justification Memo documents M&AM’s decision to proceed with its chosen extinguishment option.

Please see Exhibit E-2 for a template of the Extinguishment Justification Memo.

The M&AM Director is responsible for preparing the Extinguishment Justification Memo. The Justification Memo includes the following sections:

• Recommendation

• Executive Summary

• Rationale for Recommendation

• Overview of Key Issuer Information

• Issuer CAMELS Analysis

• Ginnie Mae Actions Taken To-Date

• Action Items and Key Considerations

• Approvals & Key Decisions/Change Log

The Recommendation section includes a recommendation that the Issuer be extinguished per the Ginnie Mae Director of M&AM. The section

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 15 includes an explanation of why the Issuer should be designated extinguished, including the specific violations that led to the recommendation, and recommended next steps.

The Executive Summary section includes relevant portfolio information, as well as any recent events leading to the Issuer’s extinguishment designation. It will also include a timeline graphic showing key events pertaining to the Issuer’s risk(s) and any action previously taken by Ginnie Mae with regard to the identified risk(s).

The purpose of the Rationale for Recommendation section is to explain why the Issuer is recommended for extinguishment status, including specific determinations based on recent actions/events. For each determination, cite the specific Ginnie Mae MBS Guide, Guaranty Agreement, or other relative guidance requirement that was breached.

In addition, provide further elaboration on the Issuer’s condition specific to each determination. The rationale as to why the extinguishment option was chosen instead of alternative extinguishment options should also be discussed.

The Overview of Key Issuer Information section includes general details about the Issuer. The majority of the information required can be located in RFS or Salesforce. This information is divided into two tables, Corporate Information and Portfolio Information.

CAMELS Analysis is a financial methodology that is used to evaluate an Issuer’s financial standing based on six factors represented by the acronym “CAMELS”. The six factors are Capital Adequacy, Asset Quality, Management, Earnings Quality, Liquidity, and Stability. This section provides a breakdown of each factor regarding the Issuer’s current status. The information to populate this section is located in RFS under Corporate Watch on the Mortgage Bankers Rating Detail Report.

The Ginnie Mae Actions Taken To-Date section lists any actions Ginnie Mae has taken prior to the drafting of the Extinguishment Justification Memo regarding the Issuer. The following are potential actions that may be included:

• When the Issuer was placed on the Watch List

• The outcome of any Office of Enterprise Risk (OER) credit reviews

• Communications with the Issuer regarding the risks identified

• Communications internally about the Issuer and the risks identified

• When Ginnie Mae became aware that requirements were breached

• Any prior Enhanced Monitoring Plans, Unilateral Notifications, Notice of Violations, or Letters of Understanding

• When the Extinguishment Justification Memo was prepared

Given the Issuer’s current condition and the recommendation to pursue immediate termination and extinguishment, the Action Items and Key Considerations section details the M&AM leadership recommended action items to be completed. Action items may include issuing a final NOV, assigning an MSS to the potential extinguishment, proposing an extinguishment date, and other steps that may be needed to prepare for the extinguishment.

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 16

The Approvals & Key Decisions/Change Log section includes spaces for the four Ginnie Mae signatures required to approve the Extinguishment Justification Memo: The Issuer’s MBA, the Director of M&AM, the Senior Vice President (SVP) or Designee of OIPM, and the Chief Risk Officer.

The Key Decisions/Change Log serves as an audit trail for significant events/changes to the Extinguishment Justification Memo after the initial approval.

If a Justification Memo has already been drafted for Special Situation and was collected during Step 1.01, this information can be leveraged to draft the Extinguishment Justification Memo. Ginnie Mae can also leverage a completed Extinguishment Justification Memo from a recent extinguishment for additional guidance when performing Step 1.05.1.

b. Evaluate and Determine Extinguishment Options (1.05.2)

Utilizing the methodology outlined in the Extinguishment Waterfall White Paper, the M&AM Director evaluates the Issuer’s situation and determines the appropriate extinguishment path to recommend via the Extinguishment Justification Memo. As of the date of this SOP, Ginnie Mae has contemplated the following paths:

• Acknowledgement Agreement (AA)

• Voluntary Sale

• Extinguishment with Regulatory Agency Involvement

• Interim Servicing Agreement (ISA)

• Rapid Relocation (Rapid Relo)

• Transferring the Extinguished Issuer’s Portfolio to Ginnie Mae’s

MSS(s)

Given the unique nature of all Issuer extinguishments, Ginnie Mae considers the available extinguishment options and determines the most advantageous strategy for Ginnie Mae and its risk appetite, investors, and the affected borrowers. Pros and cons of each extinguishment option and analysis conducted to arrive at the chosen extinguishment path is documented in the “Analysis Extinguishment Paths” template in the Justification Memo.

In certain situations, Ginnie Mae may consider combining one or more of the aforementioned extinguishment options. For example, for the extinguishment of an Issuer with a large portfolio or portfolios spanning multiple Ginnie Mae programs, Ginnie Mae may opt to sell a portion of the portfolio while transferring the remaining portion to the MSS(s). Each Issuer extinguishment is unique in nature; therefore, M&AM evaluates the extinguishment option(s) on a case-by-case basis. Ultimately, M&AM memorializes its decision in the Extinguishment Justification Memo.

6. Provide Input on Extinguishment Justification Memo (1.06)

OER’s Counterparty Risk Director reviews the analysis and methodology performed in Step 1.05 and provides feedback to the M&AM Director.

7. Provide Assistance on Extinguishment Justification Memo (1.07)

DESC reviews the analysis and methodology performed in Step 1.05 and provides feedback to OIPM.

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 17

8. Brief Extinguishment Justification Memo Strategy to Ginnie Mae Leadership

(1.08)

The M&AM Director will schedule a meeting with Ginnie Mae executive leadership to brief the extinguishment strategy and solicit feedback, if applicable.

9. Approve Extinguishment Justification Memo (1.09)

a. Incorporate Feedback from OER and DESC (1.09.1)

The M&AM Director coordinates with the Senior/Lead MBA to review the feedback from OER and DESC and apply appropriate updates.

b. Submit Extinguishment Justification Memo (1.09.2)

The M&AM Director submits the Extinguishment Justification Memo to the SVP of OIPM/Designee and the Chief Risk Officer (CRO) from OER for review and approval.

c. Is Extinguishment Justification Memo Approved? (1.09.3)

The OIPM SVP/Designee and CRO review the Extinguishment

Justification Memo and M&AM’s recommendation. If the OIPM

SVP/Designee and CRO approve the Extinguishment Justification

Memo, the M&AM Director proceeds with initiating the extinguishment and proceeds to the step appropriate for the extinguishment path selected:

For Acknowledgement Agreement, proceed to Step 1.10;

For Extinguishment with Regulatory Agency Involvement, proceed to Step 1.11;

For Interim Servicing Agreement, proceed to Step 1.12;

For Rapid Relo, proceed to Step 1.13; or For Transfer to MSS/HMBS Sub-Contractor, proceed to Step

1.14.

If the OIPM SVP/Designee and CRO do not approve the Extinguishment

Justification Memo, they provide feedback to the M&AM Director, specifying the necessary revisions. If revisions are necessary, proceed to Step 1.09.4.

d. Revise Extinguishment Justification Memo (1.09.4)

If the OIPM SVP/Designee and CRO do not approve the Extinguishment

Justification Memo, the M&AM Director revises the Extinguishment

Justification Memo to incorporate the feedback received and proceeds to Step 1.09.2.

10. Acknowledgement Agreement (1.10)

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 18

If the M&AM Director invokes the AA as indicated by the Extinguishment Justification Memo, proceed to the AA Process Flow. The AA Process Flow can be referenced in Exhibit 22.

11. Extinguishment with Regulatory Agency Involvement (1.11)

In certain circumstances, Ginnie Mae may need to coordinate extinguishment activities with a Regulatory Agency (FDIC, FHFA, NCUA, etc.) and/or Insuring Agencies. The M&AM Director conducts a Situation Assessment Call with the Regulator(s) involved with the Issuer extinguishment and determines roles and responsibilities of all stakeholders.

The M&AM Director then appoints an Extinguishment Lead to interface with the regulator/insuring agency and coordinate communication to clarify roles and responsibilities. Due to the unique nature of coordinating an Issuer extinguishment with a Regulator, further action will be determined on a case-by-case basis.

12. Interim Servicing Agreement (1.12)

If the M&AM Director invokes the ISA extinguishment option as indicated by the Extinguishment Justification Memo, proceed to the ISA Process Flow.

The ISA Process Flow can be referenced in Exhibit 23.

13. Rapid Relo (1.13)

If the M&AM Director invokes the Rapid Relo extinguishment option as indicated by the Extinguishment Justification Memo, proceed to the Rapid Relo Process Flow. The Rapid Relo Process Flow can be referenced in Exhibit 24.

14. Transfer to MSS/ HMBS Sub-Contractor (1.14)

Ginnie Mae assumes full ownership of the extinguished Issuer’s portfolio and appoints one or both of its MSSs to perform servicing activities on its behalf.

If the approved extinguishment strategy is to transfer the extinguished

Issuer’s portfolio to the Ginnie Mae MSS or HMBS Sub-Contractor, proceed to Step 1.15.

15. Engage the Field Review Contractor (FRC) and Master Sub-Servicer (MSS) (1.15)

a. Inform FRC and MSS of Issuer Extinguishment (1.15.1)

The FRC COR and MSS COR inform the FRC and MSS, respectively, of the imminent Issuer extinguishment.

b. Provide Technical Direction to FRC and MSS (1.15.2)

The FRC COR and MSS COR provide technical direction to their respective contractors to prepare for the Issuer extinguishment.

Technical direction can be described as formally outlining, pricing, and issuing the work orders through the Statement of Work for the extinguishment. The FRC and the MSS complete these activities concurrently.

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 19

Please see Exhibit E-3 for a template of the Technical Direction.

MSS: The MSS COR issues technical direction to the MSS. The MSS is required to develop an Issuer Extinguishment Contingency Plan upon contract award. In the event that Ginnie Mae identifies a potential Issuer extinguishment, the MSS COR requests that the MSS update its Issuer Extinguishment Contingency Plan, including an updated Capacity Plan.

Note: Issuer extinguishment Contingency Plans should be updated on annual basis.

FRC: The FRC COR issues work order to the FRC.

16. Compile Existing Issuer Master Agreements (1.16)

The MBA compiles the Issuer’s existing Form HUD-11702; Form HUD-

11707; Forms HUD-11709 and HUD-11720 to support the Custodial Bank

Account Freeze Letter; and Form HUD-11715 to support the Document

Custodian Letter.

Note: Access to MAMS is required to extract the extinguished Issuer’s

Master Agreements.

a. Compile Current Year HUD Forms (1.16.1)

The MBA accesses MAMS and saves copies of approved/completed current year HUD Forms: 11702, 11707, 11709, 11715, 11720.

b. Distribute Extinguished Issuer’s Master Agreements (1.16.2)

The MBA emails copies of the extinguished Issuer’s Master Agreements to the extinguishment Team Leads (as identified in the Communication

Plan in Step 1.20) and DESC.

17. Provide Input for Pre-Extinguishment Worksheet (1.17)

The FRC provides the MBA with any custodial and corporate bank account information, including custodial account reconciliations, obtained from the

FRC’s most recent field review.

18. Prepare Pre-Extinguishment Worksheet (1.18)

DESC prepares the Issuer Pre-Extinguishment Worksheet. The Issuer Pre-

Extinguishment Worksheet is a tool to provide a summary of critical Issuer information that details the reason for extinguishment as well as corporate, portfolio, and compliance overviews of the Issuer.

A template for the Issuer Pre-Extinguishment Worksheet is included in

Exhibit E-4.

a. Identify Pre-Extinguishment Worksheet Template (1.18.1)

DESC retrieves the most recent Issuer Pre-Extinguishment Worksheet template.

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 20

b. Obtain Necessary Information (1.18.2)

DESC consults the MBA to obtain the most recent information needed to prepare the Issuer Pre-Extinguishment Worksheet using information obtained during the Issuer’s most recent compliance review and information available in GPADS and MAMS.

c. Complete Issuer Pre-Extinguishment Worksheet (1.18.3)

DESC completes the Issuer Pre-Extinguishment Worksheet.

d. Submit Issuer Pre-Extinguishment Worksheet (1.18.4)

DESC submits the completed Issuer Pre-Extinguishment Worksheet to the MBA for review and approval.

19. Approve Issuer Pre-Extinguishment Worksheet (1.19)

a. Is Issuer Pre-Extinguishment Worksheet Approved? (1.19.1)

The MBA reviews the Issuer Pre-Extinguishment Worksheet for completeness. If the MBA approves the worksheet, proceed to Step 1.20.

If revisions to the worksheet are necessary, proceed to Step 1.19.2.

b. Revise Issuer Pre-Extinguishment Worksheet (1.19.2)

DESC incorporates and/or addresses the MBA’s comments and prepares a revised Issuer Pre-Extinguishment Worksheet. Proceed to Step 1.18.4.

20. Prepare Communication Plan (1.20)

The MBA and DESC develop a communication strategy for the Issuer extinguishment. The communication strategy is developed to establish a communication protocol, gather Point of Contact (POC) information, and determine the initial communication schedule for the extinguishment, promote effective communication, and serve as a guide throughout the extinguishment process.

Note: Per guidance from the Attorney General, all regional and national guidance should be followed in the event of emergency or other extenuating circumstance. If Ginnie Mae or its contractors have questions about how to proceed with travel during these situations, they should contact the relevant

Contracting Officer.

A template for the Communication Plan is included in Exhibit E-5.

a. Identify Communication Plan Template (1.20.1)

DESC retrieves the most recent Communication Plan template.

b. Identify Team Members and Complete Extinguishment Team Matrix (1.20.2)

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 21

Team members that will participate in the Extinguishment will be identified and designated by OIPM through the Extinguishment Team Matrix, which is a component of the Communication Plan. Upon identifying all team members, the MBA will draft and complete the Extinguishment Team Matrix.

c. Draft Communication Plan (1.20.3)

DESC prepares the initial Communication Plan, which identifies stakeholders, communication needs, communication channels, and roles and responsibilities.

21. Approve Communication Plan (1.21)

a. Is the Communication Plan Approved? (1.21.1)

The Senior/Lead MBA reviews the Communication Plan for completeness. If the Senior/Lead MBA approves the worksheet, the

Communication Plan is sent to the M&AM Director for approval. If the

M&AM Director approves the Communication Plan, proceed to Step 1.22.

If revisions to the plan are necessary, proceed to Step 1.21.2.

b. Revise Communication Plan (1.21.2)

DESC addresses the Senior/Lead MBA/M&AM Director’s comments and prepares a revised Communication Plan. Proceed to Step 1.21.1.

22. Distribute Communication Plan (1.22)

The Senior/Lead MBA distributes the approved Communication Plan to all Extinguishment Team Members, including contractor support.

23. Provide Scenario Guidance to VAPE Contractor for Initial Valuation (1.23)

Using the Issuer Pre-Extinguishment Worksheet information, servicing tapes, and additional insights from collateral and origination file reviews, as applicable, OER provides scenario guidance to the Valuation, Modeling, and Policy Guidance (VAPE) Contractor, factoring in sensitivities, inputs, and other qualitative and quantitative factors affecting the value of the portfolio.

Servicing tapes can be obtained from data extracts from EWODS, IPMS, Agency files, Subservicer, etc. Note: If data for the current month is not available, the previous month may be used.

a. Perform Initial Valuation Using Established Assessment Criteria (1.23.1)

The VAPE Contractor uses the scenario guidance from OER, as well as the Issuer data, to determine an Initial Valuation of the portfolio, which projects mortgage-servicing rights (MSR) cash flows. The VAPE

Contractor calculates the fair market value of the portfolio to determine the price a third-party buyer would expect to pay, as well as the cash flows to service the portfolio, which include, but are not limited to, servicing income, servicing costs, loan buyouts, and expected recoveries.

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 22

b. Submit Initial Valuation (1.23.2)

Upon completion of the Initial Valuation, the VAPE Contractor submits the Initial Valuation to the Economic Modeling Director for review and approval.

24. Review and Approve Initial Valuation (1.24)

a. Approve Initial Valuation (1.24.1)

The Economic Modeling Director is responsible for approving the Initial

Valuation once the VAPE Contractor completes the model. If the

Economic Modeling Director approves the Initial Valuation, proceed to

Step 1.25.

25. Note that Quarter-End Entry is Necessary (1.25)

The Office of the Chief Financial Officer (OCFO) records the necessary quarter-end accounting entries for this extinguishment.

2.5 KEY INTERNAL CONTROLS

# Control Name Control Activity Control

Frequency Control Nature

Control Type

Review and approve

Extinguishment Justification Memo.

The Extinguishment Justification Memo is prepared by the Lead Mortgage Banking Analyst and reviewed and approved by the M&AM Director. Subsequently, the OIPM SVP/Designee and CRO review the Justification Memo and approve the selected extinguishment option, if supported.

Ad Hoc Preventive Manual

Review and approve Issuer Pre-

Extinguishment Worksheet.

The Lead Mortgage Banking Analyst reviews the Issuer Pre- Extinguishment Worksheet, prepared by DESC, for completeness. The Lead Mortgage Banking Analyst approves the Pre- Extinguishment Worksheet.

Ad Hoc Preventive Manual

Contingency & Capacity Plan

Review & Approval

*Future state control

The DDC prepares the Draft Extinguishment Contingency and Estimated DDC Capacity Plans. The plans are submitted to Ginnie Mae for review and approved by the

OIPM MBA.

Upon Request and

Annually Preventative Manual

Initial Valuation of the Issuer's portfolio.

The Valuation, Modeling, and Policy Guidance (VAPE) Contractor prepares and submits the initial portfolio valuation to the Economic Modeling Director. The Economic Modeling Director

Ad Hoc Preventive Manual

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 23

Control

Frequency Control Nature

Control Type approves the model via email once complete.

Review Extinguishment policies, procedures, and methodologies.

On an annual basis, the M&AM Director reviews the Extinguishment policies, procedures, and methodologies for relevance and reasonableness. The M&AM Director approves the corresponding policies, procedures, and methodologies.

Annual Detective Manual

2.6 EVIDENTIAL MATTER

1. Extinguishment Policies, Procedures, and Methodologies – Reviewed by the M&AM Director for relevance and reasonableness on an annual basis. The M&AM Director approves the corresponding policies, procedures, and methodologies.

2. Soft MSS Notification Letter – Notification prepared by the MSS COR (OIPM) to notify the MSS/HMBS Subcontractor of impending portfolio transfer. Specific Issuer information will be withheld until after the signing of the Justification Memo.

3. Issuer Pre-Extinguishment Worksheet – Worksheet prepared by DESC that details the reason for extinguishment and corporate, portfolio, and compliance overviews of the Issuer.

4. Communication Plan – Plan created by DESC to establish a Communication protocol, gather POC information, and determine the initial communication schedule for the extinguishment; promote effective communication; serve as a guide throughout the extinguishment process.

5. VAPE Portfolio Initial Valuation – Valuation calculated by VAPE that uses the scenario guidance from OER, as well as the Issuer data, to determine an Initial Valuation of the portfolio and the fair market value of the portfolio.

2.7 APPENDICES

Refer to the applicable Exhibits at the end of the SOP. These are found on Page 69.

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 24

3.0 PRE-SITE VISIT

3.1 SCOPE

Following aggregating pertinent Issuer information in the Organize phase, the Pre- Site Visit phase includes drafting and approving formal communications to parties affected by the extinguishment including the Document Custodian, MSS, impacted Ginnie Mae Program Offices, and the Issuer being extinguished.

With the inputs from the Issuer Pre-Extinguishment Worksheet and the Extinguishment Justification Memo, Ginnie Mae prepares to execute the chosen extinguishment path.

3.2 BUSINESS PROCESS DOCUMENTATION

Phase 2:

Pre-Site Visit Process Flows

Phase 2 - Pre-Site

Visit - Business Process Documentation.pdf

The estimated process duration of the Pre-Site Visit Phase is contingent upon the amount of lead time Ginnie Mae has available. In certain circumstances, Ginnie Mae may have ample lead time (e.g., 30 days) to complete Pre-Site

Visit activities, whereas other circumstances may dictate an expedited Pre-

Site Visit process (e.g., 3-7 days). Therefore, the duration will vary on a case-by-case basis depending on the Issuer that is being extinguished.

3.3 ROLES AND RESPONSIBILITIES

Phase 2:

Pre-Site Visit RACI Matrix

Phase 2 - Pre-Site

Visit - RACI Matrix.pdf

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 25

3.4 PROCEDURES

A. Procedures Inputs: Pre-Extinguishment Worksheet, Communication Plan, Soft MSS

Notification Letter, Extinguishment Justification Memo.

Outputs: NOV Extinguishment Letter, Gold Copy Template, Notifications (Funds

Custodian, Document Custodian, Insuring Agencies, MSS), Issuer Fidelity Bond and Errors & Omissions Certificates, Fidelity Bond Placeholder Letter (Claim

Letter), Situation Assessment Call Minutes, Sec Memo, Integrated Data

Collection Plan (IDCP), Master Agreements, Power of Attorney (POA)

Templates, MERS Notification

Systems: Salesforce, IPMS, GMEP, PTS, MAMS, GinnieNET.

Note: The following Procedure steps correspond to Extinguishment Phase 2:

Pre-Site Visit as referenced in the Business Process Documentation in 3.2 and reflect the typical process. However, in certain circumstances, the sequencing of procedure steps listed below may vary in duration and become “trailing items” completed during the Site Visit Phase.

1. Prepare Notice of Violation (NOV) Extinguishment Letter (2.01)

The Senior/Lead Mortgage Banking Analyst (MBA) drafts the NOV

Extinguishment Letter to initiate extinguishment activities. The purpose of the

NOV Extinguishment Letter is to inform the Issuer of its extinguishment from the

Ginnie Mae MBS Program.

A template for the NOV Extinguishment Letter is included in Exhibit E-6.

a. Identify the NOV Extinguishment Letter template (2.01.1)

The Senior/Lead MBA retrieves the most recent NOV Extinguishment Letter template.

b. The Senior/Lead MBA prepares the NOV Extinguishment Letter (2.01.2)

Tasks performed by the Senior/Lead MBA include entering the name and Issuer ID of the extinguished Issuer, drafting the explanation of reason for extinguishment, including references to the Ginnie Mae Mortgage-Backed Securities (MBS) Guide and Ginnie Mae Guaranty Agreement(s), drafting extinguishment instructions, and listing the records that the extinguished Issuer must provide. The Senior/Lead MBA must also attach the most recent pool and loan listing from DART as an attachment.

c. Submit the Draft NOV Extinguishment Letter (2.01.3)

The Senior/Lead MBA consults with the M&AM Director to ensure the document captures the reason(s) for extinguishment outlined in the Extinguishment Justification Memo and submits the draft NOV Extinguishment Letter to the Office of General Counsel (OGC) for legal review. The Senior/Lead MBA should note that the final Pool/Loan listing may be added after draft is returned from OGC and put into final format for signature.

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 26

2. Review NOV Extinguishment Letter (2.02)

a. Is the NOV Extinguishment Letter Approved? (2.02.1)

OGC performs a legal review of the document. If the NOV Extinguishment

Letter is approved by OGC, proceed to Step 2.03. If revisions are necessary, proceed to Step 2.02.2.

b. Revise NOV Extinguishment Letter (2.02.2)

The Senior/Lead MBA addresses OGC’s comments and prepares a revised

NOV Extinguishment Letter. Proceed to Step 2.01.3.

3. Review and Approve NOV Extinguishment Letter (2.03)

a. Is the NOV Extinguishment Letter Approved? (2.03.1)

The Senior/Lead MBA submits the OGC-approved NOV Extinguishment

Letter to the SVP/Designee of OIPM for review and approval. If the NOV

Extinguishment Letter is approved, proceed to Step 2.04. If revisions are necessary, proceed to Step 2.03.2.

b. Revise NOV Extinguishment Letter (2.03.2)

The Senior/Lead MBA addresses the OIPM SVP/Designee’s comments and prepares a revised NOV Extinguishment Letter. Proceed to Step 2.03.1.

4. Coordinate with OCFO to Determine Appropriate New Default Issuer ID (2.04)

MBA coordinates with OCFO to determine the appropriate New Default (i.e.

“9000”) Issuer ID.

5. Provide Input on New Default Issuer ID (2.05)

OCFO validates the New Default Issuer ID to the MBA.

6. Create New Default Record in Salesforce and IPMS for Document Storage (2.06)

Note: The Senior/Lead MBA must ensure they have appropriate access to IPMS and Salesforce to perform this step.

a. The Senior/Lead MBA creates a new Issuer in IPMS. (2.06.1)

b. The Senior/Lead MBA creates a new Issuer in Salesforce. (2.06.2)

7. Draft Sec Memo to Establish New Default Issuer ID (2.07)

The Sec Memo is the formal document to establish and communicate the New

Default (i.e. “9000”) Issuer ID.

A template for the Sec Memo is included in Exhibit E-7.

a. Identify the Sec Memo template (2.07.1)

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 27

The MBA retrieves the most recent Sec Memo template, requesting the most recent Sec Memo ID Number for use.

b. Draft Sec Memo (2.07.2)

The MBA prepares the required Sec Memo by:

i. Marking the field for New Issuer and inputting the New Default Issuer ID as the Issuer Number, “Ginnie Mae – [insert extinguished Issuer’s legal name, followed by its Issuer Number]” as the Legal Name

ii. Inputting “c/o [insert MSS]” followed by the MSS’s address in the appropriate fields.

iii. The Senior/Lead MBA’s contact information should be used to fill in the Telephone No. and GNMA Contact fields.

iv. The MSS COR should be noted in the Other field.

8. Approve Sec Memo to Establish New Default Issuer ID (2.08)

a. Is the Sec Memo Approved? (2.08.1)

The MBA submits the draft Sec Memo to the Senior/Lead MBA for review and approval. If the Sec Memo is approved, it will be submitted for OIPM processing. If revisions are necessary, proceed to Step 2.08.2.

b. Revise Sec Memo (2.08.2)

The MBA addresses the Senior/Lead MBA comments and prepares a revised

Sec Memo. Proceed to Step 2.08.1.

9. Coordinate MSS Security Officer Access for New Default Issuer ID (2.09)

The MSS consults OIPM to create two new MSS Security Officer accounts following the creation of the new Default Issuer ID.

Note: Direction to the Pool Processing Agent/Central Paying and Transfer Agent

(PPA/CPTA) (Currently Bank of New York Mellon (BNYM) as of the date of submission for this SOP) must be made to accept Form HUD-11702 from the

MSS with a different Issuer ID Number (physical signature page); AND approval to accept blank Forms HUD-11709/HUD-11720, giving the MSS 30 days to finalize and upload signed forms. The MSS should also work with the PPA/CPTA to setup the HUD-11715 for Ginnie Mae's DDC.

a. Complete Ginnie Mae Systems Access Issuer Security Officer Registration (2.09.1)

The MSS completes the latest version of the registration form from Appendix

III-29 of the Ginnie Mae MBS Guide. At least two Security Officers must be designated, one Security Officer for registering users into GMEP, and a second Security Officer to approve those users.

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 28

b. Submit to PPA/CPTA (2.09.2)

Completed forms are sent to the Ginnie Mae Security Administrator, which is currently the PPA/CPTA.

10. Approve MSS Security Officer Access for New Default Issuer ID (2.10)

a. Receive Security Officer Registration Request (2.10.1)

PPA/CPTA will review and approve the MSS Security Officer Access for New Default Issuer ID.

b. Send confirmation to OIPM and the MSS (2.10.2)

PPA/CPTA will notify OIPM and the MSS that Security Officer registration is complete.

11. Submit the New Default Issuer ID (2.11)

The approved Sec Memo is submitted by the MBA to OSO for processing and to ensure Issuer is not published as a new Issuer on website.

12. Determine if Funding in Finance Account is Sufficient (2.12)

In advance of the on-site extinguishment, OCFO determines if the funds available in the Finance Account are sufficient to cover immediate cash outflows

(e.g., upcoming pass-through payments, borrower draws, etc.). For Single

Family portfolios, the amount of funds available in the Finance Account need to cover the next month’s payment to security holders. For reverse portfolios, Ginnie Mae needs to be prepared to fund upcoming borrower draw payments.

13. Communicate with Treasury/OMB regarding Finance Account Sufficiency (2.13)

OCFO communicates with Treasury/OMB to request appropriations if funds in

Finance Account are not sufficient.

14. Assist with Gold Copy Template Preparation (2.14)

DESC creates the draft Gold Copy Template, which is a crosswalk that reconciles the individual loan and pool numbers across the different systems and sources from which they are drawn.

A template for the Gold Copy Template is included in Exhibit E-8.

a. Obtain Reports Needed for Gold Copy Template Preparation (2.14.1)

DESC obtains the most recent DART Monthly Loan and Monthly Pool reports to identify the initial population of pools and loans in the Ginnie Mae portfolio to be seized. DART reporting is available after the 5th business day of the month. Additionally, DESC obtains a listing of pools issued during the month of the extinguishment from GinnieNET.

b. Obtain Information on Pools Issued During Month of Extinguishment (2.14.2)

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 29

The MBS Specialist (OSO) coordinates with the PPA (currently BNYM) to identify pools issued during the month of extinguishment and any pending/pipeline pooling activity. The information obtained should include loan package number, loan numbers, case numbers, MINs, and settlement date of each pool.

c. Identify Issuer’s Reporting Cutoff Date (2.14.3)

MBS Specialist (OSO) contacts the MBSOA Contractor responsible for RFS to identify the extinguished Issuer's reporting cutoff date.

d. Prepare Gold Copy Template Draft (2.14.4)

DESC prepares a loan crosswalk as of the extinguishment date that includes the Pool #, Issuer Loan #, Ginnie Mae Loan ID #, MERS ID, Agency Case

Number, Subservicer Loan # and Original Loan #. PPA/CPTA also retrieves current origination reports from GinnieNET that is used for Gold Copy

Template preparation.

e. Submit the draft Gold Copy Template to the Senior/Lead MBA (2.14.5)

15. Review Gold Copy Template and Disseminate Loan Lists (2.15)

The Senior/Lead MBA reviews and disseminates the loan lists to Ginnie Mae team members and MSS, FRC, and OSO for confirmation and use in preparing notification letters and performing on-site activities.

Following the transfer to the MSS and Designated Document Custodian (DDC), DESC updates the MSS Loan # and DDC Collateral IDs to complete the Gold

Copy Template. This may occur in either the Site Visit or Site Visit Closeout phase.

16. Draft MSS Response Plan (MRP) (2.16)

The MRP will outline the MSS’s plan for executing the MSS Extinguishment Role.

a. Identify the MSS Contingency Plan (2.16.1)

The MSS/HMBS Sub-Contractor retrieves the most recent MSS Contingency

Plan.

b. Draft the MRP (2.16.2)

The MSS/HMBS Sub-Contractor updates the MSS Contingency Plan to reflect the specific Issuer being extinguished. Once the MSS Contingency

Plan is updated, it will be considered as the MRP.

The MRP will consider factors such as:

i. Size of the extinguished portfolio

ii. Utilization of sub-servicer(s)

iii. Servicing and ancillary systems utilized

iv. Portfolio composition (e.g., Federal Housing Administration [FHA], Veteran Administration [VA], and/or Rural Development [RD]).

S O P # 6 0 3 0 . 0 3 . 0 0 0 3 P a g e | 30

17. Approve MRP (2.17)

a. Is the MRP Approved? (2.17.1)

The MSS submits the draft MRP to the MSS…