Attachment_4_-_Ginnie_Mae_Default_Manual_-_FRC.pdf

Government National Mortgage Association

Default Manual

Revisions and Approvals

Date Document Version Document Revision Description Document Author 5/24/2011 1.0 Initial Release FRC

Approval Date

Approved Version Approver Role Approver Signature

1.0 FRC Project Manager

1.0 Ginnie Mae

Table of Contents

REVISIONS AND APPROVALS

1.0 INTRODUCTION

1.1 Purpose

1.2 Default Process Stakeholders

1.2.1 Internal Stakeholders

1.2.2 External Stakeholders

1.3 Managing the Default Process

1.4 Manual Organization

1.5 Information Sources

1.6 Future Updates to the Default Manual

1.7 Acronyms and Abbreviations

1.8 Approval

2.0 PHASE 0 - PRE-DEFAULT ACTIVITIES

2.1 Ginnie Mae Phase 0 Activities

2.2 FRC Phase 0 Activities

2.3 MSS Phase 0 Activities

3.0 PHASE 1 - PRE-SITE VISIT ACTIVITIES

3.1 Default Decision

3.2 Pre-Site Visit Checklists

3.3 Assignment and Notification of Default Team

3.4 Coordination of Travel Arrangements

3.5 Preparation of Letters

3.6 Default Documentation

3.7 Integrated Default Conference

3.8 Background Briefing Sheet

3.9 Integrated Data Collection Plan

3.10 Integrated Default Plan

4.0 PHASE 2 - SITE VISIT ACTIVITIES

4.1 Ginnie Mae Phase 2 Activities

4.2 MSS Phase 2 Activities

4.3 FRC Phase 2 Activities

4.4 Assistance to Other Parties

4.5 Communication Protocols

4.5.1 Primary Default Point of Contact

4.5.2 Prioritization and Time Constraints

4.5.3 Communication of Default Letter

4.5.4 Conduct of FRC and MSS Personnel

4.5.5 Escalation of Communications

4.5.6 Irregularities or Improper Activity

4.5.7 Coordination with Law Enforcement Personnel

4.6 Data Collection

4.6.1 Pending Account Funds Movement

4.7 FRC Data Analysis

4.8 Required Analyses

4.8.1 Delinquent Mortgages

4.8.2 Guaranty Fee Reconciliation

4.8.3 Reconciliation of Loan Trial Balance

4.8.4 Reconciliation of Mortgage Collateral to Securities Outstanding

4.8.5 Tests of Expected P&I

4.8.6 Reconciliation of P&I Custodial Accounts

4.8.7 Reconciliation of T&I Custodial Accounts

4.8.8 Reconciliation of Other Types of Custodial Accounts

4.8.9 Analysis of Non-Timely funds movement of P&I, T&I, liquidations and claims

4.8.10 Summary of Results

4.8.11 Chronology

4.9 Optional Analyses

4.10 Analytical Analyses

4.10.1 Analysis of claims payments not reported or transferred to Security Holders timely

4.10.2 Analysis of comingling of 203(k) funds

4.10.3 Analysis of Defaulted Issuer’s maintenance of an advance, recovery, and excess funds tracking log

4.11 Escrow Account Analyses

4.12 Lockbox Procedures

4.13 Narrative Analysis

4.14 Subservicer Feedback

4.15 Loan Identification Crosswalk

4.16 Additional Analyses

4.17 Findings and Recommendations

4.18 FRC On-Site Reporting

4.18.1 Status Reports

4.18.2 IDP Status Reports

4.18.3 Account Flow Chart

4.18.4 Cash Accounting Procedures

4.19 Termination of Site Visit

5.0 PHASE 3 - POST-SITE VISIT ACTIVITIES

5.1 Ginnie Mae Phase 3 Activities

5.2 MSS Phase 3 Activities

5.3 FRC Phase 3 Activities

APPENDIX A – PHASE 0 GUIDES AND TEMPLATES

APPENDIX A-1 – MBS/OMF Pre-Default File

APPENDIX A-2 – MBS/OMF Issuer Information Worksheet

APPENDIX A-3 - Issuer Contact Tracking Log

APPENDIX A-4 - Sample Issuer Letter

APPENDIX A-5 - Sample Default Memorandum

APPENDIX A-6 – FRC Issuer Information Worksheet

APPENDIX A-7 - Special Field Review Procedures

APPENDIX B – PHASE 1 GUIDES AND TEMPLATES

APPENDIX B-1 – Date of Default Worksheet

APPENDIX B-2 – Ginnie Mae POC File

APPENDIX B-3 – Default Letter

APPENDIX B-4 – Limited Powers of Attorney

APPENDIX B-5 – Standard MSS Confirmation Letter

APPENDIX B-6 – Bank (Account Freeze) Letter

APPENDIX B-7 – Multifamily Bank Letter for FHA-Required Escrow Accounts

APPENDIX B-8 – Document Custodian Letter

APPENDIX B-9 – Phase I Situation Assessment Guide

APPENDIX B–10 – Template for Background Briefing Sheet

APPENDIX B-11 - Integrated Default Plan Template

APPENDIX C – PHASE 2 GUIDES AND TEMPLATES

APPENDIX C-1 – Guidelines for Delivering Default Letter

APPENDIX C-2 – Notification Memorandum to FHA Commissioner

APPENDIX C-3 – Memorandum to Establish a “9000” Number

APPENDIX C-4 – Example of Escrow Account Analyses

APPENDIX D – PHASE 3 GUIDES AND TEMPLATES

APPENDIX D-1 – Bank Transmittal Letter

APPENDIX D-2 - Ginnie Mae Assessment of Default Execution

APPENDIX D-3 – MSS Assessment of Default Execution

Table of Exhibits

EXHIBIT 1.1 – INTERNAL STAKEHOLDERS

EXHIBIT 1.2 – EXTERNAL STAKEHOLDERS

EXHIBIT 1.3 – PHASES OF THE DEFAULT PROCESS

EXHIBIT 1.4 – OVERVIEW OF THE DEFAULT PROCESS

EXHIBIT 1.5 – INFORMATION SOURCES

EXHIBIT 1.6 -- ACRONYMS AND ABBREVIATIONS

EXHIBIT 2.1 – PHASE 0 – PRE-DEFAULT ACTIVITIES PROCESS

EXHIBIT 2.2 - PHASE 0 CHECKLIST: PRE-DEFAULT ISSUER MONITORING

EXHIBIT 3.1 – PHASE 1 – PRE-SITE VISIT ACTIVITIES PROCESS

EXHIBIT 3.2 -- GINNIE MAE DEFAULT PREPARATION CHECKLIST

EXHIBIT 3.3 -- FRC DEFAULT PREPARATION CHECKLIST

EXHIBIT 3.4 --MSS DEFAULT PREPARATION CHECKLIST

EXHIBIT 3.5 -- INTEGRATED DATA COLLECTION PLAN TEMPLATE

EXHIBIT 4.1 – SITE VISIT ACTIVITIES PROCESS

EXHIBIT 4.2 – GINNIE MAE SITE VISIT CHECKLIST

EXHIBIT 4.3 – MASTER SUBSERVICER SITE VISIT CHECKLIST

EXHIBIT 4.4 – DELINQUENT MORTGAGE ANALYSIS

EXHIBIT 4.5 – GFEE RECONCILIATION SHORTFALLS

EXHIBIT 4.6 – UNFUNDED OR OVER-FUNDED GFEE RECONCILIATION

EXHIBIT 4.7 – LOAN TRIAL BALANCE TO AGGREGATE – TOTAL NUMBER OF LOANS RECONCILIATION

EXHIBIT 4.8 – LOAN TRIAL BALANCE TO POOL/LOAN PACKAGE LEVEL: UPB, FIC, NUMBER OF LOANS

RECONCILIATION

EXHIBIT 4.9 - TEMPLATE FOR RECONCILIATION OF MORTGAGE COLLATERAL TO SECURITIES OUTSTANDING

EXHIBIT 4.10 - TEMPLATE FOR TEST OF EXPECTED P&I (CD POOLS)

EXHIBIT 4.11 - TEMPLATE FOR TEST OF EXPECTED P&I (IR POOLS)

EXHIBIT 4.12 - TEMPLATE FOR RECONCILIATION OF P&I CUSTODIAL ACCOUNTS

EXHIBIT 4.13 - TEMPLATE FOR RECONCILIATION OF T&I CUSTODIAL ACCOUNTS

EXHIBIT 4.14 - TEMPLATE FOR RECONCILIATION OF OTHER NON-T&I ESCROW CUSTODIAL ACCOUNTS

EXHIBIT 4.15 – ANALYSIS OF TIMELY FUNDS MOVEMENT – BORROWER P&I PAYMENTS

EXHIBIT 4.16 – ANALYSIS OF TIMELY FUNDS MOVEMENT – BORROWER T&I PAYMENTS

EXHIBIT 4.17 – ANALYSIS OF TIMELY FUNDS MOVEMENT – AGENCY CLAIM PAYMENTS

EXHIBIT 4.18 – ANALYSIS OF TIMELY FUNDS MOVEMENT - LIQUIDATIONS

EXHIBIT 4.19 - INDICATED AMOUNTS DUE GINNIE MAE AS OF XX/XX/XXXX (DATE OF CLOSEOUT)

EXHIBIT 4.20 – GINNIE MAE-RELATED CUSTODIAL ACCOUNT BALANCES AS OF XX/XX/XXXX (DATE OF CLOSE-

OUT)

EXHIBIT 4.21 – ANALYSIS OF CLAIMS PAYMENTS NOT REPORTED OR TRANSFERRED TO SECURITY HOLDERS TIMELY

EXHIBIT 4.22 – ANALYSIS OF TIMELY REPORTING OF AGENCY CLAIM PAYMENTS TO GINNIE MAE

EXHIBIT 4.23 – ANALYSIS OF TIMELY PASS-THROUGH OF AGENCY CLAIM PAYMENTS IN THE TOTAL AMOUNT

RECEIVED

EXHIBIT 4.24 – ANALYSIS OF TIMELY LIQUIDATION AND PASS-THROUGH UPON FINAL AGENCY CLAIM ACTIVITY . 104

EXHIBIT 4.25 – ANALYSIS OF COMPLIANCE OF BANK ACCOUNTS CONTAINING FHA 203(K) FUNDS

EXHIBIT 4.26 – ANALYSIS OF PROPER FUNDS HANDLING OF 203(K) ESCROW ACCOUNTS

EXHIBIT 4.27 – ANALYSIS OF UNFUNDED 203(K) BALANCES, OUTSTANDING CUSTODIAL DEPOSITS, WITHDRAWALS, AND WITHDRAWAL REQUESTS

EXHIBIT 4.28 – ANALYSIS OF P&I ADVANCE, ADVANCE RECOVERY, AND EXCESS FUNDS

EXHIBIT 4.29 – DATA COLLECTION STATUS REPORT

EXHIBIT 4.30 – SAMPLE ACCOUNT FLOW CHART

EXHIBIT 5.1 – PHASE 3 – POST-SITE VISIT ACTIVITIES PROCESS

EXHIBIT 5.2 - PHASE 3 CHECKLIST: DEFAULTED ISSUER PORTFOLIO ASSESSMENT & RECONCILIATION

1.0 Introduction

1.1 Purpose

To minimize its financial risk, the Government National Mortgage Association (Ginnie Mae) closely monitors the Issuers of its mortgage-backed securities. When it determines that an Issuer cannot meet its obligations, it must act quickly to carry out the default process and protect its assets. The purpose of this Manual is to provide the procedures and guidelines that should be followed to respond effectively and efficiently to an Issuer Default.

1.2 Default Process Stakeholders

Exhibits 1.1 and 1.2 identify the stakeholders in the default process both internal and external to Ginnie Mae and its contractors. The majority of this Manual provides the process for coordinating the efforts of the internal stakeholders of Ginnie Mae, the Field Review Contractor (FRC), and the Master Subservicer (MSS) with the Defaulted Issuer, but in some cases other stakeholders will contribute to the default process. Ginnie Mae is responsible for coordinating the activities of all internal stakeholders as defined in Section 1.2.1. Other external stakeholders may exist based on the unique circumstances of each Issuer Default, but the stakeholders identified in Section 1.2.2 are common to multiple default instances.

1.2.1 Internal Stakeholders

Exhibit 1.1 – Internal Stakeholders

Internal Stakeholder Role Ginnie Mae Responsible for initiating the default, executing the seizure of the defaulted participant’s portfolio, and managing the FRC and MSS. Within Ginnie Mae, stakeholder groups include the Office of Mortgage-Backed Securities, the Monitoring Division, the Account Executives, the Office of Program Operations, the Office of Risk, and the Office of Finance, all of whom may participate in the default activity.

Ginnie Mae Field Review Contractor (FRC)

The FRC is responsible for data collection for the purposes of generating a default report, providing assistance to the primary Ginnie Mae POC, and providing recommendations or responses to additional analysis as directed by the Monitoring Division.

Internal Stakeholder Role Ginnie Mae Master Subservicer

(MSS)

The Ginnie Mae MSS is responsible for transferring the Ginnie Mae portfolio from the Defaulted Issuer’s control into the MSS’s control for the purposes of servicing the portfolio on behalf of Ginnie Mae.

Ginnie Mae Pool Processing Agent

(PPA)

The PPA is the entity responsible for administering the pass-through process for the newly Defaulted Issuer portfolio.

Ginnie Mae Mortgage Backed Securities Administrative Agent

(MBSAA)

The MBSAA provides data support and analytics used to assist the transfer and evaluation of the Defaulted Issuer’s portfolio.

Department of Housing and Urban Development Office of General Counsel (OGC)

The OGC provides a final answer on any dispute as to legal issues encountered in the execution of the on-site default.

1.2.2 External Stakeholders

Exhibit 1.2 – External Stakeholders

External Stakeholder Role Defaulted Issuer (Issuer) In accordance with the Guaranty

Agreement, the Defaulted Issuer is responsible for assisting in the transfer of the Ginnie Mae portfolio from the Defaulted Issuer’s control to Ginnie Mae’s.

Issuer Subservicer (ISS) An ISS is used by some Ginnie Mae Issuers to handle some of the servicing operations of their portfolio. In a default situation, those aspects of the servicing operation which were previously performed by the ISS will be transferred to the MSS, and the ISS will assist in the transfer of control of these operations as well as providing records, reconciliations, and files that were previously maintained on behalf of the now Defaulted Issuer.

External Stakeholder Role Funds Custodian(s) In accordance with the terms and conditions of the Forms HUD-11709 and HUD-11720 or successor Forms, the Funds Custodian(s) are financial institutions used by the Defaulted Issuer. They will retitle and transfer control of the accounts used in the servicing of the Ginnie Mae portfolio from the Defaulted Issuer to Ginnie Mae.

Document Custodian(s) The Issuer’s Document Custodian(s) will transfer access to the loan collateral files to Ginnie Mae and its designees in accordance with the terms and conditions of the Form HUD-11715 or successor Forms.

Insuring Agencies (FHA/VA/RD/PIH) Insurance Agencies are the Federal Housing Administration (FHA), U.S. Department of Veterans Affairs (VA), U.S. Department of Agriculture Rural Development (RD), or U.S.

Department of Housing and Urban Development Office of Public and Indian Housing (PIH). They provide mortgage insurance or guaranty for the loans backing the Ginnie Mae securities and also process and provide mortgage insurance claim related funds.

Federal Deposit Insurance Corporation (FDIC)

FDIC is the agency which may be in possession of a Ginnie Mae Defaulted Issuer in the event that the Defaulted Issuer was a bank under the FDIC insurance program and FDIC executed its rights to obtain control of the bank.

Bankruptcy Executors For some Defaulted Issuers in bankruptcy, an executor authorized to perform on behalf of the Defaulted Issuer or its estate may be appointed and Ginnie Mae may work with this executor to obtain required information for the defaulted portfolio and provide documentation relating to any claims by Ginnie Mae against the Defaulted Issuer.

External Stakeholder Role Secured Party An institution that has received a Ginnie

Mae approved pledge of servicing rights from the Defaulted Issuer. The Secured Party, Defaulted Issuer, and Ginnie Mae would have an executed acknowledgement agreement prior to event of default.

Stand-By Issuer A Ginnie Mae approved Issuer that at all times meets Ginnie Mae’s eligibility requirements for which the Secured Party has obtained the services to transfer the portfolio of a Defaulted Issuer.

1.3 Managing the Default Process

Defaulting an Issuer of Ginnie Mae mortgage-backed securities is a very complex process involving analysis and reconciliation of large amounts of data and coordination of the interests and activities of numerous stakeholders. This Manual describes the procedures for managing this complexity through the application of project management techniques. These techniques include flowcharting the default process in its various phases, developing an Integrated Default Plan (IDP) for conducting the process, monitoring the execution of the IDP, and making changes to the IDP as necessary.

Ginnie Mae is ultimately responsible for all aspects of the default process. However, it will be assisted in the management of the default process by the FRC. Upon notification of an impending default, the FRC will develop an IDP and submit it to Ginnie Mae for review and approval. The FRC will then closely monitor progress in executing the IDP and provide periodic status reports to Ginnie Mae. The FRC will make any changes to the IDP as directed by Ginnie Mae in consultation with other stakeholders. The MSS will assist Ginnie Mae in management of those aspects of the process related to servicing and the transfer of servicing for a Defaulted Issuer’s portfolio. In recognition of the quick response requirements of an Issuer Default, this Manual provides a number of templates that can be quickly tailored to a specific default.

While all the stakeholders identified in Section 1.2 participate in the default process, the majority of default work is executed by four primary stakeholders: Ginnie Mae, the Defaulted Issuer and, if applicable, the ISS, the MSS and the FRC.

The default process is carried out in four phases which Ginnie Mae has defined as follows:

• Phase 0: Pre-Default

• Phase 1: Pre-Site Visit

• Phase 2: Site Visit

• Phase 3: Post-Site Visit

Each of these default process phases, its primary purpose, and the event that most commonly precipitates the initiation of that phase of the default process is summarized in Exhibit 1.3 on the following page:

Exhibit 1.3 – Phases of the Default Process

It is important to note that while this is a preferred structure, there may be circumstances that would warrant adjusting the phased approach. For instance, circumstances may warrant that Phase 0 be eliminated and that Ginnie Mae would determine that a default process should be initiated at Phase 1. In such cases, Ginnie Mae will use its judgment to adjust the phases as

# Phase 0 Phase 1 Phase 2 Phase 3

Pu rp os e

To conduct observation to determine if an Issuer needs to be removed from the Ginnie Mae program

To prepare Ginnie Mae and its stakeholders for the successful execution of the seizure of the Ginnie Mae portfolio and the relevant supporting information

1) To successfully transfer control of the portfolio from the Defaulted Issuer to the MSS

2) To obtain all relevant information required to determine the state of Ginnie Mae funds used to support the portfolio

1) To prepare reports necessary to document any proof of claim Ginnie Mae may have against the Defaulted Issuer or other participants

2) To update Ginnie Mae’s systems and accounts to facilitate the on-going servicing of the portfolio

Tr ig ge rin g Ev en t

Decision by the Ginnie Mae Risk Committee that an Issuer poses sufficient risk to Ginnie Mae that a default event may occur

Ginnie Mae Risk Committee determination that an Issuer is in default of the Guaranty Agreement and that Ginnie Mae should obtain control of the portfolio and its servicing

The development and delivery of the default letter to the Issuer

A determination by the Ginnie Mae on-site representative to terminate the on-site portion of the review of the Defaulted Issuer

Pre-Default Activity Pre-Visit Activity Site Visit Post-Site Visit

Phases of the Default Process required in order to execute the transfer of its portfolio and safeguard against losses incurred in the seizure of the portfolio.

Exhibit 1.4 on the next page provides a flowchart of the activities performed by the four major stakeholders during the four process phases throughout the default process.

Exhibit 1.4 – Overview of the Default Process

1.4 Manual Organization

This Manual is organized as follows:

Introduction – The Introduction provides an overview of the default process and definitions of key terms, acronyms, and stakeholders.

Phase 0 – Pre-Default Activities - This Section describes how Ginnie Mae monitors the status of its Issuers and determines whether an Issuer should be placed in default. It describes the inputs the FRC provides Ginnie Mae from field reviews of Issuers as well as the inputs received from the MBSAA contractor and other external sources. It also addresses actions by the MSS to review and, if necessary, update its contingency plans for responding to a default.

Phase 1 - Pre-Site Visit Activities – This Section describes Ginnie Mae’s activities in making the default decision, notifying default team members and coordinating arrangements for the site visit to the Defaulted Issuer. It addresses the FRC’s activities in developing an Integrated Default Plan (IDP) and an Integrated Data Collection Plan (IDCP) as well as the MSS’s activities in organizing its response team and developing a plan to transfer servicing of the Defaulted Issuer’s portfolio.

Phase 2 - Site Visit Activities – This Section describes Ginnie Mae’s activities in delivering the default letter to the Defaulted Issuer and coordinating the efforts of the on-site Default Team.

It describes the FRC’s on-site activities in collecting data, analyzing data and providing interim data analysis reports. It also describes the MSS’s procedures in removing and transporting files from the Defaulted Issuer’s site and preparing for the transfer of servicing of the Defaulted Issuer’s portfolio.

Phase 3 – Post-Site Visit Activities – This Section describes Ginnie Mae’s activities conducted after completion of the site visit. These include updating Ginnie Mae’s systems to reflect the new control of the Defaulted Issuer’s portfolio, transferring Custodial Account balances to Ginnie Mae, receiving and reviewing reports from the FRC and MSS, and preparing a final report on default execution. This Section also addresses the FRC’s and MSS’s preparation and submission of their final reports to Ginnie Mae.

APPENDICES A, B, C, and D – GUIDES AND TEMPLATES – These appendices provide guides and templates that are referenced in the body of this Manual.

1.5 Information Sources

This Manual consolidates inputs from several sources, as described in Exhibit 1.5 below:

Exhibit 1.5 – Information Sources

Title Location Risk Based Manual Modernization:

Requirements for a Revised Default Manual, September 30, Ginnie Mae

Ginnie Mae MBS Guide for Issuers http://www.ginniemae.gov/guide/guidtoc.asp?subTitle=Issuers

Ginnie Mae Accounting Manual http://www.ginniemae.gov/guide/acct.pdf

Appendix A (Phase 0), Pre-Default Issuer Monitoring

Ginnie Mae Reading Room

Appendix B (Phase 1), Default Preparation

Ginnie Mae Reading Room

Appendix C (Phase 2), Default Execution

Ginnie Mae Reading Room

Appendix D (Phase 3), Issuer Portfolio Assessment and Reconciliation

Ginnie Mae Reading Room

1.6 Future Updates to the Default Manual

There may be a need to update this Manual from time to time in order to keep up with changes in policies, regulations, Forms, or other guidance. Ginnie Mae will identify any need for updating this Manual and request the FRC to submit a plan to do so. Upon approval of the plan by Ginnie Mae, the FRC will make proposed changes to this Manual and submit the revisions to Ginnie Mae for Ginnie Mae’s approval. Upon Ginnie Mae’s approval, the FRC will update this Manual and record the update on the Revisions and Approvals page in the front of this Manual.

http://www.ginniemae.gov/guide/guidtoc.asp?subTitle=Issuers http://www.ginniemae.gov/guide/acct.pdf

1.7 Acronyms and Abbreviations

A list of Acronyms and Abbreviations used in this Manual is provided in Exhibit 1.6.

Exhibit 1.6 -- Acronyms and Abbreviations

Acronym/Abbreviation Meaning ACH Automated Clearing House ARM Adjustable Rate Mortgage CCA Collections Clearing Account CD Concurrent Date CPTA Central Payment and Transfer Agent DPMS Default Process Master Schedule EDCA Escrow Disbursement Clearing Account EVP Executive Vice President FDIC Federal Deposit Insurance Corporation FHA Federal Housing Administration FIC Fixed Installment Control FRC Field Review Contractor FRP Findings Resolution Plan G/L General Ledger Gfee Ginnie Mae Guaranty Fee Ginnie Mae Government National Mortgage Association GPADS Ginnie Mae Portfolio Analysis Data System GPM Graduated Payment Mortgage The Guide Ginnie Mae Guide for Issuers HUD U.S. Department of Housing and Urban Development IDCP Integrated Data Collection Plan IDP Integrated Default Plan IPMS Integrated Pool Management System IR Internal Reserve ISS Issuer Subservicer MBS Ginnie Mae Office of Mortgage-Backed Securities MBSAA Mortgage-Backed Securities Administrative Agent MERS Mortgage Electronic Registration System MF Multifamily MIN MERS Identification Number MIP Mortgage Insurance Premium Monitoring Ginnie Mae Monitoring Division MSS Ginnie Mae Master Subservicer OF Ginnie Mae Office of Finance

Acronym/Abbreviation Meaning OGC U.S. Department of Housing and Urban Development

Office of General Counsel OIG U.S. Department of Housing and Urban Development

Office of the Inspector General OPB Original Principal Balance OMF Ginnie Mae Office of Multifamily P&I Principal and Interest Participant Any Approved Ginnie Mae Issuer or Document

Custodian Pass-Through Pass-Through refers to the event of executing a security holder remittance or events related to such remittance. “Pass through,” as two unhyphenated words, refers to any event where funds move from one location to another.

PIH U.S. Department of Housing and Urban Development Office of Public and Indian Housing

POC Point of Contact PPA Pool Processing Agent PTS Pool Transfer System RC Ginnie Mae Risk Committee RD Rural Development REO Real Estate Owned RFR Reserve for Replacement RFS Reporting and Feedback System SF Single Family SVP Senior Vice President T&I Taxes and Insurance UPB Unpaid Principal Balance USDA U.S. Department of Agriculture VA U.S. Department of Veteran Affairs VP Vice President

1.8 Approval

This Manual has been approved by Ginnie Mae. It is expected that personnel who participate in the default process will follow the procedures in this Manual as directed by Ginnie Mae. Any deviations from these procedures should be approved by Ginnie Mae.

2.0 Phase 0 - Pre-Default Activities

Ginnie Mae actively monitors the performance of its Issuers, and it is assisted by information obtained from both internal and external sources, such as FHA, FDIC and other Government- Sponsored Enterprises (GSE). The applicable Guaranty Agreements and Chapter 23 of the Ginnie Mae Guide describe the grounds on which Ginnie Mae, in its sole discretion, may decide to declare an Issuer in default. This section provides a description of the events or conditions that could lead to an Issuer default, as summarized below, and the activities performed by Ginnie Mae, the FRC and the MSS during the pre-default monitoring phase. A flowchart of these activities is provided in Exhibit 2.1 on the next page.

Events or conditions of an Issuer default could include, but are not limited to:

• Any failure by a Ginnie Mae I or Ginnie Mae II Issuer to have sufficient funds available in the P&I Custodial Account or Central P&I Custodial Account in time to make timely payments related to a required security holder remittance by the due date

• Any application by the Issuer to Ginnie Mae or the CPTA for an advance of funds in order to pay all or any part of a required security holder payment

• Any other act or omission by the Issuer preventing the timely payment to a security holder

• Any impending or actual insolvency of the Issuer, and/or material changes in the Issuer’s business status that affects Ginnie Mae or the Issuer’s ability to carry out its obligations

• Any unauthorized use of custodial funds

• Any withdrawal or suspension of the Issuer’s approved status by FHA, Fannie Mae or

Freddie Mac

• Any failure to submit a required report or notice

• Any submission of a false report, statement, or data item, act of dishonesty, breach of fiduciary duty, or willful misconduct related to the Ginnie Mae MBS Programs

• Any other failure of the Issuer to observe or comply with any term or provision of the applicable Guaranty Agreement or the Guide that the Issuer has not timely remedied or corrected upon notification by Ginnie Mae

Ginnie Mae may attribute any act by the Issuer’s Subservicer or any agent of the Issuer to the Issuer.

Exhibit 2.1 – Phase 0 – Pre-Default Activities Process

2.1 Ginnie Mae Phase 0 Activities

A checklist of Ginnie Mae activities during pre-default monitoring is provided as Exhibit 2.2 on the next page. Ginnie Mae reviews a variety of information on the status of its Issuers, including information from the Issuer, Ginnie Mae and the FRC. It maintains a Master Tracking List of Issuers that are potential default candidates. Ginnie Mae also maintains a file of information on Issuers it is tracking. The contents of this file are listed in Appendix A-1.

Appendix A-2 provides a worksheet template of information on Issuers being tracked that is maintained by Ginnie Mae. Appendix A-3 provides the Format for an Issuer Contact Tracking Log, which is used to record contacts made between Ginnie Mae and Issuers.

If Ginnie Mae determines that an Issuer may be in financial difficulty, it sends an initial contact letter to the Issuer expressing its concern. A sample template for this initial contact letter is provided in Appendix A-4. If warranted by the Issuer’s financial condition, a proposed default memorandum is prepared for consideration by Ginnie Mae’s Risk Committee (RC). A sample template of the proposed default memorandum is provided in Appendix A-5.

Exhibit 2.2 - Phase 0 Checklist: Pre-Default Issuer Monitoring

Task Action Taken/ Information Received

Responsible Party

Date Assigned

Completed (Y/N)

Date Completed

Source of Problem Identified Internal?

External?

Most Recent Issuer Ranking Date of Most Recent Ranking

Watchlist updated MBS/OMF file on the troubled Issuer updated Date of original Contact Letter Date of last Contact Letter Date of last business plan Date of Special Field Review (if applicable)

Prepare Proposed Default Memorandum Schedule a meeting of the Risk Committee to discuss proposed action against the Issuer Prepare Monitoring file

MBS/OMF/Monitoring Signature:

Date:

Confer with VP-MBS/OMF and OGC on the reason(s) for default

Convene Risk Committee

Phase 0 Checklist

Pre-Default Issuer Monitoring (For use when preparing for a Risk Committee Meeting)

Information from Watchlist

Monitor Troubled Issuers

Receive Issuer Information

2.2 FRC Phase 0 Activities

Upon request, the FRC will prepare the FRC Issuer Information Worksheet based on the information obtained in the Ginnie Mae Issuer Compliance Review and from the PPA and MBSAA. These worksheets become part of the information reviewed by Ginnie Mae during pre-default monitoring. A template for these worksheets is provided in Appendix A-6. At Ginnie Mae’s request, the FRC will also conduct Specialized Field Reviews of Issuers that may be defaulted by Ginnie Mae. The procedures to be performed in these Specialized Field Reviews are described in Appendix A-7.

2.3 MSS Phase 0 Activities

During the pre-default phase, the MSS will develop or update its contingency plan for responding to a Defaulted Issuer. The contingency plan will identify those MSS departments that will be involved in the default response. Each MSS will have its own organization, but typical MSS departments involved in the default process could include:

• Acquisitions

• Foreclosure/Bankruptcy/REO

• Investor Accounting

• Investor Certification

• Collections/Loss Mitigation

• Mortgage Insurance

• Special Loans

The contingency plan will identify the tasks to be performed by each department before, during, and after the site visit to the Defaulted Issuer. The contingency plan will also identify the schedules and resources required to accomplish these tasks in accordance with the terms of its contract with Ginnie Mae. The contingency plan will also identify MSS data requirements for inclusion in the IDCP. The contingency plan will describe how the MSS’s activities will be coordinated with the activities of Ginnie Mae and the FRC.

3.0 Phase 1 - Pre-Site Visit Activities

Following a decision to default an Issuer, a number of activities must be conducted to plan and prepare for a site visit to the now Defaulted Issuer. A flowchart of these activities is provided in Exhibit 3.1 on the next page, and details of these activities are provided in the subsequent sections.

Exhibit 3.1 – Phase 1 – Pre-Site Visit Activities Process

3.1 Default Decision

The default process begins with a decision by the RC to default an Issuer. The RC also selects a default date using the criteria listed in the Date of Default Worksheet shown in Appendix B-1.

The Ginnie Mae staff maintains a file of default related material as listed in Appendix B-2. After the default decision, a default letter is drafted by OGC for signature by the Ginnie Mae President/Executive Vice President (EVP). A sample template for the default letter is provided in Appendix B-3. The Ginnie Mae staff also assists the OGC in drafting the Limited Powers of Attorney document. A template for this document is provided in Appendix B-4.

3.2 Pre-Site Visit Checklists

The date of default determined by the RC may allow enough time for the Ginnie Mae Site Representative, the FRC and the MSS to perform pre-site visit activities. Exhibit 3.2 on the next page provides a checklist of the pre-site visit activities performed by the Ginnie Mae Site Representative. Exhibits 3.3 and 3.4 on the subsequent pages provide checklists of pre-site visit activities performed by the FRC and the MSS, respectively.

Exhibit 3.2 -- Ginnie Mae Default Preparation Checklist

Responsible Party

Date Assigned

Completed (Y/N)

Date Completed

Default date set and MSS selected by Risk Committee

(RC)

Confirm halt of all transactions by the Defaulted Issuer on Integrated Pool Management System (IPMS) Confirm Issuer pools frozen at Transfer Agent

Receive Ginnie Mae file from

MBS

Receive signed RC default decision Notify MSS Assign and notify Ginnie Mae POC (if applicable) Coordinate with OGC and OF Notify FRC

Complete Defaulted Issuer worksheets OR Obtain listing of current mortgage pools Request current Custodial Account agreements and evidence of recertification from

PPA

Request listing of recent pools issued

Assist OGC in drafting of default letter Attach complete list of Defaulted Issuer's mortgage pools to the default letter Obtain concurrence of Ginnie Mae POC, OMF VP, and OGC Obtain signature of Ginnie Mae President/EVP

Draft Document Custodian letters Receive draft bank letter from Ginnie Mae Site Representative Draft sample MF letter for FHA required escrow accounts Prepare letter to MERS to assign Defaulted Issuer portfolio to Ginnie Mae Obtain signature of Ginnie Mae

POC

Obtain signature of Ginnie Mae

VP

Assist OGC in drafting limited powers of attorney

Prepare Issuer Default Package

Prepare Bank & Document Custodian Letters & Limited Powers of Attorney

Ginnie Mae Default Preparation Checklist

Make Default Decision

Assign & Notify Default Team

Gather Detailed Information on Defaulted Issuer

Responsible Party

Date Assigned

Completed (Y/N)

Date Completed

Contact the MSS for the default Send worksheets to MSS Review MSS Team Matrix Conduct conference call Complete Phase 1 Situation Assessment Guide during conference call [Attach to Checklist]

Prepare travel arrangements for Ginnie Mae POC and OGC Coordinate travel arrangements with MSS and FRC

Document travel requests Prepare travel itinerary and give copy to Ginnie Mae POC

Review & approve Integrated Default Plan Verify Defaulted Issuer Information Prepare MSS Engagement Confirmation Letter Collect Site Visit Documentation

Original and copies of the default letter Original and copies of the bank letters Original and copies of the Document Custodian letter(s) Original and copies of limited powers of attorney MSS Engagement Confirmation Letter Copy of the guaranty agreement Copy of Forms HUD-11709, 11720, 11715, and 11710D

Copies of the Defaulted Issuer's Ginnie Mae pool numbers listing Copy of the MBS worksheet

Copy of the FRC MBS/OMF worksheet Travel itinerary

Coordinate with Ginnie Mae POC

Ginnie Mae POC's Signature:

Date:

Finalize Pre-Default Activities

Ginnie Mae Default Preparation Checklist (Cont.)

Perform Situation Assessment Conference Call

Coordinate Travel Arrangements

Exhibit 3.3 -- FRC Default Preparation Checklist

Responsible Party

Date Assigned

Completed (Y/N)

Date Completed

Receive Work Authorization for Default from Ginnie Mae Identify FRC Default Team Members Notify Ginnie Mae POC of FRC

POC

Collect contact information from Ginnie Mae & MSS Submit consolidated list of contacts to all team members

Develop initial IDCP from template Request listing of all loans in Defaulted Issuer’s Ginnie Mae portfolio from MBSAA including Pool #, Ginnie Mae Unique Loan ID #, Borrower Name, Interest Rate, OPB, and UPB Request comments from Ginnie Mae and MSS Incorporate Comments received

Submit IDCP for inclusion in IDP

Develop initial IDP from template Obtain and incorporate IDCP and MSS Contingency Plan Request Comments from Ginnie Mae and MSS Incorporate any comments and submit to Ginnie Mae for review and approval

Prepare travel arrangements for FRC Team personnel Coordinate travel arrangements with Ginnie Mae and MSS

Document travel requests Prepare travel itinerary and give copy to Ginnie Mae Site Representative

Provide copies of IDP to participants Provide FRC readiness status Discuss action items Document Results of conference call

FRC POC's Signature:

Date:

Coordinate Travel Arrangements

Participate in Situation Assessment Conference Call

FRC Default Preparation Checklist

Receive Notification of Default

Prepare Integrated Data Collection Plan (IDCP)

Prepare Integrated Default Plan (IDP)

Exhibit 3.4 --MSS Default Preparation Checklist

Responsible Party

Date Assigned

Completed (Y/N)

Date Completed

Receive Task Order for Default from Ginnie Mae Identify MSS Default Team Members Notify Ginnie Mae POC of MSS

POC

Provide contact Information to

FRC

Receive consolidated list of contacts

Develop Response Plan by updating Contingency Plan Request comments from Ginnie Mae and MSS Incorporate Comments received

Submit MRP for inclusion in IDP

Prepare travel arrangements for MSS Team personnel Coordinate travel arrangements with Ginnie Mae and FRC

Document travel requests Prepare travel itinerary and give copy to Ginnie Mae Site Representative

Provide MSS readiness status Discuss action items Review results of conference call as documented by FRC

MSS POC's Signature:

Date:

Participate in Situation Assessment Conference Call

MSS Default Preparation Checklist

Receive Notification of Default

Prepare MSS Response Plan (MRP)

Coordinate Travel Arrangements

3.3 Assignment and Notification of Default Team

At the time the RC makes the default decision, it also selects an MSS. Appendix B-5 provides a template of the letter sent to the MSS confirming its selection. Shortly after the default decision, Ginnie Mae issues a Work Authorization to the FRC and a Task Order to the MSS.

Ginnie Mae also notifies and provides copies of the default letter to responsible offices, including Monitoring, the Office of Multifamily, the Office of Finance, and the Office of the Chief Risk Officer. Ginnie Mae may also provide a copy of the signed default letter to the FRC and the MSS.

3.4 Coordination of Travel Arrangements

Site visit arrangements for Ginnie Mae, MSS and FRC Default Team members are coordinated and a travel itinerary prepared. Coordination should include flight arrival times, site arrival times, and any hotel accommodations.

3.5 Preparation of Letters

Prior to the site visit, Ginnie Mae personnel will prepare and submit letters to parties involved in the default process. These letters and the appendices that provide templates for them are as follows:

1. Bank (Account Freeze) Letter - Appendix B-6

2. Multifamily Bank Letter for FHA-Required Escrow Accounts – Appendix B-7

3. Document Custodian Letter – Appendix B-8

3.6 Default Documentation

In preparation for the site visit, Ginnie Mae personnel will collect necessary documentation, including original and copies of the default letter, bank letters and Document Custodian letter(s) (see Exhibit 3.2 for a complete list of documentation collected).

3.7 Integrated Default Conference

A conference call or meeting will be held between representatives from Ginnie Mae, the FRC and the MSS to coordinate default activities. In preparation for this meeting, the FRC will provide a Team Matrix for Ginnie Mae review. An outline of the topics to be addressed in the meeting is provided in Appendix B-9. The FRC will document the results of this meeting, providing a copy to Ginnie Mae and the MSS.

3.8 Background Briefing Sheet

The FRC will review the final report for the most recent review conducted by the FRC and prepare a background briefing sheet identifying the following:

• The account structure as understood by the most recent field compliance review performed by FRC

• The findings and the current status of the findings from the most recent field review

• Any other observations noted during the course of the review

This background briefing sheet will be provided to Ginnie Mae in accordance with a schedule agreed to between Ginnie Mae and the FRC. A template for the Background Briefing Sheet is provided in Appendix B- 10.

3.9 Integrated Data Collection Plan

The FRC will develop an IDCP which will define what data is to be collected to meet the requirements of Ginnie Mae, the MSS and the FRC. The IDCP will include a data requirements table in the Format shown in Exhibit 3.5:

Exhibit 3.5 -- Integrated Data Collection Plan Template

Item Required Data Data Recipient

When Required

Data Gatherer

Data Source

1 A list of all bank accounts including account number, routing number, account title, and bank name used to support the servicing of defaulted participant portfolio including, but not limited to, the following:

Clearing accounts Corporate servicing accounts Lockbox accounts Custodial accounts Escrow accounts Accounts funding corporate advances Accounts funding newly securitized loans Disbursement accounts

Item Required Data Data Recipient

When Required

Data Gatherer

Data Source

There will also be an indication of all accounts through which Ginnie Mae funds may pass through.

2 The bank account statements for the three months leading to the date of default for all the accounts identified above

3 Bank account reconciliations for the three months leading to the date of default for all accounts identified above

4 A list of all daily transactions from all accounts identified above starting from the end date of the most recently available bank statement for each account and continuing through the date of default

5 A list of all transactions to move funds from the T&I Account that have not yet cleared the T&I account, indication the transaction amount and purpose of disbursement

6 A list of all transaction to transfer funds from clearing or lockbox accounts that are pending deposit into the Ginnie Mae Custodial Accounts, including the transaction amounts and the pending deposit amounts to each custodial account, and the corresponding loans to which the deposits should be credited

7 Issuer-provided internal loan level records that support the bank statement balances

8 The most recent forms HUD 11709 and HUD 11720 for the identified accounts

9 The most recent Investor Trial Balance completed for the Ginnie Mae portfolio, as well as the trial balance from the three months preceding the default

10 Individual Loan Payment Histories (12-month period)

When Required

Data Gatherer

Data Source

11 A list of all loans liquidated from the Ginnie Mae portfolio; including Pool #, Loan #, Liquidation Reason Code, Case #, Insuring Agency, Date of Liquidation, and Liquidation Principal Amount; for the year preceding the date of default

12 Schedule of Delinquent Loans for the most recent reporting month cut-off date and as of the date of default

13 Schedule of Prepaid Loans 14 Schedule of Curtailments 15 Ginnie Mae-provided list of loans with agency termination status 16 Loan collection/default history notes or logs for specified loans 17 Printouts from Agency websites noting current status 18 Ginnie Mae I Pre-Collection Notices 19 Ginnie Mae II Pre-Collection Notices 20 The advance/recovery/excess funds tracking report(s) for three months preceding the date of default

21 A list of all claims paid/pending/denied in the Ginnie Mae portfolio for the year preceding the date of default

22 The most recent Reconciliation of Mortgage Collateral to Securities Outstanding for all pools

23 The Test of Expected P&I for all pools for the last three months

24 Form HUD 11710A (or successor form) for all pools for three months prior to the date of default

25 Form HUD 11710D (or successor form) for the relevant portfolios for three months prior to the date of default

26 Issuer-prepared Forms HUD 11710E (or successor form) for all loans liquidated during the test period

When Required

Data Gatherer

Data Source

27 A list of all loans in the Ginnie Mae portfolio in electronic format including Pool #, Loan #, Borrower Name, Property Address, OPB, Interest Rate, Date of Securitization, and UPB if this information is not already included in the trial balance as of the date of default

28 A listing of all loans with negative escrows balances to include the amount of escrow advances, if not included on the Trial Balances for the last three months prior to the default date

29 A list of all loans refinanced or paid off by the defaulted Issuer within the last six months including refinanced loan number, new loan number, borrower name, property address, OPB, outstanding escrow payments or refunds, date the refinanced loan was closed, date the funds for the new loan were disbursed per HUD-1, and date the old loan was paid off where either the newly created loan or refinanced loan was in the defaulted issuer’s Ginnie Mae portfolio

30 A list of all loans and pools currently in the defaulted participant’s securitization pipeline, including loan number, pool/loan package number, OPB, property address, borrower name, and agency insurance/guaranty status

31 The location where borrower checks are received

32 The location that trailing documents are sent to

33 A list of all pools by certification status

34 A list of all loan collateral for which a liquidation release was filed, including pool number, loan number, and release reason code

35 The current non-liquidation release tracking report from the Document Custodian

When Required

Data Gatherer

Data Source

36 The location of servicing files in hard copy form

37 The location of any images of servicing files

38 FHA Status Reports from FHA Connection

39 A list of FHA loans with indemnification agreements

40 A list of agency claim offsets 41 A list of all loans in the portfolio with

MERS Agreements, including pool #, loan #, and MERS Identification Number (MIN)

The IDCP will also describe the logistics for collecting, transporting, and storing required data. If the FRC is aware of optional or additional analyses, defined in Sections 4.9 through 4.16, that have been identified by Ginnie Mae to be performed, the FRC should tailor the IDCP to include these additional data requirements. Ginnie Mae or the MSS may also provide additional data requirements that should be included in the IDCP. The IDCP will be included as an appendix to the IDP.

3.10 Integrated Default Plan

The FRC will develop an Integrated Default Plan (IDP) describing how the default process will be conducted. The IDP will serve as the master plan for managing and coordinating the activities of various stakeholders in the default process. The FRC will submit the IDP to Ginnie Mae for approval. Subsequent changes to the IDP will be approved by Ginnie Mae in consultation with stakeholders. A template for the IDP is provided in Appendix B-11.

The IDP will include a Default Process Master Schedule (DPMS). The DPMS will be prepared and maintained using project management software. A template for the DPMS is also included in Appendix B-11.

If there is not sufficient time or information to prepare a full IDP prior to the site visit, the FRC will provide team members with a copy of the DPMS with as many tasks and dates as possible identified.

4.0 Phase 2 - Site Visit Activities

The Default Team (“the Team”) that conducts the site visit will consist of personnel from Ginnie Mae, the MSS, the FRC, OGC, and other parties as identified by Ginnie Mae. A flowchart showing activities to be performed by the Default Team while on-site is provided in Exhibit 4.1 on the next page. The subsequent sections of 4.0 provide a description of these activities.

Exhibit 4.1 – Site Visit Activities Process

4.1 Ginnie Mae Phase 2 Activities

The Ginnie Mae Site Representative will lead the Team while on-site and will be responsible for delivering the default letter to the Defaulted Issuer. A representative from the Ginnie Mae OGC may also accompany the Default Team. Guidelines for delivering the default letter are presented in Appendix C-1. A checklist of activities to be performed by Ginnie Mae during the site visit is provided in Exhibit 4.2 found on the next page.

The Ginnie Mae Site Representative must prepare and submit a memorandum advising the FHA Commissioner when the Defaulted Issuer portfolio contains FHA insured loans as per MBSAA data. A template for this memorandum is provided in Appendix C-2. The Site Representative must also prepare and submit a memorandum to the Director, Office of Program Operations, for Ginnie Mae to assign a new #9000 number to use for transfer of Defaulted Issuer responsibilities and data within Ginnie Mae’s information systems. A template for this Memorandum is presented in Appendix C-3.

Exhibit 4.2 – Ginnie Mae Site Visit Checklist

Responsible Party

Date Assigned

Completed (Y/N)

Date Completed

Determine who will deliver default letter to Defaulted Issuer Determine who will deliver bank letter if multiple sites Determine delivery time Inform Ginnie Mae POC of delivery time (Ginnie Mae POC will fax Document Custodian letter at appropriate time)

Deliver letters to bank and Defaulted Issuer simultaneously

Ensure Defaulted Issuer faxes MF letter to financial institutions with FHA-required escrow accounts Verify retrieval of check register (only applicable if institution still maintains a check register)

Resolve any conflicts between MSS and the Defaulted Issuer Obtain Security Holder register Obtain Issuer organization chart and/or employee directory

Deliver letters to bank and Document Custodian Assess bank and Defaulted Issuer compliance If necessary, OGC attorney contacts U.S. Attorney and/or U.S. Marshal

Verify Ginnie Mae POC notified:

HUD/FHA

VA

RD

PIH (if applicable) Confirm request to all Agencies to halt claim payments to Defaulted Issuer / Servicer. If it is not possible to halt claim payments, obtain list of all claims Agency will process and pay to Defaulted Issuer Verify Multifamily Ginnie Mae POC sent follow-up letter to financial institutions Verify Ginnie Mae POC anchor requested that OPO assign a new Issuer identification number Verify MSS confirmation letter was sent

Notify External Parties

Ginnie Mae Site Visit Checklist (For use by the Ginnie Mae Site Representative during the site visit)

Hold Default Execution Team Meeting

Start Site Visit

Freeze Bank & Custodial Activity

4.2 MSS Phase 2 Activities

The MSS is designated by Ginnie Mae. Ginnie Mae will notify the MSS of the date of default as soon as possible. The main role of the MSS during the site visit is to assume the responsibility for servicing the Defaulted Issuer’s securities on behalf of Ginnie Mae. A checklist of activities to be performed by the MSS is provided in Exhibit 4.3.

Responsible Party

Date Assigned

Completed (Y/N)

Date Completed

Check-in with Ginnie Mae POC and verify bank and Document Custodian letters were faxed Perform end of day assessment

Complete Phase 2 End of Day Assessment Guide [Attach to Checklist] If FBI involvement, request copies of all materials they seize Keep U.S. Attorney's Office informed as necessary Keep U.S. Marshal's Office informed as necessary

Ginnie Mae POC's Signature:

Date:

Ginnie Mae Site Visit Checklist (Cont.)

(For use by the Ginnie Mae Site Representative during the site visit)

Conduct Preliminary Site Visit Assessment

Exhibit 4.3 – Master Subservicer Site Visit Checklist

Defaulted Issuer Name:

Defaulted Issuer Number:

Task Action Taken/ Information Received

Responsible Party

Date Assigned

Completed (Y/N)

Date Completed

Coordinate with the FRC to secure incoming and in-house cash Coordinate with the FRC to secure incoming payments at the lockbox (es), including developing an understanding of how exception payments are processed Determine…