Freddie Mac Single-Family Seller/Servicer Guide Section 2401.1 — Master Systems License

Freddie Mac Single-Family Seller/Servicer Guide Section 2401.1 — Master Systems License

2401.1: Master Systems License (12/17/25) This section constitutes the base terms and conditions for the licensing framework authorizing the use of Freddie Mac Systems, and, as such, contains contractual provisions related to: ■ Scope and applicability ■ Definitions ■ Royalty free use license ■ Licensed Materials; use and other limitations ■ System access; interface development and maintenance; Related Third Parties ■ Authorized User registration; access management and security; requirements for Excluded Servicing Tools ■ Ownership of the Licensed Materials; rights in data ■ Representations and warranties; indemnification ■ Limited warranty; liability limitation ■ Term and Termination ■ Additional Provisions (a) Scope and applicability Immediately upon a User’s first access to a System on or after the Effective Date, the Seller/Servicer shall be bound by the terms and conditions of this Section 2401.1 (i.e., the “Master Systems License”) and, to the extent applicable, any System-Specific License. Except with respect to Section 2401.1(f) and the Seller/Servicer’s use of Freddie Mac Access Manager, neither this Master Systems License nor any System-Specific License shall apply to any Excluded Servicing Tool, which shall continue to be governed by its separate license, user agreement or similar document. (b) Definitions Freddie Mac Single-Family Seller/Servicer Guide Chapter 2401 As of 12/17/25 Page 2401-2 The definitions below apply solely for purposes of this Master Systems License and each System-Specific License. Capitalized terms used but not defined in this Master Systems License have the meaning set forth in the Glossary or as otherwise specified in the Guide: Definitions for purposes of this Master Systems License and each System-Specific License A Access Manager The meaning is set forth in Section 2401.1(f)(i) below Administrator The meaning is set forth in Section 2401.1(f)(ii) below Aggregate Data The meaning is set forth in Section 2401.1(g)(iv) below Authentication Credentials The meaning is set forth in Section 2401.1(f)(i) and (ii) below Authorized User Any employee or contract worker of the Seller/Servicer or of a Related Third Party who is authorized by the Seller/Servicer or such Related Third Party to access and use the Licensed Materials in connection with his or her responsibilities to the Seller/Servicer and/or the Related Third Party. Authorized Users are sometimes referred to in Purchase Documents as “Permitted Users” D Distributed Code Any application or operating system software provided or made available by Freddie Mac (or third parties on behalf of Freddie Mac) to the Seller/Servicer for implementation at a Seller/Servicer location in connection with the Purpose. Documentation User guides, job aids, training materials, any written instructions (including such instructions as they relate to administering Authentication Credentials and any other Confidential Means of Access), and any other documentation relating to a System that Freddie Mac provides or makes available to the Seller/Servicer, as amended from time to time E Effective Date The date, set forth in the Guide Bulletin pursuant to which the Master Systems License and each System-Specific License is published, on or after which a User’s access to a System will bind the Seller/Servicer or Related Third Party, Freddie Mac Single-Family Seller/Servicer Guide Chapter 2401 As of 12/17/25 Page 2401-3 as applicable, to the Master Systems License and each System-Specific License Enhancements The meaning is set forth in Section 2401.1(g)(ii) below Excluded Servicing Tool A Servicing Tool that is governed by a separate license, user agreement or similar document (whether in the Guide or elsewhere) other than a System-Specific License F Form The meaning is set forth in Section 2401.1(f)(i) below L License The meaning is set forth in Section 2401.1(k)(iii) below Licensed Materials Individually and collectively, the Systems, Output and Documentation M Master Systems License The meaning set forth in Section 2401.1(a) above O Output Any reports, findings, feedback certificates, messages (including those in such reports, findings or certificates), data, information or other content generated by a System that is provided or made available to the Seller/Servicer P Purpose The meaning is set forth in Section 2401.1(c) below R Related Third Party The meaning is set forth in the Glossary S Specifications The meaning is set forth in Section 2402.1(b) Support Services Services provided by Freddie Mac or its contractors to support the operation and maintenance of a System Sys-to-Sys Credentials The meaning is set forth in Section 2401.1(f)(i) below System Individually and collectively, a Freddie Mac-owned, -leased, -licensed or -controlled technology platform whether or not identified in a System-Specific License including, without Freddie Mac Single-Family Seller/Servicer Guide Chapter 2401 As of 12/17/25 Page 2401-4 limitation, Distributed Code, Specifications, any related computer, other hardware or electronic device, application or operating system software, website, private data or other communication network, interface (including any application programming interface (API) created and hosted by Freddie Mac to facilitate back-end access to its systems) and/or connectivity which, in each instance, Freddie Mac provides or makes available to the Seller/Servicer in connection with the Purpose; provided, however, that the term “System” as used in this Master Systems License and any System- Specific License shall not include any Excluded Servicing Tool or the Uniform Collateral Data Portal®; and provided further that the term “System” shall include Access Manager. The term “System,” as used within this Master Systems License and any System-Specific License, is to be construed as within the meaning of the term “Systems” as this latter term is defined in Chapter 1401. System Data The meaning is set forth in Section 2401.1(g)(iii) below System-Specific License Each license set forth in Chapter 2402, 2404, 2405 and 2406. T Third Parties The meaning is set forth in Section 2401.1(i) below U User Any individual who gains access to the Licensed Materials directly or indirectly through the Seller/Servicer or a Related Third Party, and includes Authorized Users User IDs The meaning is set forth in Section 2401.1(f)(i) below (c) Royalty free use license Freddie Mac grants to the Seller/Servicer a limited, revocable, non-exclusive, non- transferable license to access and use the Licensed Materials through its Authorized Users during the term of this Master Systems License and any System-Specific License; provided, however, that such access and use shall be solely for the Seller/Servicer’s internal business purposes in connection with its origination and/or Servicing of Mortgages, as applicable (collectively, the “Purpose”). The Seller/Servicer may allow Related Third Parties to access and use the Licensed Materials solely to the extent necessary to discharge their respective responsibilities to the Seller/Servicer in connection with the Purpose, except to the extent prohibited by or, if permitted, subject to any requirements set forth in, any applicable Purchase Document; provided, however, the Seller/Servicer shall obligate each such Related Third Party in writing Freddie Mac Single-Family Seller/Servicer Guide Chapter 2401 As of 12/17/25 Page 2401-5 to comply with the terms of this Master Systems License and each applicable System- Specific License, as set forth in Section 2401.1(e)(iii). Except as otherwise indicated by Freddie Mac in any relevant Documentation or Purchase Document, Freddie Mac does not currently assess a fee in connection with the Seller/Servicer’s use of any System but expressly reserves the right to do so in the future. The Seller/Servicer acknowledges that it may incur (and will be responsible for) costs from third parties such as credit reporting agencies, other vendors and other Related Third Parties in connection with its use of certain Systems. (d) Licensed Materials; use and other limitations (i) Use of Licensed Materials Use of the Licensed Materials is subject to, and the Seller/Servicer shall comply at all times with: ■ The terms of this Master Systems License and any applicable System-Specific License ■ The Documentation; and ■ All other applicable requirements of the Purchase Documents (including, but not limited to, requirements relating to confidentiality such as those set forth in Section 1201.8) The Seller/Servicer’s use of each System constitutes an Eligible Electronic Transaction, as such term is defined in Section 1401.1(b), using Freddie Mac Systems within the meaning of the Guide, including, without limitation, Chapter 1401. (ii) Prohibited uses Under no circumstances shall the Seller/Servicer: (A) Provide access to or otherwise make the Freddie Mac Exclusionary List available to a Related Third Party or any other party except as permitted under and in accordance with Section 1201.8(a)(iii); or (B) Enable or permit any person or entity on the Freddie Mac Exclusionary List to access or use the Licensed Materials, whether directly or indirectly through the Seller/Servicer or any Related Third Party (iii) Seller responsibilities and Freddie Mac rights Freddie Mac Single-Family Seller/Servicer Guide Chapter 2401 As of 12/17/25 Page 2401-6 The Seller/Servicer is and shall remain fully responsible and liable for use of the Licensed Materials by each Related Third Party and any User and expressly consents to the sharing and receipt of Output, data and information among and between the Seller/Servicer and each Related Third Party as permitted by a System and described in its Documentation. The Seller/Servicer shall have controls in place to ensure that each Related Third Party and Authorized Users comply with the terms of this Master Systems License and any System-Specific License in their use of the Licensed Materials. Freddie Mac reserves the right, at any time and in its sole discretion, to modify, enhance, retire or otherwise cease providing the Licensed Materials or the Support Services. To the extent possible, Freddie Mac will endeavor to provide reasonable notice of any such action, unless it is legally required to cease providing the Licensed Materials immediately. Regardless of such action by Freddie Mac, the Seller/Servicer agrees that it will remain in full compliance with all applicable law in connection with its origination and Servicing of Mortgages. (iv) Distributed Code Regarding the Distributed Code, the Seller/Servicer shall: (A) Not make any copies of the Distributed Code, other than for the limited purpose of creating a single archival or backup copy (B) Use only the most recent version of the Distributed Code provided or made available by Freddie Mac (C) Follow Freddie Mac’s instructions concerning the cessation of use of the Distributed Code (including any old or retired versions thereof); and (D) Except to the extent otherwise permitted by Freddie Mac in writing, to not distribute to or otherwise share any Output with, a party not otherwise licensed by Freddie Mac to access such Output, except with respect to a consumer to whom such Output relates, upon his or her request (v) Licensed Materials Regarding Licensed Materials, the Seller/Servicer shall: (A) Not make any representation, statement or suggestion to a third party regarding any capability of any Licensed Materials that purport to be, or might reasonably be construed to be, made on behalf of Freddie Mac Freddie Mac Single-Family Seller/Servicer Guide Chapter 2401 As of 12/17/25 Page 2401-7 (B) Not issue any press release regarding its use of the Licensed Materials, or otherwise use Freddie Mac’s name or marks in any marketing or promotional materials without the prior written consent of a duly authorized officer of Freddie Mac; and (C) Permit Freddie Mac, from time to time upon reasonable notice, to audit facilities and systems used in conjunction with the Licensed Materials to confirm compliance with the requirements of this Master Systems License and any System-Specific License (e) System access; interface development and maintenance; Related Third Parties (i) System access The Seller/Servicer may access a System by means of a: (A) Web server hosted by or on behalf of Freddie Mac (B) System-to-system interface between the System and the Seller/Servicer’s platform which is developed and maintained by the Seller/Servicer and approved in writing by Freddie Mac; and/or (C) System interface with a Related Third Party-provided loan origination or other loan manufacturing tool or Servicing Tool (ii) Interface development and maintenance With respect to its System access under Section 2401.1(e)(i)(B), Freddie Mac may provide the Specifications to the Seller/Servicer pursuant to Section 2402.1 to facilitate the Seller/Servicer’s design, development and maintenance of the system-to-system interface with such System. With respect to its System access under Section 2401.1(e)(i)(C), Freddie Mac may have conducted limited testing on Related Third Party interfaces with loan origination or other loan manufacturing tools or Servicing Tools, and those interfaces which have been deemed to be compatible with identified Systems are listed on Freddie Mac’s website. Notwithstanding any Freddie Mac-conducted testing or website identification, and, without limiting the application of any other provision of this Master Systems License or a System- Specific License, Freddie Mac assumes no responsibility for, and shall bear no liability whatsoever arising out of or related to any interface identified in Sections 2401.1(e)(i)(B) or 2401.1(e)(i)(C), despite the fact that such an interface provides access to a System, or that Freddie Mac may have conducted limited testing or provided Support Services or other assistance with respect to the same. (iii) Related Third Parties Freddie Mac Single-Family Seller/Servicer Guide Chapter 2401 As of 12/17/25 Page 2401-8 As permitted under Section 2401.1(c), the Seller/Servicer may engage Related Third Parties to assist it in its furtherance of the Purpose. Freddie Mac does not endorse any Related Third Party or sanction any engagement by the Seller/Servicer of any Related Third Party. The Seller/Servicer shall maintain a separate, independent contract with each Related Third Party concerning the Seller/Servicer’s use of such party’s platform, product or service. As part of such contract, the Seller/Servicer may appoint a Related Third Party to act as the Seller/Servicer’s agent for purposes of gaining access to a System, including entering data into the System, ordering and receiving consumer credit data through the System, and obtaining Output, in each instance on behalf of its principal, the Seller/Servicer. The Seller/Servicer shall be responsible for and bear all liability arising out of or related to any act or omission of its Related Third Parties, including any act or omission that causes a Seller/Servicer to violate any applicable law and/or any provision of the Guide or other Purchase Document. Under no circumstances shall Freddie Mac assume any responsibility or bear any liability whatsoever arising out of or related to any act or omission of a Related Third Party, notwithstanding that Freddie Mac may have facilitated the relationship between the Seller/Servicer and such Related Third Party. The Seller/Servicer shall include in its separate, independent contracts with Related Third Parties provisions that (1) bind each Related Third Party to the terms and conditions of this Master Systems License and each applicable System-Specific License and (2) specifically designate Freddie Mac as an express, intended third-party beneficiary of each such contract solely for the purpose of enforcing Freddie Mac’s rights under such contract. Additionally, the Seller/Servicer shall monitor the performance of its Related Third Parties so as to ensure the compliance of each with this Master Systems License and each applicable System-Specific License. Freddie Mac may also maintain separate, independent contracts with Related Third Parties regarding their respective provision of platforms and services to other entities, including the Seller/Servicer. Freddie Mac may from time to time and in its sole discretion terminate any such contract, which termination could result in the need for the Seller/Servicer to obtain an alternate platform, product and/or service from an alternative provider. Freddie Mac will attempt to notify the Seller/Servicer of such termination, but shall have no liability arising out of or in connection with any such termination, whether or not prior notice is provided to the Seller/Servicer. (f) Authorized User registration; access management and security; requirements for Excluded Servicing Tools Freddie Mac Single-Family Seller/Servicer Guide Chapter 2401 As of 12/17/25 Page 2401-9 (i) Authorized User registration To facilitate its provision of System access to a Related Third Party for use on its behalf as provided hereunder, the Seller/Servicer may share Authorized Users’ identification codes (“User IDs”) and passwords, PIN or other access codes, including system-level access codes (“Sys-to-Sys Credentials”), together with User IDs, the “Authentication Credentials,” with such Related Third Party. In addition, Freddie Mac may provide or make available to the Seller/Servicer: ■ An electronic registration form for the provisioning of Authentication Credentials and Authorized Users (“Form”) and/or ■ Access Manager, an automated access and credential management application designed to facilitate the Seller/Servicer’s management of Authentication Credentials and its Authorized Users, which may also include one or more Forms (collectively, “Access Manager”) (ii) Access Manager The Seller/Servicer shall, and, if applicable, shall cause each Related Third Party to, specifically identify each Authorized User for the System in Access Manager. Access Manager may require the designation of one or more Authorized Users to perform administrative functions for the particular System (each, an “Administrator”) such as: ■ Identifying other Authorized Users to whom Freddie Mac may grant System(s) access ■ Receiving the Authentication Credentials from Freddie Mac; and ■ Adding or deleting Authorized Users and modifying or submitting new User IDs and completing additional Forms in accordance with the Documentation. (iii)Security and safeguarding requirements Without limiting the application of any information security or other similar requirement of a Purchase Document including, without limitation, any contained in Chapter 1302, the Seller/Servicer shall safeguard and protect all information it provides to Access Manager, as well as all Authentication Credentials and other Confidential Means of Access (as that term is defined in Section 1401.1(b)), and shall adopt security measures to prevent the loss, theft, unauthorized access, disclosure, compromise or use of any of the foregoing. Such measures shall include the maintenance of up-to-date virus detection software to protect against malware and other malicious software. As soon as practicable, and, in any event, no later than within one Business Day of an Administrator’s name change, or an employee’s or contractor’s termination, the Seller/Servicer shall either: Freddie Mac Single-Family Seller/Servicer Guide Chapter 2401 As of 12/17/25 Page 2401-10 ■ Utilize Access Manager to register the Administrator name change, or remove or otherwise delete such employee or contract worker as an Authorized User; or ■ Notify Freddie Mac of such name change or termination so that Freddie Mac may register the name change or revoke the employee’s or contractor’s access to each System (iv) Required notifications to Freddie Mac The Seller/Servicer shall notify Freddie Mac as soon as practicable and, in any event, no later than within one Business Day in the event: ■ Of any actual or suspected loss, theft or unauthorized access, disclosure, compromise or use of any System, Authentication Credential, or any other Confidential Means of Access ■ The Seller/Servicer has reason to believe that an Administrator’s access to a System, including Access Manager, is no longer secure for any reason ■ An unauthorized User has gained access to a System ■ An Authorized User has gained access to a System that he or she is not authorized to access or use; or ■ An Authorized User has used a System for purposes other than the Purpose (v) Recertification and credential management From time to time an Administrator may be required by Access Manager to engage in campaigns to recertify the authorizations and roles of Authorized Users. The Administrator shall comply with all reasonable instructions, including any provided through Access Manager, for any such campaign. The Seller/Servicer shall reset Authentication Credentials no less than once every 90 days, except with respect to Sys-to-Sys Credentials, which shall be reset no less than once every 365 days. In the event such resets do not occur, or if Authentication Credentials have not been used for a period of at least 90 days, or Sys-to-Sys Credentials have not been used for a period of at least 365 days, then, in any such event, Freddie Mac may, in its sole discretion, deactivate System access associated with any such Authentication Credential. (vi) Security best practices and responsibility Freddie Mac Single-Family Seller/Servicer Guide Chapter 2401 As of 12/17/25 Page 2401-11 Without limiting the application of any other provision of this Section 2401.1(f) or a Purchase Document, the Seller/Servicer agrees to implement and maintain industry best practices with respect to the security of, and access to, each System, including the imposition and enforcement of requirements against sharing of Authentication Credentials between and among Users, and accepts all risks and liability resulting from any failure to adopt and maintain such industry best practices. (vii) Excluded Servicing Tools The Seller/Servicer shall manage each of its Authorized Users’ access to those Excluded Servicing Tools that Freddie Mac designates from time to time in accordance with the Authorized User registration, access management, and security requirements set forth in this Section 2401.1(f). The Seller/Servicer shall not permit a Related Third Party to access an Excluded Servicing Tool unless otherwise permitted by Freddie Mac in writing (e.g., under another section of the Guide, other Purchase Document, applicable user agreement, system license or related system documentation). Until Freddie Mac designates an Excluded Servicing Tool as subject to this Section 2401.1(f), including through the issuance of a Form identifying such Excluded Servicing Tool, the Seller/Servicer must continue to follow the user access and security requirements applicable to such Excluded Servicing Tool. (g) Ownership of the Licensed Materials; rights in data (i) Ownership and confidentiality The Licensed Materials are the sole and exclusive property of Freddie Mac (or, as applicable, its third-party licensors). The Seller/Servicer acknowledges that it has no ownership or other rights or interests in the Licensed Materials, except to the extent of the rights expressly granted in this Master Systems License and any System-Specific License, and covenants that it will treat all nonpublic information and data concerning the Licensed Materials and any Support Services as strictly confidential in accordance with Section 1201.8. The Seller/Servicer will not modify, enhance, disassemble or reverse engineer any Licensed Materials in any manner or for any reason. All rights in and to copyrights, trade secrets, patents, trademarks and other rights in and to the Licensed Materials shall be the property of and remain with Freddie Mac (or, as applicable, its third-party licensors). (ii) Restrictions on use; Enhancements; and proprietary notices The Seller/Servicer agrees that Freddie Mac shall be the sole and exclusive owner of any actual or proposed changes, modifications, upgrades or enhancements in functionality, Freddie Mac Single-Family Seller/Servicer Guide Chapter 2401 As of 12/17/25 Page 2401-12 design or otherwise, to the Licensed Materials and any successor products or systems (collectively, the “Enhancements”). The Seller/Servicer hereby assigns, and agrees to assign, to Freddie Mac all rights in the Enhancements, without any recourse to the Seller/Servicer. The Seller/Servicer understands and acknowledges that Freddie Mac shall not be under any obligation to consider or implement any Enhancements it may suggest or recommend to Freddie Mac. The Seller/Servicer shall reproduce without modification on any copy of the Output, Specifications or Documentation all copyright, confidentiality and other proprietary notices included on the original version or otherwise provided or made available by the System or Freddie Mac. (iii)Use of System data The Seller/Servicer acknowledges and agrees that Freddie Mac may use, modify, reproduce and retain all data: (A) Submitted by a User to any System (B) Generated in the utilization of a System that pertains to the functionality or performance of the System; and/or (C) Necessary or useful in assisting Freddie Mac in the provision of Support Services (all such data collectively referenced in this Section 2401.1(g)(iii) as the “System Data”) for all purposes related to such System, the underlying software and models, and any actual or potential Mortgage to which such data relate, including, without limitation, for analytic, statistical, quality control and similar purposes (iv) Use of System Data or Aggregate Data Freddie Mac may provide statistical, comparative and summary information derived from the System Data (i.e., the “Aggregate Data”) to Freddie Mac’s customers and other third parties; provided, however, that except to the extent permitted or required by applicable law, Aggregate Data shall be anonymized and shall not specifically identify or be linked to any consumer. Notwithstanding the foregoing, Freddie Mac will not disclose System Data or Aggregate Data in a manner that either associates the Seller/Servicer with a particular Mortgage file, or enables the recipient of any such data to determine that the Seller/Servicer submitted such Mortgage file to the System, in either case unless: (A) Required by applicable law, a subpoena or a court order; or Freddie Mac Single-Family Seller/Servicer Guide Chapter 2401 As of 12/17/25 Page 2401-13 (B) Consented to by the Seller/Servicer. Notwithstanding anything to the contrary contained in this Master Systems License or any System-Specific License, Freddie Mac may provide System Data and Aggregate Data to: ■ FHFA ■ Any agency of the federal government ■ Any State government; or ■ As otherwise permitted by the Purchase Documents As set forth in Sections 1201.9 and 3301.1(a), and notwithstanding anything to the contrary contained in this Master Systems License or any System-Specific License, all System Data, Aggregate Data and other data and information associated with a Mortgage that is purchased or guaranteed by Freddie Mac shall be the sole and exclusive property of Freddie Mac, which it may use for any purpose including, but not limited to, such purposes set forth in this Section 2401.1(g). (h) Representations and warranties; indemnification This Master Systems License details the obligations and responsibilities of the Seller/Servicer concerning compliance with laws and representations made through data and documentation, including indemnification and warranty requirements, as outlined below: (i) General representations and warranties The Seller/Servicer acknowledges and agrees that: (A) All of the representations and warranties it is deemed to make under applicable Purchase Documents with respect to loan documentation, data and other information it provides to Freddie Mac shall apply to any such materials it or any User provides to Freddie Mac through any System, as well as to the Seller/Servicer’s use of the Licensed Materials; and (B) Freddie Mac will have all rights and remedies available to it under the Purchase Documents with respect to a breach by the Seller/Servicer of any such representation or warranty or any Seller/Servicer misrepresentation (ii) Legal compliance In addition to the provisions of Sections 2401.1(h)(i)-(iii) or any other provision of a Purchase Document pertaining to its compliance with laws including, without limitation, Section 1301.2 and Chapter 4202, the Seller/Servicer represents, warrants and agrees that Freddie Mac Single-Family Seller/Servicer Guide Chapter 2401 As of 12/17/25 Page 2401-14 it has obtained or, if applicable, will obtain, legal counsel and has developed policies, systems and procedures to ensure that its use of the Licensed Materials is, and, at all times relevant to this Master Systems License and any System-Specific License, shall remain, in full compliance with: (A) All federal, State and local laws, rules and regulations applicable to its activities in connection with which any Licensed Materials are used, including, without limitation, the Real Estate Settlement Procedures Act, the Truth in Lending Act, the Fair Credit Reporting Act, the Equal Credit Opportunity Act and the Home Mortgage Disclosure Act, and each of their implementing regulations and commentary, as applicable; and (B) All applicable laws, rules, regulations and conventions relating to data privacy, international communications and the importation and exportation of software and data The Seller/Servicer bears sole responsibility for complying with all laws, rules, regulations and conventions referenced in the preceding Section 2401.1(h)(ii), and shall not rely on the Licensed Materials in connection with its compliance efforts. The Seller/Servicer acknowledges and agrees that: (A) The Licensed Materials do not analyze compliance with laws, regulations, or ordinances, or with any requirements that may be imposed by any regulator; and (B) The Seller/Servicer’s compliance obligations shall in no event be imposed upon, assumed or shared by Freddie Mac as a result of the Seller/Servicer’s (or any Related Third Party’s) use of the Licensed Materials (iii)User and Administrator representations In addition to the provisions of Sections 2401.1(h)(i)-(ii), the Seller/Servicer further represents, warrants and agrees that: (A) Each Administrator is an officer of the Seller/Servicer or is otherwise specifically authorized by the Seller/Servicer to perform such administrative functions (B) Each User is duly authorized to act on behalf of, and has full authority to legally bind the Seller/Servicer by such User’s acts and omissions (C) Freddie Mac is entitled to rely on the truth, accuracy and completeness of all data and information submitted by each Administrator and any other User to each System, including any data and information submitted through a Form; and (D) No computer virus, including any malware, time bomb or any code designed to cause a System to malfunction or self-destruct or allow unauthorized access or cause harm to a System shall be introduced into a System by or through the Seller/Servicer. Freddie Mac Single-Family Seller/Servicer Guide Chapter 2401 As of 12/17/25 Page 2401-15 (iv) Indemnification In addition to its obligations under the provisions of any Purchase Document, including Chapter 1401, the Seller/Servicer shall indemnify Freddie Mac and its directors, officers, employees, agents, successors and assigns and hold each harmless from and against any and all liabilities, losses, claims, damages, costs and expenses, including reasonable attorneys’ fees, arising directly or indirectly out of or relating to: ■ Any User’s use of the Licensed Materials; and/or ■ Any breach of a Seller/Servicer representation, warranty, covenant and/or obligation under this Master Systems License or any System-Specific License, whether such breach arises out of its own action or inaction or the action or inaction of a Related Third Party, any User, or of any Seller/Servicer or Related Third Party director, officer, employee, subcontractor, partner, principal, agent, successor or assign Freddie Mac shall provide the Seller/Servicer with notice of any such claim after it comes to Freddie Mac’s attention. (i) Limited warranty; liability limitation Freddie Mac represents and warrants that it has the right to grant the Seller/Servicer the rights specified in this Master Systems License and any System-Specific License. EXCEPT AS EXPRESSLY PROVIDED IN SECTION 2401.1(c)(iii), THE LICENSED MATERIALS AND THE SUPPORT SERVICES ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS, AND ALL USES OF THE FOREGOING ARE AT THE SELLER/SERVICER’S, A RELATED THIRD PARTY’S AND EACH USER’S SOLE RISK. FREDDIE MAC MAKES NO REPRESENTATIONS OR WARRANTIES WITH RESPECT TO ANY DATA OR OTHER INFORMATION OBTAINED, PROVIDED OR TRANSMITTED THROUGH ANY SYSTEM, INCLUDING, WITHOUT LIMITATION, ANY DATA OR OTHER INFORMATION CONTAINED IN A CONSUMER REPORT. EXCEPT TO THE EXTENT EXPRESSLY PROVIDED IN SECTION 2401.1(i), ALL WARRANTIES (BOTH EXPRESS AND IMPLIED) CONCERNING THE LICENSED MATERIALS AND THE SUPPORT SERVICES ARE HEREBY EXPRESSLY DISCLAIMED, INCLUDING ANY WARRANTIES OF MERCHANTABILITY, ACCURACY AND/OR FITNESS FOR A PARTICULAR PURPOSE. ONE OR MORE SYSTEMS MAY INCLUDE COLOR DESIGNATIONS IN THEIR RESPECTIVE OUTPUT, SOME OF WHICH MAY BE EMBEDDED IN ICONS. ANY SUCH COLOR DESIGNATION (INCLUDING ANY ICON IN WHICH SUCH A DESIGNATION IS EMBEDDED) IS INTENDED SOLELY AS A VISUAL GUIDE FOR INDICATING THE NEED (IF ANY) FOR AN AUTHORIZED USER TO REVIEW DATA FILES FOR ERRORS OR INCONSISTENCIES, AS SET FORTH IN THE LICENSED MATERIALS. SUCH DESIGNATIONS AND ICONS ARE NOT PROVIDED FOR ANY OTHER REASON, NOR SHOULD THEY BE USED OR RELIED UPON EXCEPT FOR Freddie Mac Single-Family Seller/Servicer Guide Chapter 2401 As of 12/17/25 Page 2401-16 PURPOSES OF TRIGGERING DATA FILE REVIEWS AS SET FORTH IN THE LICENSED MATERIALS. NO OUTPUT (INCLUDING ANY DESIGNATION OR ICON) GENERATED BY A SYSTEM SHALL BE INTERPRETED OR CONSTRUED AS GIVING RISE TO ANY AGREEMENT OR OBLIGATION ON THE PART OF FREDDIE MAC TO PURCHASE ANY MORTGAGE ASSOCIATED WITH THE OUTPUT. NOTWITHSTANDING ANYTHING TO THE CONTRARY IN THIS MASTER SYSTEMS LICENSE OR IN ANY SYSTEM-SPECIFIC LICENSE: (A) FREDDIE MAC WILL HAVE NO LIABILITY TO (1) THE SELLER/SERVICER, OR (2) ANY RELATED THIRD PARTY, ANY USER OR ANY OTHER INDIVIDUAL OR ENTITY (COLLECTIVELY, “THIRD PARTIES”) FOR INDIRECT, INCIDENTAL, SPECIAL OR CONSEQUENTIAL DAMAGES OF ANY TYPE WHATSOEVER, INCLUDING, WITHOUT LIMITATION, LOST PROFITS ARISING OUT OF OR RELATING IN ANY MANNER WHATSOEVER TO THE LICENSED MATERIALS, THE SUPPORT SERVICES, OR ANY USE THEREOF, WHETHER UNDER A CONTRACT, TORT OR ANY OTHER THEORY OF LIABILITY, EVEN IF FREDDIE MAC, SELLER/SERVICER OR ANY THIRD PARTY IS AWARE OF THE POSSIBILITY OF SUCH DAMAGES (B) FREDDIE MAC WILL HAVE NO LIABILITY TO ANY THIRD PARTY FOR ANY CLAIMS ARISING OUT OF OR RELATING TO THE LICENSED MATERIALS, THE SUPPORT SERVICES, OR ANY USE OF OR INABILITY TO USE THE LICENSED MATERIALS OR SUPPORT SERVICES. (C) WITHOUT LIMITING THE PROVISIONS OF SECTIONS 2401.1(i)(A) AND (B), FREDDIE MAC’S SOLE LIABILITY ARISING OUT OF OR RELATING TO THE LICENSED MATERIALS OR THE SUPPORT SERVICES FROM ANY SOURCE AND UNDER ANY THEORY OF LIABILITY WHATSOEVER, INCLUDING, WITHOUT LIMITATION, LIABILITY ARISING OUT OF CONTRACT, NEGLIGENCE OR STRICT LIABILITY, OR IN TORT OR WARRANTY, WILL CONSIST OF ACTUAL MONETARY DAMAGES UP TO, BUT NOT TO EXCEED, AN AGGREGATE OF FIVE THOUSAND DOLLARS ($5,000). FREDDIE MAC AND THE SELLER/SERVICER EXPRESSLY ACKNOWLEDGE AND AGREE THAT THE LIMITATIONS AND EXCLUSIONS CONTAINED HEREIN (1) REPRESENT THE PARTIES’ AGREEMENT AS TO THE ALLOCATION OF RISK BETWEEN THEM (INCLUDING, WITHOUT LIMITATION, THE POSSIBILITY THAT A REMEDY MAY FAIL ITS ESSENTIAL PURPOSE AND CAUSE CONSEQUENTIAL LOSS), WITHOUT WHICH THE PARTIES WOULD NOT HAVE BEEN WILLING TO ENTER INTO THIS MASTER SYSTEMS LICENSE OR ANY SYSTEM-SPECIFIC LICENSE INCORPORATED HEREIN, AND (2) FORM AN ESSENTIAL BASIS OF THE BARGAIN BETWEEN THE PARTIES (j) Term and Termination Freddie Mac Single-Family Seller/Servicer Guide Chapter 2401 As of 12/17/25 Page 2401-17 (i) Term The term of this Master Systems License shall commence upon a User’s first access to any System on or after the Effective Date, and, except as set forth in this Section 2401.1(j), shall continue in full force and effect until terminated by the Seller/Servicer upon thirty (30) days’ prior written notice to Freddie Mac, or by Freddie Mac upon ten (10) days’ prior written notice to the Seller/Servicer. (ii) Termination of rights under Master Systems License Without limiting Freddie Mac’s rights to terminate any User’s access to a System as provided for in this Master Systems License, Freddie Mac may terminate this Master Systems License and/or any System-Specific License and/or Seller/Servicer’s rights to access and use any specific System pursuant to this Master Systems License, effective immediately, upon notice to the Seller/Servicer in the event of any default by the Seller/Servicer under this Master Systems License, or any default by the Seller/Servicer under the terms of any Purchase Document or other agreement between Freddie Mac and the Seller/Servicer, including any System-Specific License. The Seller/Servicer’s rights under this Master Systems License will automatically terminate if and when the Seller/Servicer ceases to be an approved Freddie Mac Seller/Servicer. Freddie Mac may terminate an Authorized User’s rights to use any System if an Authorized User or Related Third Party identified in the Freddie Mac Exclusionary List (or any of its employees, contractors, directors or officers identified in the Freddie Mac Exclusionary List) participates as described in Section 3101.1 in the origination, sale, quality control or Servicing of a Mortgage or in the underlying real estate transaction. (iii)Effect of termination All System-Specific Licenses and the rights of all Authorized Users to use each System will terminate as of the effective date of termination of this Master Systems License. Freddie Mac may terminate, in its sole discretion and without notice, what it believes to be unauthorized access to any System by any User. Upon termination of the Seller/Servicer’s right to use a System, the Seller/Servicer will have no further right to access such System or any associated Documentation, Output or Support Services, except that the Seller/Servicer may retain and continue to use a copy of any Output associated with the System to the extent required by: (A) The Purchase Documents (B) The Seller/Servicer’s normal internal quality control processes or document retention protocols; or Freddie Mac Single-Family Seller/Servicer Guide Chapter 2401 As of 12/17/25 Page 2401-18 (C) Applicable law, in each case subject to the provisions of this Master Systems License and any applicable System-Specific License Upon termination, the Seller/Servicer will promptly, and in no event later than thirty (30) days after the effective date of such termination, return to Freddie Mac (or, if requested by Freddie Mac, destroy and have an officer of the Seller/Servicer certify in writing that it has destroyed) all copies of Distributed Code and Documentation. Any provisions of this Master Systems License and any System-Specific License that contemplate their continuing effectiveness following termination of this Master Systems License and any System-Specific License including, but not limited to, Sections 2401.1(d), 2401.1(g), 2401.1(h), 2401.1(i), 2401.1(j)(iii) and 2401.1(k) hereof shall survive any termination of this Master Systems License and such System-Specific License. (k) Additional provisions (i) Assignment The Seller/Servicer shall not assign any of its rights or obligations under this Master Systems License or any System-Specific License in any manner whatsoever without Freddie Mac’s prior written consent. (ii) Notices All notices required or permitted hereunder, including, but not limited to, notice of an amendment to the terms of this Master Systems License or any System-Specific License, shall be in accordance with Section 1101.2(d) or Section 1302.2(b), as applicable, and may be provided via the applicable System. (iii)Waivers The failure of either party to exercise in any respect any right or remedy provided for in this Master Systems License shall not be deemed a waiver of such right or remedy. No waiver at any time of any provision of this Master Systems License or any System- Specific License (any such license, a “License”) will be deemed a waiver of any other provision of that License or any other License, or a waiver of that or any other provision of this License or any other License at any other time. (iv) Seller/Servicer responsibilities The Seller/Servicer recognizes that it is responsible for: (A) Obtaining and maintaining connectivity to each System; and Freddie Mac Single-Family Seller/Servicer Guide Chapter 2401 As of 12/17/25 Page 2401-19 (B) Developing and maintaining its own record-keeping processes and systems for Output, in each instance at its own expense in accordance with the Documentation. (v) Governing law This Master Systems License and each System-Specific License will be construed, and the rights and obligations of the parties hereunder determined, in accordance with the laws of the Commonwealth of Virginia, without regard to provisions concerning conflicts of law. Any dispute arising out of or in connection with this Master Systems License and any System-Specific License shall be settled in a proceeding brought in the United States District Court for the Eastern District of Virginia, and the Seller/Servicer irrevocably submits to the jurisdiction and venue of that Court. Subject to the provisions of Section 2401.1(i) above, the rights and remedies of the parties are cumulative and are in addition to, and not in lieu of, all rights and remedies available at law and in equity. (vi) Severability If any provision of this Master Systems License or a System-Specific License is held invalid, illegal or unenforceable, such provision will to that extent be deemed omitted from this Master Systems License or such System-Specific License, and the remaining provisions of the Master Systems License or System-Specific License will continue to be valid and enforceable and will not be affected in any way. (vii) Successors and conflicts This Master Systems License and each System-Specific License is binding upon the parties and (as permitted under Section 2401.1(k)(i)) their respective successors and assigns. In the event of a conflict between a term or condition of this Master Systems License and a term or condition of any System-Specific License, the term or condition of the System-Specific License shall prevail. (viii) Amendments Freddie Mac may amend this Master Systems License and each System-Specific License by providing notice to the Seller/Servicer of the terms of such amendment in accordance with Section 2401.1(k)(ii). The Seller/Servicer’s use of any System on and after the effective date of any such amendment shall constitute the Seller/Servicer’s consent to, and agreement with, the terms of the amendment. (ix) Access restrictions Freddie Mac Single-Family Seller/Servicer Guide Chapter 2401 As of 12/17/25 Page 2401-20 Notwithstanding any other provision in the Guide to the contrary, Freddie Mac may utilize traffic filtering or block or otherwise restrict the access of Seller/Servicers, Related Third Parties and/or their respective Authorized Users (as defined in Section 2401.1(b)) to one or more Systems (as defined in Section 2401.1(b)) from certain countries or regions outside the United States. This may include, but is not limited to, blocking access from countries or regions implicated by sanctions or other restrictions imposed by the Office of Foreign Assets Control (“OFAC”). Freddie Mac shall have no liability to Seller/Servicers, their Related Third Parties or any other party as a result of imposing or effecting any such restrictions on access. Freddie Mac Single-Family Seller/Servicer Guide Chapter 2402 As of 04/08/26 Page 2402-1 Chapter 2402: System-Specific Licenses for Selling Tools and Systems 2402.1: System-Specific License for Specifications (12/17/25) This section contains information related to: ■ Scope and applicability ■ Definitions ■ Provision for developing interfaces and consumer messages with provided specifications ■ Representations and warranties (a) Scope and applicability The Specifications are licensed pursuant to this System-Specific License and the Master Systems License. Immediately upon a User’s first receipt of any Specifications on or after the Effective Date, the Seller/Servicer shall be bound by this System-Specific License and the Master Systems License. This System-Specific License is incorporated into and made a part of the Master Systems License by this reference. Any reference herein to the System-Specific License shall be deemed to include this System-Specific License and the Master Systems License. (b) Definitions The definitions below apply for purposes of this System-Specific License. Capitalized terms used but not defined in this System-Specific License have the meaning set forth in the Glossary, the Master Systems License (Chapter 2401) or elsewhere in the Guide: Definitions related to the System-Specific License for specifications C Consumer Message A finding or message developed by the Seller/Servicer that is readily understood by a consumer and is made available to such consumer by the Seller/Servicer through the Lender Platform Freddie Mac Single-Family Seller/Servicer Guide Chapter 2402 As of 04/08/26 Page 2402-2 Definitions related to the System-Specific License for specifications I Interface One or more technical or user interfaces developed, owned and/or maintained by or on behalf of the Seller/Servicer that enables Users to communicate with and use one or more Systems through the transmission and receipt of data and other information to and from each such System by means of the Lender Platform L L2C Specifications Any lender-to-consumer Specifications provided to the Seller/Servicer that enables it to develop Consumer Messages Lender Platform A custom loan origination or other technology platform (including any web-based application, software or system as well as each Interface and all releases, upgrades and other modifications thereto) developed, owned and/or maintained by or on behalf of the Seller/Servicer Lender Test Materials The meaning set forth in Section 2402.1(c)(v) below S Specifications The specifications, including L2C Specifications, integration guides and any related technical documentation provided by or on behalf of Freddie Mac to enable the development and maintenance of each Interface and Consumer Message as applicable, including any Specification Update Specification Update The meaning set forth in Section 2402.1(c)(iii) below (c) Provision for developing interfaces and consumer messages with provided specifications The following terms govern Freddie Mac’s provision of Specifications and the Seller/Servicer’s responsibilities for developing, implementing and maintaining interfaces and consumer messages with one or more Systems. (i) Provision of Specifications Freddie Mac shall provide discrete sets of Specifications to the Seller/Servicer to facilitate the development of Consumer Messages and one or more Interfaces relating to one or more Systems. Each set of Specifications is incorporated into this System-Specific Freddie Mac Single-Family Seller/Servicer Guide Chapter 2402 As of 04/08/26 Page 2402-3 License by this reference and constitutes confidential information for purposes of Sections 1201.8 and 2401.1(g)(i). Note: The terms and conditions of this System-Specific License shall apply to all Specifications separately provided by Freddie Mac. (ii) Development responsibilities The Seller/Servicer shall develop and maintain the Interface and each Consumer Message solely and exclusively at its own direction, cost and expense and shall have complete and exclusive ownership of the Interface and each Consumer Message subject to the license set forth in Section 2402.1(c)(vi). (iii) Compliance The Seller/Servicer shall be solely responsible for the accuracy, technical sufficiency and functionality of the Interface. The Interface shall at all times comply in all respects with the Specifications, including any modifications to or replacements of the Specifications (each such modified or replaced version of a Specification referred to herein as a “Specification Update”) as Freddie Mac may undertake from time to time. (iv) Accuracy The Seller/Servicer shall be solely responsible for the accuracy of each Consumer Message, each of which shall at all times comply in all respects with: ■ The Specifications, including the L2C Specifications, and ■ All federal, State and local laws, rules and regulations applicable to a Consumer Message, including, without limitation, the Real Estate Settlement Procedures Act, Truth in Lending Act, Fair Credit Reporting Act, Equal Credit Opportunity Act and Home Mortgage Disclosure Act and each of their implementing regulations and commentary, as applicable Freddie Mac has the right, but not the obligation, to review and comment on each Consumer Message. The Seller/Servicer shall promptly make (or cause to be made) any modifications to a Consumer Message that Freddie Mac may request, and in no event shall any Consumer Message contain any (x) Output, including, without limitation, any credit risk categorization or loan purchase eligibility such as “Accept” or “Eligible,” or (y) reference to Freddie Mac or a System which reference has not previously been approved in writing by an officer of Freddie Mac. (v) Testing Except as set forth below in Section 2402.1(c)(vi), the Seller/Servicer and Freddie Mac may mutually agree to test the Seller/Servicer’s implementation of the Specifications. In Freddie Mac Single-Family Seller/Servicer Guide Chapter 2402 As of 04/08/26 Page 2402-4 such event, Freddie Mac may retain a third-party vendor to perform such testing on Freddie Mac’s behalf, and the Seller/Servicer shall provide to Freddie Mac and/or its vendor: ■ One access privilege or one copy of the Lender Platform, ■ One copy of each export and any other file (including any Consumer Message) along with any associated documentation that includes the results of the Seller/Servicer’s testing (collectively with the Lender Platform, the “Lender Test Materials”), and ■ Reasonable assistance in such testing The Seller/Servicer shall use commercially reasonable efforts to correct any defects in the Interface revealed by any such testing. In addition to the foregoing, the Seller/Servicer will correct any “bugs” or other defects in the Interface promptly after it receives notice thereof from Freddie Mac. (vi) Specification updates From time to time Freddie Mac may make Specification Updates available to the Seller/Servicer, which the Seller/Servicer shall implement in accordance with the timelines and testing requirements (if any) set forth in each Specification Update. Freddie Mac will provide the Seller/Servicer with as much notice as is practicable under the circumstances with respect to each Specification Update, including any such update that Freddie Mac directs the Seller/Servicer to implement on an emergency basis. If Freddie Mac does not specify an implementation timeline for a Specification Update, the implementation date shall be ninety (90) days after publication of the Specification Update. If a Specification Update sets forth testing requirements, the Seller/Servicer shall not implement an associated version of its Interface or any related Consumer Message until Freddie Mac has successfully conducted its review and, as applicable, testing with the Seller/Servicer. (vii) License for testing The Seller/Servicer hereby grants to Freddie Mac a royalty-free, nonexclusive and nontransferable license to use the Lender Test Materials for testing and evaluation purposes as permitted under this Section 2402.1(c). (d) Representations and warranties In addition to representations and warranties made and otherwise referenced in the Master Systems License, the Seller/Servicer represents and warrants to Freddie Mac that: Freddie Mac Single-Family Seller/Servicer Guide Chapter 2402 As of 04/08/26 Page 2402-5 ■ The Interface will comply with the Specifications, ■ Each Consumer Message will comply with all laws and regulations as set forth in Section 2402.1(c)(iv), ■ The Interface will accurately transmit to the System all data and information input into the Interface, ■ The Lender Platform will not violate any patents, copyrights or other proprietary rights belonging to third parties, and ■ The Seller/Servicer will use its best efforts to ensure that the Lender Platform will at all times be and remain free of computer viruses and any code designed to cause the System to malfunction or self-destruct or to allow unauthorized access or cause harm to the System

Source: Freddie Mac Single-Family Seller/Servicer Guide Section 2401.1 — Master Systems License · source URL · snapshot 5869ee9e606cd4ae