Freddie Mac Single-Family Seller/Servicer Guide Section 3101.1 — Freddie Mac Exclusionary List

Freddie Mac Single-Family Seller/Servicer Guide Section 3101.1 — Freddie Mac Exclusionary List

3101.1: Freddie Mac Exclusionary List (02/04/26) This section contains requirements related to: ■ Purpose and use of the Exclusionary List ■ Seller/Servicer warranties regarding the Exclusionary List ■ Reporting and confidentiality obligations ■ Process for placement on the Exclusionary List ■ Remedies (a) Purpose and use of the Exclusionary List (i) Purpose of the Exclusionary List Freddie Mac maintains the Freddie Mac Exclusionary List (“Exclusionary List”) to protect the integrity of its Mortgage purchasing and Servicing functions. The names of persons or entities whose conduct presents risks to Freddie Mac, as determined by Freddie Mac in its sole discretion, may be placed on the Exclusionary List, in which case such persons or entities are prohibited from doing business with Freddie Mac in any role described in Section 3101.1(a)(ii) below. (ii) Use of the Exclusionary List The Seller/Servicer must use the Exclusionary List only for the following purposes: (A) Screen parties involved in the origination of the Mortgage Before the sale of each Mortgage to Freddie Mac, the Seller must use the Exclusionary List to determine whether, as of the Note Date, a person or entity whose name is on the Exclusionary List performed any of the following roles in the origination of the Mortgage or the underlying real estate transaction: ■ Borrower ■ Property seller Freddie Mac Single-Family Seller/Servicer Guide Chapter 3101 As of 12/17/25 Page 3101-2 ■ Loan Originator or Loan Origination Company (e.g., loan officers, Third-Party Originators, retail lenders, Mortgage Brokers and Correspondents) ■ Real estate agent or real estate company ■ Settlement agent or the individual listed as the settlement agent on the Settlement/Closing Disclosure Statement ■ Settlement company ■ Appraiser or appraisal company If a party whose name is on the Exclusionary List performed any of these roles in the origination of a Mortgage or the underlying real estate transaction, the Mortgage is not eligible for sale to Freddie Mac. (B) Screen parties involved in sales, quality control, loan production, processing, underwriting or Servicing functions for Freddie Mac Mortgages The Seller/Servicer must use the Exclusionary List to confirm that none of the Seller/Servicer’s own employees engaged in any of the following functions with respect to Freddie Mac Mortgages are on the Exclusionary List: ■ Sales ■ Quality control ■ Loan production ■ Processing ■ Underwriting ■ Servicing This prohibition includes both the Seller/Servicer’s own employees and any third party to whom sales, quality control, loan production, processing, underwriting or Servicing functions regarding Freddie Mac Mortgages are outsourced or assigned. The Seller/Servicer must screen new employees involved in the aforementioned activities against the Exclusionary List at the time of hiring and at least twice per year thereafter. The Seller/Servicer must confirm that any buyer of a short sale property is not on the Exclusionary List. Freddie Mac Single-Family Seller/Servicer Guide Chapter 3101 As of 12/17/25 Page 3101-3 Note: Prohibited roles in sales functions include, without limitation, parties involved in the delivery of Freddie Mac Mortgages. Prohibited roles in quality control functions include, without limitation, parties involved in reviewing eligibility of Freddie Mac Mortgages and reporting adverse findings to Freddie Mac. (iii)Access to the Exclusionary List The Exclusionary List is updated at least monthly and is available to Seller/Servicers via Freddie Mac Gateway®. The Seller/Servicer must use only the most current version of the Exclusionary List and must obtain an authorized ID and password to access the Exclusionary List. Seller/Servicers may obtain additional information on accessing the Exclusionary List by calling Customer Service at 800-FREDDIE or contacting their Freddie Mac account representative. (b) Seller/Servicer warranties regarding the Exclusionary List (i) Seller warranties regarding the Exclusionary List With respect to each Mortgage delivered to Freddie Mac, the Seller represents and warrants that: ■ As of the Note Date, no person or entity whose name is listed on the Exclusionary List performed a role in the origination of the Mortgage, the sale of the Mortgage to Freddie Mac or the underlying real estate transaction (as set forth in Section 3101.1(a)(ii)(A), above) ■ No person or entity whose name is listed on the Exclusionary List performed a role in the sales, quality control, loan production, processing, underwriting or Servicing functions (as set forth in Section 3101.1(a)(ii)(B), above) for the Mortgage at any time ■ It will maintain sufficient controls, and supporting documentation of such, to meet these warranty obligations (ii) Waiver of Seller warranties regarding the Exclusionary List Before the Funding Date, the Seller may contact Freddie Mac to request review of a Mortgage to obtain a waiver of the warranty requirements in Sections 3101.1(b)(i) and 1301.5(c)(i)(8). The Seller should make such requests to Freddie Mac as set forth in Section 1301.5(c)(i). (iii)Servicer warranties regarding the Exclusionary List Freddie Mac Single-Family Seller/Servicer Guide Chapter 3101 As of 12/17/25 Page 3101-4 With respect to each Mortgage serviced on behalf of Freddie Mac, the Servicer represents and warrants that: ■ No individual or entity on the Exclusionary List will perform a role in any Servicing or quality control functions relating to the Mortgage. This warranty applies to both the Servicer’s own employees and any third party to whom Servicing or quality control functions regarding Freddie Mac Mortgages are outsourced or assigned. ■ The buyer of a short sale property is not on the Exclusionary List ■ It will maintain sufficient controls, and supporting documentation of such, to meet these warranty obligations (iv) Waiver of Servicer warranties regarding the Exclusionary List The Servicer must contact Freddie Mac to request a written waiver before performing a function or entering into a transaction that would violate the Servicer’s warranties set forth in Section 3101.1(b)(iii). The Servicer should make such request to the Freddie Mac Exclusionary List mailbox at [email protected]. As part of the request, the Servicer must inform Freddie Mac of the nature and extent of the role played in the proposed transaction by the person or entity whose name is on the Exclusionary List and provide other relevant information upon request. If Freddie Mac elects to grant the waiver, Freddie Mac will provide to the Servicer written notice of such election, in which case the warranty concerning the involvement of an excluded person or entity will not be applicable to such transaction. All other requirements of the Purchase Documents relating to the Servicing of the Mortgage will remain in full force and effect. Freddie Mac’s decision regarding the waiver of any warranties is within its sole discretion. (c) Reporting and confidentiality obligations (i) Reporting obligations of the Seller/Servicer The Seller/Servicer must immediately report the discovery of a possible breach of any warranty in Section 3101.1 to the Freddie Mac Exclusionary List mailbox at [email protected]. (ii) Confidentiality and use of the Exclusionary List The Exclusionary List and the identities of the persons and entities on the Exclusionary List whose names are not publicly available are “Freddie Mac confidential information” for the purposes of Section 1201.8. Freddie Mac Single-Family Seller/Servicer Guide Chapter 3101 As of 12/17/25 Page 3101-5 The Seller/Servicer represents and warrants that it will keep the Exclusionary List confidential in accordance with the terms and conditions of Section 1201.8. The Seller/Servicer may use the Exclusionary List only as required in Section 3101.1(a)(ii) and must not use or disclose the Exclusionary List for any other purpose without first obtaining Freddie Mac’s written permission. The Seller/Servicer will indemnify Freddie Mac for any loss, damage, or expense resulting from the Seller/Servicer’s failure to maintain the confidentiality of the Exclusionary List or information contained in the Exclusionary List. (d) Process for placement on the Exclusionary List Freddie Mac will generally provide an individual or entity with written notice of any proposed placement of their name on the Exclusionary List, along with an opportunity to submit a written response; however, Freddie Mac may determine, in its sole discretion, that circumstances require immediate placement of a person’s or entity’s name on the Exclusionary List, without prior written notice. Grounds for placement on the Exclusionary List include, without limitation: ■ Fraud or possible fraud ■ Misrepresentations, misstatements or omissions of facts ■ Theft or misappropriation of funds ■ Willful or reckless violation of statutory or regulatory requirements ■ Business practices that Freddie Mac determines present risks to Freddie Mac ■ Lack of business controls to ensure the integrity of the Mortgages sold to or serviced for Freddie Mac ■ Evidence that demonstrates a lack of integrity or business competence ■ Any grounds that, in Freddie Mac’s judgment, may adversely affect Freddie Mac Freddie Mac, in its sole discretion, will render a final decision regarding placement on the Exclusionary List after reviewing any response submitted by the proposed individual or entity. (e) Remedies Freddie Mac’s remedies for a breach of the warranties, obligations or requirements of the Seller/Servicer regarding the Exclusionary List include all remedies available to Freddie Mac under the Purchase Documents, including, without limitation, suspension or termination of the Seller or Servicer and repurchase of the Mortgage. Freddie Mac Single-Family Seller/Servicer Guide Chapter 3101 As of 12/17/25 Page 3101-6 3101.2: FHFA Suspended Couterparty Program (12/17/25) This section contains requirements related to: ■ Avoiding employing Named Parties ■ Selling or Servicing Mortgages involving Named Parties ■ Responsibility to review FHFA’s SCP list FHFA maintains a Suspended Counterparty Program (SCP) and requires Freddie Mac to refrain from and/or cease conducting business with individuals and entities listed on FHFA’s SCP list (“Named Parties”), subject to any conditions or exclusions in the applicable Named Party’s final suspension order. (a) Avoiding employing Named Parties Seller/Servicers must establish and maintain procedures to ensure Seller/Servicers do not employ or contract with Named Parties for any purpose directly related to the origination, underwriting, or Servicing of a Freddie Mac Mortgage, subject to any conditions or exclusions in the applicable SCP Named Party’s final suspension order. (b) Selling or Servicing Mortgages involving Named Parties The Seller must not sell to Freddie Mac, and the Servicer must not engage in any Servicing activity in connection with, any Mortgage in which a Named Party is a necessary signatory on the Note, Security Instrument, modification agreement, deed of sale (e.g., short sale, third- party sale, etc.) or other contract related to such Mortgage, subject to any conditions or exclusions in the applicable Named Party’s final suspension order. (c) Responsibility to review FHFA’s SCP list Seller/Servicers are responsible for reviewing FHFA’s SCP list and related final suspension orders, which can be found on FHFA’s website at http://www.fhfa.gov/SupervisionRegulation/LegalDocuments/Pages/SuspendedCounter partyProgram.aspx. Freddie Mac Single-Family Seller/Servicer Guide Chapter 3201 As of 05/06/26 Page 3201-1 Chapter 3201: Fraud Prevention, Detection and Reporting; Reporting Other Suspicious Activity 3201.1: Fraud prevention and detection measures (05/06/26) The Seller/Servicer must have in place comprehensive practices and procedures to prevent and detect fraud throughout each stage of the origination and Servicing of a Mortgage and in related real estate transactions. This section identifies fraud prevention and detection requirements related to: ■ Employee hiring and training ■ Origination and Servicing ■ Seller/Servicer’s in-house quality control program ■ Additional fraud mitigation resources Seller/Servicers must implement additional practices and procedures, as deemed necessary, to ensure that an effective fraud prevention and detection plan is in place. (a) Employee hiring and training The Seller/Servicer must have screening and hiring practices in place to ensure the integrity of its employees. Employees and any entity or individual engaged to handle or perform functions typically handled by employees, and in a position to notice or report fraud and suspected fraud, must receive training in each applicable area of the Seller/Servicer’s mortgage business about: ■ Common and emerging fraud schemes ■ Red flags that may signal fraud and the need for more review The Seller/Servicer must communicate its procedures (including requirements of this chapter) for prevention, detection and reporting of fraud and suspected fraud to its employees and the entities and individuals referenced above. Parties engaged to handle or perform functions typically performed by employees and in a position to notice or report fraud or suspected fraud may include: ■ Contract underwriters Freddie Mac Single-Family Seller/Servicer Guide Chapter 3201 As of 05/06/26 Page 3201-2 ■ Contract processing services (including loan processors) ■ Contract quality control firms ■ Borrower outreach companies ■ Loss mitigation services ■ Collection companies The training must include periodic updates at least annually to ensure employees and parties referenced above are aware of emerging fraud scenarios. The Seller/Servicer must either provide the training directly, hire a third party to provide the training, or obtain an annual written verification from the engaged entity or individual confirming that training has already been received from another party in accordance with the requirements of this section. (b) Origination and Servicing The Seller/Servicer must take the following minimum steps to prevent and detect fraud in the areas of origination and Servicing: ■ Escalate internally and properly investigate information received from any source that indicates suspected fraud. Sources can include: • Borrowers • Participants in the Mortgage transaction • Participants in the related real estate transactions • Servicing functions relating to a Mortgage or REO property • Loss mitigation activities or transactions, such as: ■ Forbearance plans ■ Loan modifications ■ Foreclosures ■ Deeds-in-lieu of foreclosure Freddie Mac Single-Family Seller/Servicer Guide Chapter 3201 As of 05/06/26 Page 3201-3 ■ Short sales of the underlying property ■ Investigate unusual patterns or discrepancies or other red flags, such as first and early- payment defaults ■ Comply with Section 3101.1 regarding screening through the Freddie Mac Exclusionary List ■ Comply with all other Guide provisions relating to fraud prevention and detection Red flags identified in origination and/or Servicing may include, but are not limited to: ■ Origination: ❑ Collateral, appraisal and property fraud (e.g., flipping, flopping, over or under valuation, property condition) ❑ Misrepresentations (e.g., assets, liabilities/debt, occupancy, strawbuyer, employment, income) ❑ Identity theft ❑ Irregularities in the loan application or Mortgage documentation (e.g., false documents, forgeries, excessive gift funds) ■ Servicing: ❑ Potentially suspicious payment activity (e.g., structured cash payments, payments returned due to fraud, curtailments or large payments with unknown source of funds, payment kiting) ❑ Loan modification and foreclosure fraud (e.g., loan modification rescue schemes, misrepresentation of eligibility requirements) ❑ Debt elimination schemes (e.g., false identity theft claims, sovereign citizen fraud) ❑ Potentially suspicious or fraudulent payoffs (e.g., early payoffs, potentially suspicious or fraudulent wires, diversion of funds) Seller/Servicers must know the parties with whom they do business. ■ Sellers must approve, evaluate and monitor Mortgage Brokers, Correspondents, Mortgage Service Providers, appraisers, and property data collectors ■ Servicers must approve, evaluate and monitor appraisers and any third party to whom Servicing functions relating to a Mortgage or REO property are outsourced or assigned, Freddie Mac Single-Family Seller/Servicer Guide Chapter 3201 As of 05/06/26 Page 3201-4 including, but not limited to, any loss mitigation activities or transactions such as foreclosures, deeds-in-lieu of foreclosure or short sales (c) Seller/Servicer’s in-house quality control program Pre- and post-funding quality control reviews are an integral part of fraud prevention and detection in the mortgage process. In the event populations of loans are identified that have a reason to suspect fraud, discretionary samples must be used to identify and report any additional instances of suspected fraud. Seller/Servicers must comply with all other Guide provisions relating to quality control reviews, including Section 3402.2(a). The Seller/Servicer must periodically (at least annually) update its quality control policies and procedures to address emerging fraud scenarios. (d) Additional fraud mitigation resources Information on preventing, detecting and investigating potential fraud and other suspicious activity is available on Freddie Mac’s website at https://sf.freddiemac.com/working-with- us/fraud-prevention/overview. For additional information, consult the Freddie Mac fraud hotline at 800-4FRAUD8 (800- 437-2838) or the Freddie Mac Exclusionary List, which is accessible via Freddie Mac Gateway®. 3201.2: Fraud and other Suspicious Activity reporting requirements (05/06/26) This section contains requirements related to: ■ Procedures for detecting, identifying and reporting fraud, suspected fraud and Suspicious Activity ■ Requirement to report fraud, suspected fraud and Suspicious Activity ■ Required reporting timelines ■ Use of the Tip Referral Tool ■ Fraud types and trends The Seller/Servicer must take measures to ensure that Mortgages sold to, or serviced for, Freddie Mac are free from any fraud, suspected fraud, Suspicious Activity, potential Suspicious Activity, Freddie Mac Single-Family Seller/Servicer Guide Chapter 3201 As of 05/06/26 Page 3201-5 misrepresentation, misstatement or omission, and the Seller/Servicer must report impacted Mortgage(s) in accordance with the requirements outlined in this section. Mortgages involving any misstatement, misrepresentation or omission by the Borrower or any other party in the Mortgage and/or real estate transaction are not eligible for sale to Freddie Mac. (a) Procedures for detecting, identifying and reporting fraud, suspected fraud and Suspicious Activity The Seller/Servicer must have a documented program with procedures for detecting, identifying and reporting fraud, suspected fraud and other Suspicious Activity in connection with a Mortgage sold to, or serviced for, Freddie Mac and discovered at any time, including, but not limited to, during origination, quality control reviews, Servicing activities or loss mitigation efforts. Before reporting to Freddie Mac, a Seller/Servicer must perform due diligence to establish whether there is a reasonable basis to believe that fraud, suspected fraud or Suspicious Activity may have occurred. (b) Requirement to report fraud, suspected fraud and Suspicious Activity The Seller/Servicer must report to Freddie Mac when the Seller/Servicer has a reasonable belief that one of the following is occurring or has occurred during the origination, sale or Servicing of a Mortgage (including, but not limited to, any loss mitigation activity) regardless of whether (i) it had an impact on the eligibility of the Mortgage for sale to Freddie Mac or (ii) there was a breach of the Guide: ■ Any misrepresentation, misstatement or omission related to the Mortgage, the Borrower, the Mortgaged Premises or underlying real estate transaction ■ Involvement of a person or entity on the Freddie Mac Exclusionary List is involved or was involved in the origination, sale or Servicing of the Mortgage or the underlying real estate transaction in violation of Section 3101.1. (Note: For reporting the discovery of any possible breach of warranties regarding the Exclusionary List, refer to instructions in Section 3101.1(c)(i).) ■ Involvement of a person or entity on the FHFA Suspended Counterparty Program list in the origination, sale or Servicing of the Mortgage or the related real estate transactions in violation of Section 3101.2 ■ Termination or denial of mortgage insurance based on fraud (c) Required reporting timelines Freddie Mac Single-Family Seller/Servicer Guide Chapter 3201 As of 05/06/26 Page 3201-6 The Seller/Servicer must report any reportable activity as defined in Section 3201.2(a) through Freddie Mac’s Tip Referral Tool, accessible via Freddie Mac Gateway, within the time frames outlined in the table below. Required reporting timelines Required time frame for reporting Discovery of reportable activity Within 30 days ■ Reportable activity discovered during a quality control review: The Seller/Servicer must notify Freddie Mac within 30 days after the date the quality control results are reported in writing to the Seller/Servicer’s Senior Management, in accordance with the reporting requirements in Section 3402.3(b) ■ Reportable activity discovered through any means other than a quality control review: The Seller/Servicer must notify Freddie Mac within 30 days after discovery Immediate (within one Business Day) In addition to the above 30-day reporting requirements, the Seller/Servicer must notify Freddie Mac within one Business Day after: ■ Becoming aware of theft of custodial funds, lack of collateral, non-remittance of pay-off funds or multiple deliveries of the same Mortgage ■ Determining there is a substantial likelihood that the fraud, suspected fraud or other Suspicious Activity will receive significant public exposure or publicity ■ Receiving notification of the entry of a civil judgment, guilty plea or criminal conviction indicating lack of integrity and relating to a participant in a Mortgage or the underlying real estate transaction or relating to a board member, officer, employee or contractor of the Seller/Servicer ■ Receiving notification from law enforcement or another governmental authority that such authority is conducting an investigation or prosecution of fraud relating to Mortgages owned by, or serviced for, Freddie Mac or relating to a board member, officer, employee or contractor of the Seller/Servicer ■ Identifying a possible fraud scheme or pattern of Suspicious Activity involving (i) more than five Mortgages sold to, or serviced for, Freddie Mac or (ii) Mortgages sold Freddie Mac Single-Family Seller/Servicer Guide Chapter 3201 As of 05/06/26 Page 3201-7 Required reporting timelines Required time frame for reporting Discovery of reportable activity to, or serviced for, Freddie Mac with an aggregate UPB of at least $1 million ■ Identifying actual or possible terrorist financing or ongoing or possible money laundering schemes or activity Seller/Servicers are not required to, and must not, disclose to Freddie Mac any Financial Crimes Enforcement Network Suspicious Activity Reports (SARs) or draft SARs, documents or information revealing the existence of a SAR or indicating whether a SAR has been filed, or where disclosure of Suspicious Activity would otherwise be prohibited by law. (d) Use of the Tip Referral Tool Seller/Servicers must report all Mortgage fraud, suspected Mortgage fraud and other Suspicious Activity using the Tip Referral Tool. Referrals made through the Tip Referral Tool must include: ■ Freddie Mac loan number ■ Property address ■ Mortgage fraud/Suspicious Activity type and category ■ Parties involved ■ Supporting documentation ■ A detailed narrative description of the activity, including why it has been deemed suspicious or fraudulent. (Seller/Servicers should not include protected personal information, such as Social Security numbers, in the narrative description.) ■ Any other required information as identified in the Tip Referral Tool (e) Fraud types and trends In connection with the Seller/Servicer’s fraud tracking procedures required in Section 3201.3(b), the Seller/Servicer must maintain and, upon request, provide Freddie Mac with aggregated records and reporting detailing fraud types and trends, including the number of fraud cases and positive Exclusionary List hits. Freddie Mac Single-Family Seller/Servicer Guide Chapter 3201 As of 05/06/26 Page 3201-8 3201.3: Fraud cooperation and additional requirements (12/17/25) This section contains requirements related to: ■ Fraud cooperation ■ Additional fraud (a) Fraud cooperation The Seller/Servicer must cooperate with Freddie Mac to prevent and investigate fraud and other Suspicious Activity. Cooperation includes making available to Freddie Mac individuals with relevant knowledge and providing to Freddie Mac and, when permitted by law, assisting Freddie Mac in obtaining all information, documentation and records requested by Freddie Mac relating to a Mortgage and related real estate transactions, including, but not limited to: ■ Closing or settlement agent files ■ Mortgage files ■ Borrower payment records ■ Reverifications of employment, income, occupancy and assets ■ Any internal or external communications The Seller/Servicer must provide all information requested by Freddie Mac within 14 days after receiving the request. (b) Additional fraud Seller/Servicers are reminded of their continuing obligation to comply with all applicable federal, State and local laws, including those relating to fraud and anti-money laundering (see Section 1301.2). Seller/Servicers must have in place written procedures for preventing, detecting and reporting fraud, and detecting and reporting Suspicious Activity, including the requirements of this chapter, and must make these procedures available to Freddie Mac upon request. Seller/Servicers must implement fraud risk management processes and controls, which may include screening software/tools and monitoring. Procedures must be in place to identify and track fraud trends, volume of potential fraud (such as number of fraud incidents and Exclusionary List hits) and Suspicious Activity and fraud alert review and resolution. Freddie Mac Single-Family Seller/Servicer Guide Chapter 3301 As of 12/17/25 Page 3301-1 Chapter 3301: Mortgage File Contents

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