FHLMC Single-Family Seller/Servicer Guide Chapter 4101 — The Mortgage Application

fhlmc-4101

FHLMC Single-Family Guide Chapter 4101 §4101.1 governs Mortgage Application requirements: mandatory use of Form 65 (Uniform Residential Loan Application / URLA), use of current Form 65 version as of application date, prohibition on altering field names/descriptions/order, Note-Date accuracy of final Form 65, legibility/signature/dating requirements for final Form 65, and written-statement requirement for any material discrepancy between application and credit-report/file-verification data.

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source:
  type: regulation
  id: fhlmc-4101
  authority: FHLMC Single-Family Seller/Servicer Guide Chapter 4101 — The Mortgage Application
  description: |
    FHLMC Single-Family Guide Chapter 4101 §4101.1 governs Mortgage
    Application requirements: mandatory use of Form 65 (Uniform
    Residential Loan Application / URLA), use of current Form 65
    version as of application date, prohibition on altering field
    names/descriptions/order, Note-Date accuracy of final Form 65,
    legibility/signature/dating requirements for final Form 65, and
    written-statement requirement for any material discrepancy
    between application and credit-report/file-verification data.
obligations:
  - id: fhlmc-4101-form-65-mandatory-for-all-applications
    canonical_id: fhlmc-4101-form-65-mandatory-for-all-applications
    section: FHLMC Single-Family Guide §4101.1(a) — Form 65 must be used for all Mortgage applications
    description: |
      [LENDER] (Seller) shall use Form 65 (Uniform Residential Loan
      Application / URLA) for all Mortgage applications. Substitute
      forms or proprietary applications without Form 65 components
      may not be used. Form 65 mandatoriness is the foundation of FHLMC
      data-quality and AUS-eligibility.
    type: do
    audit_question: For every Mortgage delivered to FHLMC, can [LENDER] evidence that Form 65 (URLA) was used as the loan application — and not a substitute proprietary form?
    program_review: Does the program ensure Form 65 (URLA) is used for every Mortgage application and no substitute proprietary application is accepted?
    file_review: Pull files; confirm Form 65 was the application of record.
    judgment: false
    feeds: []
    workflow_phase: loan_origination
    owner_role: loan_originator
    secondary_owner_role: chief_credit_officer
    cadence: per-loan
    consequence: Non-Form-65 application is a Selling Guide breach; risk of FHLMC repurchase request.
    tags:
      - round-d
      - regulator-direct
      - fhlmc
      - selling-guide
      - form-65
      - urla
      - application
      - promoted
    primary_source:
      tier: 1
      authority: FHLMC Single-Family Guide §4101.1(a) — Required use of Form 65
      source_class: fhlmc-guide
      source_url: https://guide.freddiemac.com/app/guide/
      snapshot_id: fbba421721d90cb1
      fetched_at: '2026-05-25T14:09:48Z'
      content_hash: sha256:placeholder-snapshot-content-hash-from-source-json
      paragraph_quote: |
        Form 65 must be used for all Mortgage applications.
      drafter_attestation: |
        Copied verbatim from snapshot fbba421721d90cb1. §4101.1(a)
        Form-65-mandatory operative requirement.
    auditor_minimum_evidence:
      derivation: snapshot_extract
      derivation_source:
        snapshot_id: fbba421721d90cb1
        paragraph_quote: Form 65 must be used for all Mortgage applications.
        page_or_section: FHLMC Single-Family Guide §4101.1(a)
        fetched_at: '2026-05-25T14:09:48Z'
      pathway_selection_kind: mutually_exclusive_by_facts
      pathways:
        - pathway_id: csh-amep-fhlmc-4101-form-65-used
          name: Form 65 used for every FHLMC-delivered Mortgage application
          evidence_items:
            - evidence_id: csh-ev-fhlmc-4101-form-65-archive
              kind: document
              description: Per-loan Form 65 archive (initial + final versions) demonstrating Form 65 was the application form used.
              retention_rule_ref: reg-z-1026.25
              examiner_question_ref: FHLMC Servicer Review §4101.a
              cite_verified: false
            - evidence_id: csh-ev-fhlmc-4101-application-system-attestation
              kind: third_party_attestation
              description: LOS-vendor attestation that the application form generated for residential mortgage applications is the current FHLMC-approved Form 65 (URLA) version.
              retention_rule_ref: reg-z-1026.25
              examiner_question_ref: FHLMC Servicer Review §4101.b
              cite_verified: false
      pathway_selection_logic: |
        Single pathway — Form 65 is mandatory for FHLMC; no alternative pathway. Both per-loan archive AND institutional LOS attestation are required (one-loan failure could be slipped-through; one-vendor failure could be systemic).
    promoted_at: '2026-05-25T19:38:10+00:00'
    promoted_from: fhlmc-4101-roundd-v1.yaml
  - id: fhlmc-4101-use-current-version-of-form-65
    canonical_id: fhlmc-4101-use-current-version-of-form-65
    section: FHLMC Single-Family Guide §4101.1(a) — Use current Form 65 version as of loan application date
    description: |
      [LENDER] (Seller) shall use the version of Form 65 that is
      current as of the loan application date. (See Exhibit 4A, Single-
      Family Uniform Instruments.) Using a stale Form 65 version is a
      Selling Guide breach and may surface in postfunding QC review.
    type: do
    audit_question: For every Mortgage application, can [LENDER] evidence (via application-date-version map or Exhibit 4A version lookup) that the Form 65 version used was current as of the application date?
    program_review: Does the program ensure the Form 65 version used is current as of the application date (Exhibit 4A version map)?
    file_review: Confirm the Form 65 version against the application date via the Exhibit 4A version lookup.
    judgment: false
    feeds: []
    workflow_phase: loan_origination
    owner_role: loan_originator
    secondary_owner_role: quality_control_manager
    cadence: per-loan
    consequence: Stale Form 65 version is a Selling Guide breach; postfunding QC defect.
    tags:
      - round-d
      - regulator-direct
      - fhlmc
      - selling-guide
      - form-65
      - version-currency
      - promoted
    primary_source:
      tier: 1
      authority: FHLMC Single-Family Guide §4101.1(a) — Required use of Form 65
      source_class: fhlmc-guide
      source_url: https://guide.freddiemac.com/app/guide/
      snapshot_id: fbba421721d90cb1
      fetched_at: '2026-05-25T14:09:48Z'
      content_hash: sha256:placeholder-snapshot-content-hash-from-source-json
      paragraph_quote: |
        The Seller is required to use the version of Form 65 that is current as of the loan application date.
      drafter_attestation: |
        Copied verbatim from snapshot fbba421721d90cb1. §4101.1(a)
        current-Form-65-version operative requirement.
    promoted_at: '2026-05-25T19:38:10+00:00'
    promoted_from: fhlmc-4101-roundd-v1.yaml
  - id: fhlmc-4101-no-alteration-of-field-names-or-order
    canonical_id: fhlmc-4101-no-alteration-of-field-names-or-order
    section: FHLMC Single-Family Guide §4101.1(a) — Field names/descriptions/order may not be altered
    description: |
      [LENDER] (Seller) may make changes to the style and formatting of
      Form 65 and its components per the UMDP Rendering Options;
      HOWEVER, the field names, descriptions and order of sections may
      NOT be altered in any way. Form fields within a section may be
      moved within that section if additional field length is needed.
      Any adjustments made to the format of the form must be made
      pursuant to all applicable law.
    type: refrain
    audit_question: If [LENDER] uses a customized Form 65 layout, can [LENDER] evidence that customizations were limited to UMDP-allowed style/formatting AND that no field names, descriptions, or section order were altered?
    program_review: Does the program confine any Form 65 customization to UMDP-allowed style/formatting and prohibit altering field names, descriptions, or section order?
    file_review: Where a customized layout is used, review it against UMDP rendering options; confirm no field name, description, or section order was altered.
    judgment: false
    feeds: []
    workflow_phase: loan_origination
    owner_role: chief_credit_officer
    secondary_owner_role: compliance_officer
    cadence: per-form-version-change
    consequence: Altered field names/descriptions/order breaks UAD/MISMO data conformance; Selling Guide breach.
    tags:
      - round-d
      - regulator-direct
      - fhlmc
      - selling-guide
      - form-65
      - no-alteration
      - umdp
      - promoted
    primary_source:
      tier: 1
      authority: FHLMC Single-Family Guide §4101.1(a) — Required use of Form 65
      source_class: fhlmc-guide
      source_url: https://guide.freddiemac.com/app/guide/
      snapshot_id: fbba421721d90cb1
      fetched_at: '2026-05-25T14:09:48Z'
      content_hash: sha256:placeholder-snapshot-content-hash-from-source-json
      paragraph_quote: |
        the fields names, descriptions and order of sections may not be altered in any way.
      drafter_attestation: |
        Copied verbatim from snapshot fbba421721d90cb1. §4101.1(a)
        no-alteration-of-fields operative restriction. The within-
        section field-moves carve-out paraphrased in description.
    promoted_at: '2026-05-25T19:38:10+00:00'
    promoted_from: fhlmc-4101-roundd-v1.yaml
  - id: fhlmc-4101-final-form-65-accurate-as-of-note-date
    canonical_id: fhlmc-4101-final-form-65-accurate-as-of-note-date
    section: FHLMC Single-Family Guide §4101.1(b) — Final Form 65 accurate and complete as of Note Date
    description: |
      [LENDER] (Seller) shall ensure the final Form 65 reflects
      accurate and complete information as of the Note Date. All of the
      Borrower's debts incurred through the Note Date must be included
      on the final Form 65 and must be considered in the calculation of
      the Borrower's monthly debt payment-to-income ratio. The final
      Form 65 must be complete, legible, dated and signed by the
      Borrowers signing the Note.
    type: do
    audit_question: For every Mortgage, can [LENDER] evidence (a) final Form 65 accuracy/completeness as of Note Date, (b) all Note-Date debts included on final Form 65, (c) DTI calculation reflects all included debts, (d) final Form 65 is signed/dated by all Borrowers signing the Note?
    program_review: Do the P&Ps ensure the final Form 65 is accurate/complete as of the Note Date, that all Note-Date debts are included and reflected in the DTI calculation, and that it is complete, legible, dated and signed by every Borrower signing the Note?
    file_review: Pull final Form 65s; confirm Note-Date accuracy, all debts included and carried into DTI, and signatures/dates of all Note signers.
    judgment: false
    feeds: []
    workflow_phase: loan_origination
    owner_role: underwriting_manager
    secondary_owner_role: loan_originator
    cadence: per-loan
    consequence: Inaccurate or stale final Form 65 (missed Note-Date debts) is a Selling Guide breach + R&W exposure.
    tags:
      - round-d
      - regulator-direct
      - fhlmc
      - selling-guide
      - form-65
      - note-date-accuracy
      - dti
      - promoted
    primary_source:
      tier: 1
      authority: FHLMC Single-Family Guide §4101.1(b) — Completion instructions
      source_class: fhlmc-guide
      source_url: https://guide.freddiemac.com/app/guide/
      snapshot_id: fbba421721d90cb1
      fetched_at: '2026-05-25T14:09:48Z'
      content_hash: sha256:placeholder-snapshot-content-hash-from-source-json
      paragraph_quote: |
        The final Form 65 must reflect accurate and complete information as of the Note Date.
      drafter_attestation: |
        Copied verbatim from snapshot fbba421721d90cb1. §4101.1(b)
        final-Form-65-Note-Date-accuracy operative requirement. DTI
        inclusion, completeness, legibility, signature/dating tail
        paraphrased in description.
    promoted_at: '2026-05-25T19:38:11+00:00'
    promoted_from: fhlmc-4101-roundd-v1.yaml
  - id: fhlmc-4101-written-statement-for-material-discrepancy
    canonical_id: fhlmc-4101-written-statement-for-material-discrepancy
    section: FHLMC Single-Family Guide §4101.1(b) — Written statement required for material application-vs-verification discrepancy
    description: |
      [LENDER] (Seller) shall, for any Mortgage in which there is a
      material discrepancy between the information given by the
      Borrowers on the application and (a) the identifying information
      in the credit reports OR (b) the verifications in the Mortgage
      file, prepare a WRITTEN statement explaining the discrepancy.
      The written-explanation record protects the file from being
      flagged as inconsistent in postfunding QC.
    type: do
    audit_question: For every Mortgage with any material discrepancy between application data and credit-report or file-verification data, can [LENDER] produce a written statement (in the Mortgage file) explaining the discrepancy?
    program_review: Does the program ensure that any material discrepancy between application data and credit-report identifying info or file verifications produces a written explanatory statement in the file?
    file_review: Review files with discrepancies for the written statement; the compliance person judges whether a discrepancy was material and whether the explanation is sufficient.
    judgment: true
    feeds: []
    workflow_phase: loan_origination
    owner_role: underwriting_manager
    secondary_owner_role: quality_control_manager
    cadence: per-discrepancy
    consequence: Missing written discrepancy explanation creates unexplained-inconsistency QC defect; potential fraud-screen escalation.
    tags:
      - round-d
      - regulator-direct
      - fhlmc
      - selling-guide
      - form-65
      - material-discrepancy
      - written-explanation
      - promoted
    primary_source:
      tier: 1
      authority: FHLMC Single-Family Guide §4101.1(b) — Completion instructions
      source_class: fhlmc-guide
      source_url: https://guide.freddiemac.com/app/guide/
      snapshot_id: fbba421721d90cb1
      fetched_at: '2026-05-25T14:09:48Z'
      content_hash: sha256:placeholder-snapshot-content-hash-from-source-json
      paragraph_quote: |
        For any Mortgage in which there is a material discrepancy, the Seller must prepare a written statement explaining the discrepancy.
      drafter_attestation: |
        Copied verbatim from snapshot fbba421721d90cb1. §4101.1(b)
        material-discrepancy-written-statement operative requirement.
    promoted_at: '2026-05-25T19:38:11+00:00'
    promoted_from: fhlmc-4101-roundd-v1.yaml
_promotion_history:
  - promoted_at: '2026-05-25T19:38:11+00:00'
    candidate_path: obligations\_remediation\round-d-investor-guides\fhlmc-4101-roundd-v1.yaml
    candidates_promoted: 5
    candidates_skipped_existing: 0

Verbatim regulatory text (5)

Verbatim provisions from FHLMC Single-Family Seller/Servicer Guide Chapter 4101 — The Mortgage Application — each quote is a verified substring of the regulator-published source snapshot, not retyped. Quoted for reference; this is not legal advice. The operational layer (P&P updates, prompts) lives in the regulation update kits.

FHLMC Single-Family Guide §4101.1(a) — Form 65 must be used for all Mortgage applications

Form 65 must be used for all Mortgage applications.

Source: FHLMC Single-Family Guide §4101.1(a) — Required use of Form 65 · source URL · snapshot fbba421721d90cb1

FHLMC Single-Family Guide §4101.1(a) — Use current Form 65 version as of loan application date

The Seller is required to use the version of Form 65 that is current as of the loan application date.

Source: FHLMC Single-Family Guide §4101.1(a) — Required use of Form 65 · source URL · snapshot fbba421721d90cb1

FHLMC Single-Family Guide §4101.1(a) — Field names/descriptions/order may not be altered

the fields names, descriptions and order of sections may not be altered in any way.

Source: FHLMC Single-Family Guide §4101.1(a) — Required use of Form 65 · source URL · snapshot fbba421721d90cb1

FHLMC Single-Family Guide §4101.1(b) — Final Form 65 accurate and complete as of Note Date

The final Form 65 must reflect accurate and complete information as of the Note Date.

Source: FHLMC Single-Family Guide §4101.1(b) — Completion instructions · source URL · snapshot fbba421721d90cb1

FHLMC Single-Family Guide §4101.1(b) — Written statement required for material application-vs-verification discrepancy

For any Mortgage in which there is a material discrepancy, the Seller must prepare a written statement explaining the discrepancy.

Source: FHLMC Single-Family Guide §4101.1(b) — Completion instructions · source URL · snapshot fbba421721d90cb1