Freddie Mac Single-Family Seller/Servicer Guide 8303.5 — Noncompliance with reporting standards and compensatory fees

This section contains information related to: ■ Noncompliance with reporting and drafting requirements ■ Drafting noncompliance compensatory fees ■ Reporting noncompliance compensatory fees ■ EDR noncompliance compensatory fees ■ Unreported transactions and loan simulation compensatory fee ■ Aged data errors compensatory fee ■ Next month late reported payoff noncompliance compensatory fee ■ Draft delay compensatory fee ■ Contract noncompliance and contract change compensatory fee

(a) Noncompliance with reporting and drafting requirements The Servicer’s failure to comply with Freddie Mac’s requirements for reporting and drafting constitutes a violation of the Purchase Documents and the contractual obligations of the Guide. In addition to any other remedies Freddie Mac may have at law or in equity, the Servicer is subject to the assessment of compensatory fees for any violations. Freddie Mac will charge the Servicer a noncompliance compensatory fee for the Servicer’s failure to comply with Freddie Mac’s Servicing reporting requirements contained in Section 8106.1 or the accounting reporting time requirements contained in this chapter. Servicing reporting and accounting reporting noncompliance compensatory fees are each monitored and assessed separately. The Servicer will receive written notification of all compensatory and other fee assessments. Freddie Mac reserves the right to revise Freddie Mac’s compensatory and other fee schedules and change Freddie Mac’s methods of calculating compensatory and other fees at any time at Freddie Mac’s sole discretion. The Servicer may direct any questions regarding the assessment of accounting reporting compensatory and other fees to Freddie Mac (see Directory 7). See Section 8303.5(b) for instructions on remitting compensatory fees. The Servicer must complete, execute and submit to Freddie Mac Form 1132, Authorization for Automatic Transfer of Funds Through the Automated Clearing House (ACH) for Seller/Servicers, as an Electronic Record (as defined in Section 1401.1(b)), using a Portable Document Format (PDF) (or other Electronic Record format commonly used in the mortgage industry), that has been completed and contains the copy or representation of the pen and ink signature of the Servicer’s Authorized Employee (such copy or representation of the Authorized Employee’s signature shall be such Authorized Employee’s adopted Electronic Signature as defined in Section 1401.1(b)) and either: ■ Attach to an e-mail and deliver to Freddie Mac at [email protected]; or ■ Upload through the Freddie Mac eBilling system Freddie Mac and the Servicer agree that the delivery of Electronic Records with Electronic Signatures are eligible Electronic Transactions (as defined in Section 1401.1(b)) and are governed by the applicable provisions of Chapter 1401. The employee authorized to execute Form 1132 on the Servicer’s behalf must be designated as an “Authorized Employee” on the Servicer’s Form 988SF, Certificate of Incumbency for a Bank, Savings Bank, Savings and Loan Association, Credit Union, Corporation or Limited Liability Company, or Form 989SF, Certificate of Incumbency for Limited Partnerships, as applicable. The account identified in Form 1132 for the payment of fees must be a Demand Deposit Account that is separate from any Custodial Account required to be maintained pursuant to any of the Purchase Documents. The Servicer agrees to notify Freddie Mac immediately at [email protected] of any changes to the status of the Servicer’s ACH account.

(b) Drafting noncompliance compensatory fees Freddie Mac will initiate an ACH draft to collect any compensatory fees billed on the Performing Loans monthly Servicing Billing Statement and the Non-Performing Loans Invoice. To authorize ACH drafting of compensatory fees, the Servicer must: 1. Submit a completed, executed and duly authorized Form 1132 no later than 15 Business Days before the last Business Day of the first month in which the Servicer is liable to pay Freddie Mac any compensatory fees, to set up or make certain changes to the draft account. This form will authorize Freddie Mac to initiate an ACH draft and designates an account from which Freddie Mac will collect any compensatory and other fees for which Freddie Mac may bill the Servicer on the Performing Loans monthly Servicer Billing Statement and the Non-Performing Loans Invoice. 2. Designate an account other than one of Freddie Mac’s Custodial Accounts from which Freddie Mac will draft the amount due; and 3. Deliver Form 1132 to Freddie Mac as an Electronic Record (as defined in Section 1401.1(b)), using a Portable Document Format (PDF) (or other Electronic Record format commonly used in the mortgage industry), that has been completed and contains the copy or representation of the pen and ink signature of the Servicer’s Authorized Employee (such copy or representation of the Authorized Employee’s signature shall be such Authorized Employee’s adopted Electronic Signature as defined in Section 1401.1(b)) and either: ■ Attach to an e-mail and deliver to Freddie Mac at the following e-mail address: [email protected]; or ■ Upload through the Freddie Mac eBilling system ■ Freddie Mac and the Servicer agree that the delivery of Electronic Records with Electronic Signatures are eligible Electronic Transactions and are governed by the applicable provisions of Chapter 1401 The employee authorized to execute Form 1132 on the Servicer’s behalf must be designated as an “Authorized Employee” on the Servicer’s Form 988SF or Form 989SF, as applicable. Servicers may establish one ACH account for the payment of invoices for both the Performing Loans monthly Servicer Billing Statement and the Servicer Non-Performing Loans Invoice or establish two separate accounts. Servicers may submit billing inquires or billing-related requests to [email protected]. Note: See Section 9102.1 concerning Non-Performing Loans remittances. Note: See Sections 7101.1(b), 8303.5(a), 8303.5(c) through 8303.5(i) and 9603.3(f) for information on these compensatory fees.

(c) Reporting noncompliance compensatory fees Freddie Mac assesses a compensatory fee when the Servicer fails to comply with Freddie Mac’s Servicing reporting requirements for the reports listed in Section 8106.1 or with Freddie Mac’s reporting requirements contained in this chapter and Section 9102.6. If the Servicer commits more than one type of reporting offense within any consecutive 12month period, the Servicer may be subject to more than one reporting noncompliance fee. The Servicer will be subject to the applicable compensatory fee in accordance with Section 8303.5(d) for its failure to: 1. Submit complete and accurate Servicing reports, including the submission of error-free loan-level data within the required time frame 2. Report mandated data elements, such as the Last Payment Received Date (LPRD) or other fields as listed in Exhibit 60, Loan-Level Reporting Data Description 3. Provide information requested by Freddie Mac that is outside of the regular monthly reporting requirements of this chapter, or its failure to provide such requested information in a usable form within the required time frame Freddie Mac will notify the Servicer in writing of all instances of noncompliance.

(d) EDR noncompliance compensatory fees Freddie Mac assesses a compensatory fee when a Servicer fails to report applicable delinquent Mortgage information through EDR, within the first three Business Days of a month in accordance with Section 9102.6. The compensatory fees are based on the number of noncompliance violations the Servicer commits in any consecutive 12-month period starting with the month in which the first violation occurred and as shown below: EDR noncompliance compensatory fee based on the number of violations IF the noncompliance violation within a consecutive 12-month period is the Servicer’s... THEN the reporting noncompliance compensatory fee is... AND the Servicer... First violation Greater of $250 or $50 per loan, up to $5,000 Second violation Greater of $500 or $50 per loan, up to $10,000 May be required to attend a reporting training seminar at the Servicer’s expense Third violation or more Greater of $1,000 or $50 per loan, up to $15,000 In addition to the monetary compensatory fees, beginning with the second violation, Freddie Mac may require the Servicer to attend reporting training at the Servicer’s expense. Freddie Mac reserves the right to invoke additional remedies, including suspension or disqualification as a Seller/Servicer or a full or partial termination of Servicing, in the event of continuing violations. Freddie Mac will bill the Servicer for such fees on the Servicer Non-Performing Loans Invoice. Refer to Section 9102.1 for information on the payment of Servicing Non-Performing Loans Invoices via an ACH draft.

(e) Unreported transactions and loan simulation compensatory fee Freddie Mac assesses a compensatory fee of $100 per loan when a Servicer fails to clear outstanding edits or report loan-level activity by the end of the Accounting Cycle.

(f) Aged data errors compensatory fee Freddie Mac may assess a $100 compensatory fee per loan, per occurrence, up to a maximum of $15,000 per month in which there are unresolved loan-level reporting errors that appear on the Loan Reconciliation Difference Report 90 days or more category. Freddie Mac will submit an ACH draft transaction for all data error compensatory fees the Servicer owes Freddie Mac on the last Business Day of the month in which the Servicer received the Performing Loans monthly Servicer Billing Statement from Freddie Mac stating the amount of the compensatory fees. Note: Refer to Section 8303.5(b) for information on establishing the ACH draft.

(g) Next month late reported payoff noncompliance compensatory fee Freddie Mac assesses this compensatory fee when the Servicer fails to report a paid off Mortgage by the second Business Day of the month following the month in which the Servicer receives the funds. This compensatory fee is equal to one month’s interest based on the net yield for each loan that the Servicer reports late. Freddie Mac may assess this compensatory fee in addition to other fees contained in this chapter. Freddie Mac may assess a late reported payoff compensatory fee if the Servicer fails to report the payoff of a matured Mortgage in accordance with Section 8301.4(g). Freddie Mac will submit an ACH transaction for all late reported payoff noncompliance compensatory fees the Servicer owes Freddie Mac on the last Business Day of the month in which the Servicer received the Performing Loans monthly Servicer Billing Statement from Freddie Mac indicating the amount of the compensatory fee. Refer to Section 8303.5(b) for information on establishing the ACH draft.

(h) Draft delay compensatory fee

(i) Compensatory fee with respect to payoff reporting With respect to payoffs, Freddie Mac assesses this compensatory fee when the Servicer fails to report a payoff within two Business Days of the Payoff Date and the late report results in a delayed Payoff Draft Date. Note: If the Servicer fails to report a paid-off Mortgage by the second Business Day of the month following the month in which the Servicer receives the funds, then the compensatory fee is determined as provided in Section 8303.5(g) rather than this Section 8303.5(i). (ii) Compensatory fee calculation method Freddie Mac calculates this compensatory fee by the amount of the payoff funds, multiplied by the number of calendar days the payoff draft was late as a result of the late reported payoff, multiplied by the highest quoted prime rate on the last Business Day of the month in which the late payoff draft occurred in the print edition of The Wall Street Journal in its regular column entitled “Money Rates” plus 3% divided by 365. If the prime rate is not published, then Freddie Mac will determine a comparable rate. (iii) Compensatory fee with respect to principal and interest or payoffs With respect to principal and interest or payoffs, Freddie Mac assesses this compensatory fee when the Servicer fails to have sufficient funds available for Freddie Mac to draft on the P&I Draft Date or on the Payoff Draft Date, as applicable. Freddie Mac calculates this compensatory fee by the amount of the principal and interest, or payoff, as applicable, multiplied by the number of calendar days the draft of principal and interest, or payoff, was late as a result of the failure of the Servicer to have sufficient funds available, multiplied by the highest quoted prime rate on the last Business Day of the month in which the draft failure occurred in the print edition of The Wall Street Journal in its regular column entitled “Money Rates” plus 3% divided by 365. If the prime rate is not published, then Freddie Mac will determine a comparable rate. The minimum monthly compensatory fee will be based on the number of noncompliance violations the Servicer commits in any consecutive 12-month period starting with the month in which the first violation occurred and as shown below: Minimum monthly compensatory fee IF the noncompliance violation within a consecutive 12-month period is the Servicer’s... THEN the draft delay compensatory fee will be... First instance No less than $250 in any given month Second instance No less than $500 in any given month Third instance or more in 12 months No less than $1,000 in any given month Freddie Mac will submit an ACH draft transaction for all cash remittance interest reimbursement compensatory fees the Servicer owes Freddie Mac on the last Business Day of the month in which the Servicer receives the Performing Loans monthly Servicer Billing Statement stating the amount of the compensatory fee. Refer to Section 8303.5(b) for information on establishing the ACH draft. Note: See Section 9603.3(f) for the compensatory fee assessed for late execution of a repurchase request for an REO. (i) Contract noncompliance and contract change compensatory fee Except as set forth in Section 6303.1(c), Freddie Mac may assess a contract noncompliance and contract change compensatory fee based on the circumstances listed below. (i) Purchase/funding corrections – post-fund data corrections (PFDCs) When a Seller or Servicer submits a PFDC more than 60 days after the close of the Accounting Cycle in which the loan was funded (purchased), Freddie Mac will assess a compensatory fee of $500 per Mortgage when Freddie Mac processes the database correction necessary to complete an approved PFDC request and the associated cash transaction. (ii) Servicing data corrections (SDC) (A) Postsettlement correction (loss mitigation workouts) In the case of Mortgage modification, when a Servicer submits a postsettlement data correction request more than 60 days after the settlement of the loss mitigation workout, Freddie Mac will assess a compensatory fee of $500 per Mortgage when Freddie Mac processes a database correction required to correct the loan-level data discrepancy and the associated cash transaction. (B) Loan-level reporting correction When a Servicer submits a loan-level reporting correction more than 60 days after the close of the Accounting Cycle in which the initial edit or data discrepancy occurred, Freddie Mac will assess a compensatory fee of $500 per Mortgage when Freddie Mac processes a database correction required to correct the loan-level data discrepancy and the associated cash transaction. (iii) Drafting compensatory fees Freddie Mac will submit an ACH draft transaction for all contract noncompliance and contract change compensatory fees on the last Business Day of the month in which the Servicer received the Performing Loans monthly Servicer Billing Statement and/or the Non-Performing Loans Monthly Servicer Invoice. Note: See Section 8303.5(b) for information on establishing the ACH draft.

Refer to Bulletins 2026-G and 2026-11, which announced updates related to Freddie Mac’s new event-based default related reporting requirements. Beginning November 16, 2026, Servicers may implement the new requirements if they are operationally ready to do so. If a Servicer adopts the new event-based default related reporting standards before the mandatory effective date of September 27, 2027, it must comply with the associated Guide requirements that will be effective on September 27, 2027 and, upon such adoption, must discontinue monthly EDR reporting. This section contains information related to: ■ Noncompliance with reporting and drafting requirements ■ Drafting noncompliance compensatory fees ■ Reporting noncompliance compensatory fees ■ EDR noncompliance compensatory fees ■ Unreported transactions and loan simulation compensatory fee ■ Aged data errors compensatory fee ■ Next month late reported payoff noncompliance compensatory fee ■ Draft delay compensatory fee ■ Contract noncompliance and contract change compensatory fee

(a) Noncompliance with reporting and drafting requirements The Servicer’s failure to comply with Freddie Mac’s requirements for reporting and drafting constitutes a violation of the Purchase Documents and the contractual obligations of the Guide. In addition to any other remedies Freddie Mac may have at law or in equity, the Servicer is subject to the assessment of compensatory fees for any violations. Freddie Mac will charge the Servicer a noncompliance compensatory fee for the Servicer’s failure to comply with Freddie Mac’s Servicing reporting requirements contained in Section 8106.1 or the accounting reporting time requirements contained in this chapter. Servicing reporting and accounting reporting noncompliance compensatory fees are each monitored and assessed separately. The Servicer will receive written notification of all compensatory and other fee assessments. Freddie Mac reserves the right to revise Freddie Mac’s compensatory and other fee schedules and change Freddie Mac’s methods of calculating compensatory and other fees at any time at Freddie Mac’s sole discretion. The Servicer may direct any questions regarding the assessment of accounting reporting compensatory and other fees to Freddie Mac (see Directory 7). See Section 8303.5(b) for instructions on remitting compensatory fees. The Servicer must complete, execute and submit to Freddie Mac Form 1132, Authorization for Automatic Transfer of Funds Through the Automated Clearing House (ACH) for Seller/Servicers, as an Electronic Record (as defined in Section 1401.1(b)), using a Portable Document Format (PDF) (or other Electronic Record format commonly used in the mortgage industry), that has been completed and contains the copy or representation of the pen and ink signature of the Servicer’s Authorized Employee (such copy or representation of the Authorized Employee’s signature shall be such Authorized Employee’s adopted Electronic Signature as defined in Section 1401.1(b)) and either: ■ Attach to an e-mail and deliver to Freddie Mac at [email protected]; or ■ Upload through the Freddie Mac eBilling system Freddie Mac and the Servicer agree that the delivery of Electronic Records with Electronic Signatures are eligible Electronic Transactions (as defined in Section 1401.1(b)) and are governed by the applicable provisions of Chapter 1401. The employee authorized to execute Form 1132 on the Servicer’s behalf must be designated as an “Authorized Employee” on the Servicer’s Form 988SF, Certificate of Incumbency for a Bank, Savings Bank, Savings and Loan Association, Credit Union, Corporation or Limited Liability Company, or Form 989SF, Certificate of Incumbency for Limited Partnerships, as applicable. The account identified in Form 1132 for the payment of fees must be a Demand Deposit Account that is separate from any Custodial Account required to be maintained pursuant to any of the Purchase Documents. The Servicer agrees to notify Freddie Mac immediately at [email protected] of any changes to the status of the Servicer’s ACH account.

(b) Drafting noncompliance compensatory fees Freddie Mac will initiate an ACH draft to collect any compensatory fees billed on the Performing Loans monthly Servicing Billing Statement and the Non-Performing Loans Invoice. To authorize ACH drafting of compensatory fees, the Servicer must: 1. Submit a completed, executed and duly authorized Form 1132 no later than 15 Business Days before the last Business Day of the first month in which the Servicer is liable to pay Freddie Mac any compensatory fees, to set up or make certain changes to the draft account. This form will authorize Freddie Mac to initiate an ACH draft and designates an account from which Freddie Mac will collect any compensatory and other fees for which Freddie Mac may bill the Servicer on the Performing Loans monthly Servicer Billing Statement and the Non-Performing Loans Invoice. 2. Designate an account other than one of Freddie Mac’s Custodial Accounts from which Freddie Mac will draft the amount due; and 3. Deliver Form 1132 to Freddie Mac as an Electronic Record (as defined in Section 1401.1(b)), using a Portable Document Format (PDF) (or other Electronic Record format commonly used in the mortgage industry), that has been completed and contains the copy or representation of the pen and ink signature of the Servicer’s Authorized Employee (such copy or representation of the Authorized Employee’s signature shall be such Authorized Employee’s adopted Electronic Signature as defined in Section 1401.1(b)) and either: ■ Attach to an e-mail and deliver to Freddie Mac at the following e-mail address: [email protected]; or ■ Upload through the Freddie Mac eBilling system ■ Freddie Mac and the Servicer agree that the delivery of Electronic Records with Electronic Signatures are eligible Electronic Transactions and are governed by the applicable provisions of Chapter 1401 The employee authorized to execute Form 1132 on the Servicer’s behalf must be designated as an “Authorized Employee” on the Servicer’s Form 988SF or Form 989SF, as applicable. Servicers may establish one ACH account for the payment of invoices for both the Performing Loans monthly Servicer Billing Statement and the Servicer Non-Performing Loans Invoice or establish two separate accounts. Servicers may submit billing inquires or billing-related requests to [email protected]. Note: See Section 9102.1 concerning Non-Performing Loans remittances. Note: See Sections 7101.1(b), 8303.5(a), 8303.5(c) through 8303.5(i) and 9603.3(f) for information on these compensatory fees.

(c) Reporting noncompliance compensatory fees Freddie Mac assesses a compensatory fee when the Servicer fails to comply with Freddie Mac’s Servicing reporting requirements for the reports listed in Section 8106.1 or with Freddie Mac’s reporting requirements contained in this chapter and Section 9102.6. If the Servicer commits more than one type of reporting offense within any consecutive 12month period, the Servicer may be subject to more than one reporting noncompliance fee. The Servicer will be subject to the applicable compensatory fee in accordance with Section 8303.5(d) for its failure to: 1. Submit complete and accurate Servicing reports, including the submission of error-free loan-level data within the required time frame 2. Report mandated data elements, such as the Last Payment Received Date (LPRD) or other fields as listed in Exhibit 60, Loan-Level Reporting Data Description 3. Provide information requested by Freddie Mac that is outside of the regular monthly reporting requirements of this chapter, or its failure to provide such requested information in a usable form within the required time frame Freddie Mac will notify the Servicer in writing of all instances of noncompliance.

(d) EDR noncompliance compensatory fees Freddie Mac assesses a compensatory fee when a Servicer fails to report applicable delinquent Mortgage information through EDR, within the first three Business Days of a month in accordance with Section 9102.6. The compensatory fees are based on the number of noncompliance violations the Servicer commits in any consecutive 12-month period starting with the month in which the first violation occurred and as shown below: EDR noncompliance compensatory fee based on the number of violations IF the noncompliance violation within a consecutive 12-month period is the Servicer’s... THEN the reporting noncompliance compensatory fee is... AND the Servicer... First violation Greater of $250 or $50 per loan, up to $5,000 Second violation Greater of $500 or $50 per loan, up to $10,000 May be required to attend a reporting training seminar at the Servicer’s expense Third violation or more Greater of $1,000 or $50 per loan, up to $15,000 In addition to the monetary compensatory fees, beginning with the second violation, Freddie Mac may require the Servicer to attend reporting training at the Servicer’s expense. Freddie Mac reserves the right to invoke additional remedies, including suspension or disqualification as a Seller/Servicer or a full or partial termination of Servicing, in the event of continuing violations. Freddie Mac will bill the Servicer for such fees on the Servicer Non-Performing Loans Invoice. Refer to Section 9102.1 for information on the payment of Servicing Non-Performing Loans Invoices via an ACH draft.

(e) Unreported transactions and loan simulation compensatory fee Freddie Mac assesses a compensatory fee of $100 per loan when a Servicer fails to clear outstanding edits or report loan-level activity by the end of the Accounting Cycle.

(f) Aged data errors compensatory fee Freddie Mac may assess a $100 compensatory fee per loan, per occurrence, up to a maximum of $15,000 per month in which there are unresolved loan-level reporting errors that appear on the Loan Reconciliation Difference Report 90 days or more category. Freddie Mac will submit an ACH draft transaction for all data error compensatory fees the Servicer owes Freddie Mac on the last Business Day of the month in which the Servicer received the Performing Loans monthly Servicer Billing Statement from Freddie Mac stating the amount of the compensatory fees. Note: Refer to Section 8303.5(b) for information on establishing the ACH draft.

(g) Next month late reported payoff noncompliance compensatory fee Freddie Mac assesses this compensatory fee when the Servicer fails to report a paid off Mortgage by the second Business Day of the month following the month in which the Servicer receives the funds. This compensatory fee is equal to one month’s interest based on the net yield for each loan that the Servicer reports late. Freddie Mac may assess this compensatory fee in addition to other fees contained in this chapter. Freddie Mac may assess a late reported payoff compensatory fee if the Servicer fails to report the payoff of a matured Mortgage in accordance with Section 8301.4(g). Freddie Mac will submit an ACH transaction for all late reported payoff noncompliance compensatory fees the Servicer owes Freddie Mac on the last Business Day of the month in which the Servicer received the Performing Loans monthly Servicer Billing Statement from Freddie Mac indicating the amount of the compensatory fee. Refer to Section 8303.5(b) for information on establishing the ACH draft.

(h) Draft delay compensatory fee

(i) Compensatory fee with respect to payoff reporting With respect to payoffs, Freddie Mac assesses this compensatory fee when the Servicer fails to report a payoff within two Business Days of the Payoff Date and the late report results in a delayed Payoff Draft Date. Note: If the Servicer fails to report a paid-off Mortgage by the second Business Day of the month following the month in which the Servicer receives the funds, then the compensatory fee is determined as provided in Section 8303.5(g) rather than this Section 8303.5(i). (ii) Compensatory fee calculation method Freddie Mac calculates this compensatory fee by the amount of the payoff funds, multiplied by the number of calendar days the payoff draft was late as a result of the late reported payoff, multiplied by the highest quoted prime rate on the last Business Day of the month in which the late payoff draft occurred in the print edition of The Wall Street Journal in its regular column entitled “Money Rates” plus 3% divided by 365. If the prime rate is not published, then Freddie Mac will determine a comparable rate. (iii) Compensatory fee with respect to principal and interest or payoffs With respect to principal and interest or payoffs, Freddie Mac assesses this compensatory fee when the Servicer fails to have sufficient funds available for Freddie Mac to draft on the P&I Draft Date or on the Payoff Draft Date, as applicable. Freddie Mac calculates this compensatory fee by the amount of the principal and interest, or payoff, as applicable, multiplied by the number of calendar days the draft of principal and interest, or payoff, was late as a result of the failure of the Servicer to have sufficient funds available, multiplied by the highest quoted prime rate on the last Business Day of the month in which the draft failure occurred in the print edition of The Wall Street Journal in its regular column entitled “Money Rates” plus 3% divided by 365. If the prime rate is not published, then Freddie Mac will determine a comparable rate. The minimum monthly compensatory fee will be based on the number of noncompliance violations the Servicer commits in any consecutive 12-month period starting with the month in which the first violation occurred and as shown below: Minimum monthly compensatory fee IF the noncompliance violation within a consecutive 12-month period is the Servicer’s... THEN the draft delay compensatory fee will be... First instance No less than $250 in any given month Second instance No less than $500 in any given month Third instance or more in 12 months No less than $1,000 in any given month Freddie Mac will submit an ACH draft transaction for all cash remittance interest reimbursement compensatory fees the Servicer owes Freddie Mac on the last Business Day of the month in which the Servicer receives the Performing Loans monthly Servicer Billing Statement stating the amount of the compensatory fee. Refer to Section 8303.5(b) for information on establishing the ACH draft. Note: See Section 9603.3(f) for the compensatory fee assessed for late execution of a repurchase request for an REO. (i) Contract noncompliance and contract change compensatory fee Except as set forth in Section 6303.1(c), Freddie Mac may assess a contract noncompliance and contract change compensatory fee based on the circumstances listed below. (i) Purchase/funding corrections – post-fund data corrections (PFDCs) When a Seller or Servicer submits a PFDC more than 60 days after the close of the Accounting Cycle in which the loan was funded (purchased), Freddie Mac will assess a compensatory fee of $500 per Mortgage when Freddie Mac processes the database correction necessary to complete an approved PFDC request and the associated cash transaction. (ii) Servicing data corrections (SDC) (A) Postsettlement correction (loss mitigation workouts) In the case of Mortgage modification, when a Servicer submits a postsettlement data correction request more than 60 days after the settlement of the loss mitigation workout, Freddie Mac will assess a compensatory fee of $500 per Mortgage when Freddie Mac processes a database correction required to correct the loan-level data discrepancy and the associated cash transaction. (B) Loan-level reporting correction When a Servicer submits a loan-level reporting correction more than 60 days after the close of the Accounting Cycle in which the initial edit or data discrepancy occurred, Freddie Mac will assess a compensatory fee of $500 per Mortgage when Freddie Mac processes a database correction required to correct the loan-level data discrepancy and the associated cash transaction. (iii) Drafting compensatory fees Freddie Mac will submit an ACH draft transaction for all contract noncompliance and contract change compensatory fees on the last Business Day of the month in which the Servicer received the Performing Loans monthly Servicer Billing Statement and/or the Non-Performing Loans Monthly Servicer Invoice. Note: See Section 8303.5(b) for information on establishing the ACH draft.

■ Noncompliance with reporting and drafting requirements ■ Drafting noncompliance compensatory fees ■ Reporting noncompliance compensatory fees ■ Default reporting noncompliance compensatory fees ■ Unreported transactions and loan simulation compensatory fee ■ Aged data errors compensatory fee ■ Next month late reported payoff noncompliance compensatory fee ■ Draft delay compensatory fee ■ Contract noncompliance and contract change compensatory fee

(a) Noncompliance with reporting and drafting requirements The Servicer’s failure to comply with Freddie Mac’s requirements for reporting and drafting constitutes a violation of the Purchase Documents and the contractual obligations of the Guide. In addition to any other remedies Freddie Mac may have at law or in equity, the Servicer is subject to the assessment of compensatory fees for any violations. Freddie Mac will charge the Servicer a noncompliance compensatory fee for the Servicer’s failure to comply with Freddie Mac’s Servicing reporting requirements contained in Section 8106.1 or the accounting reporting time requirements contained in this chapter. Servicing reporting and accounting reporting noncompliance compensatory fees are each monitored and assessed separately. The Servicer will receive written notification of all compensatory and other fee assessments. Freddie Mac reserves the right to revise Freddie Mac’s compensatory and other fee schedules and change Freddie Mac’s methods of calculating compensatory and other fees at any time at Freddie Mac’s sole discretion. The Servicer may direct any questions regarding the assessment of accounting reporting compensatory and other fees to Freddie Mac (see Directory 7). See Section 8303.5(b) for instructions on remitting compensatory fees. The Servicer must complete, execute and submit to Freddie Mac Form 1132, Authorization for Automatic Transfer of Funds Through the Automated Clearing House (ACH) for Seller/Servicers, as an Electronic Record (as defined in Section 1401.1(b)), using a Portable Document Format (PDF) (or other Electronic Record format commonly used in the mortgage industry), that has been completed and contains the copy or representation of the pen and ink signature of the Servicer’s Authorized Employee (such copy or representation of the Authorized Employee’s signature shall be such Authorized Employee’s adopted Electronic Signature as defined in Section 1401.1(b)) and either: ■ Attach to an e-mail and deliver to Freddie Mac at [email protected]; or ■ Upload through the Freddie Mac eBilling system Freddie Mac and the Servicer agree that the delivery of Electronic Records with Electronic Signatures are eligible Electronic Transactions (as defined in Section 1401.1(b)) and are governed by the applicable provisions of Chapter 1401. The employee authorized to execute Form 1132 on the Servicer’s behalf must be designated as an “Authorized Employee” on the Servicer’s Form 988SF, Certificate of Incumbency for a Bank, Savings Bank, Savings and Loan Association, Credit Union, Corporation or Limited Liability Company, or Form 989SF, Certificate of Incumbency for Limited Partnerships, as applicable. The account identified in Form 1132 for the payment of fees must be a Demand Deposit Account that is separate from any Custodial Account required to be maintained pursuant to any of the Purchase Documents. The Servicer agrees to notify Freddie Mac immediately at [email protected] of any changes to the status of the Servicer’s ACH account.

(b) Drafting noncompliance compensatory fees Freddie Mac will initiate an ACH draft to collect any compensatory fees billed on the Performing Loans monthly Servicing Billing Statement and the Non-Performing Loans Invoice. To authorize ACH drafting of compensatory fees, the Servicer must: 1. Submit a completed, executed and duly authorized Form 1132 no later than 15 Business Days before the last Business Day of the first month in which the Servicer is liable to pay Freddie Mac any compensatory fees, to set up or make certain changes to the draft account. This form will authorize Freddie Mac to initiate an ACH draft and designates an account from which Freddie Mac will collect any compensatory and other fees for which Freddie Mac may bill the Servicer on the Performing Loans monthly Servicer Billing Statement and the Non-Performing Loans Invoice. 2. Designate an account other than one of Freddie Mac’s Custodial Accounts from which Freddie Mac will draft the amount due; and 3. Deliver Form 1132 to Freddie Mac as an Electronic Record (as defined in Section 1401.1(b)), using a Portable Document Format (PDF) (or other Electronic Record format commonly used in the mortgage industry), that has been completed and contains the copy or representation of the pen and ink signature of the Servicer’s Authorized Employee (such copy or representation of the Authorized Employee’s signature shall be such Authorized Employee’s adopted Electronic Signature as defined in Section 1401.1(b)) and either: ■ Attach to an e-mail and deliver to Freddie Mac at the following e-mail address: [email protected]; or ■ Upload through the Freddie Mac eBilling system ■ Freddie Mac and the Servicer agree that the delivery of Electronic Records with Electronic Signatures are eligible Electronic Transactions and are governed by the applicable provisions of Chapter 1401 The employee authorized to execute Form 1132 on the Servicer’s behalf must be designated as an “Authorized Employee” on the Servicer’s Form 988SF or Form 989SF, as applicable. Servicers may establish one ACH account for the payment of invoices for both the Performing Loans monthly Servicer Billing Statement and the Servicer Non-Performing Loans Invoice or establish two separate accounts. Servicers may submit billing inquires or billing-related requests to [email protected]. Note: See Section 9102.1 concerning Non-Performing Loans remittances. Note: See Sections 7101.1(b), 8303.5(a), 8303.5(c) through 8303.5(i) and 9603.3(f) for information on these compensatory fees.

(c) Reporting noncompliance compensatory fees Freddie Mac assesses a compensatory fee when the Servicer fails to comply with Freddie Mac’s Servicing reporting requirements for the reports listed in Section 8106.1 or with Freddie Mac’s reporting requirements contained in this chapter and Section 9102.6. If the Servicer commits more than one type of reporting offense within any consecutive 12month period, the Servicer may be subject to more than one reporting noncompliance fee. The Servicer will be subject to the applicable compensatory fee in accordance with Section 8303.5(d) for its failure to: 1. Submit complete and accurate Servicing reports, including the submission of error-free loan-level data within the required time frame 2. Report mandated data elements, such as the Last Payment Received Date (LPRD) or other fields as listed in Exhibit 60, Loan-Level Reporting Data Description 3. Provide information requested by Freddie Mac that is outside of the regular monthly reporting requirements of this chapter, or its failure to provide such requested information in a usable form within the required time frame Freddie Mac will notify the Servicer in writing of all instances of noncompliance.

(d) Default reporting noncompliance compensatory fees Freddie Mac may assess a compensatory fee when a Servicer fails to report applicable default related reporting events, in accordance with Section 9102.6 and Exhibit 82, Default Reporting Dataset Guidelines. The compensatory fees are based on the number of noncompliance violations the Servicer commits in any consecutive 12-month period starting with the month in which the first violation occurred and as shown below: Default related reporting noncompliance compensatory fee based on the number of violations IF the noncompliance violation within a consecutive 12-month period is the Servicer’s... THEN the reporting noncompliance compensatory fee is... AND the Servicer... First violation Greater of $250 or $50 per loan, up to $5,000 Second violation Greater of $500 or $50 per loan, up to $10,000 May be required to attend a reporting training seminar at the Servicer’s expense Third violation or more Greater of $1,000 or $50 per loan, up to $15,000 In addition to the monetary compensatory fees, beginning with the second violation, Freddie Mac may require the Servicer to attend reporting training at the Servicer’s expense. Freddie Mac reserves the right to invoke additional remedies, including suspension or disqualification as a Seller/Servicer or a full or partial termination of Servicing, in the event of continuing violations. Freddie Mac will bill the Servicer for such fees on the Servicer Non-Performing Loans Invoice. Refer to Section 9102.1 for information on the payment of Servicing Non-Performing Loans Invoices via an ACH draft.

(e) Unreported transactions and loan simulation compensatory fee Freddie Mac assesses a compensatory fee of $100 per loan when a Servicer fails to clear outstanding edits or report loan-level activity by the end of the Accounting Cycle.

(f) Aged data errors compensatory fee Freddie Mac may assess a $100 compensatory fee per loan, per occurrence, up to a maximum of $15,000 per month in which there are unresolved loan-level reporting errors that appear on the Loan Reconciliation Difference Report 90 days or more category. Freddie Mac will submit an ACH draft transaction for all data error compensatory fees the Servicer owes Freddie Mac on the last Business Day of the month in which the Servicer received the Performing Loans monthly Servicer Billing Statement from Freddie Mac stating the amount of the compensatory fees. Note: Refer to Section 8303.5(b) for information on establishing the ACH draft.

(g) Next month late reported payoff noncompliance compensatory fee Freddie Mac assesses this compensatory fee when the Servicer fails to report a paid off Mortgage by the second Business Day of the month following the month in which the Servicer receives the funds. This compensatory fee is equal to one month’s interest based on the net yield for each loan that the Servicer reports late. Freddie Mac may assess this compensatory fee in addition to other fees contained in this chapter. Freddie Mac may assess a late reported payoff compensatory fee if the Servicer fails to report the payoff of a matured Mortgage in accordance with Section 8301.4(g). Freddie Mac will submit an ACH transaction for all late reported payoff noncompliance compensatory fees the Servicer owes Freddie Mac on the last Business Day of the month in which the Servicer received the Performing Loans monthly Servicer Billing Statement from Freddie Mac indicating the amount of the compensatory fee. Refer to Section 8303.5(b) for information on establishing the ACH draft.

(h) Draft delay compensatory fee

(i) Compensatory fee with respect to payoff reporting With respect to payoffs, Freddie Mac assesses this compensatory fee when the Servicer fails to report a payoff within two Business Days of the Payoff Date and the late report results in a delayed Payoff Draft Date. Note: If the Servicer fails to report a paid-off Mortgage by the second Business Day of the month following the month in which the Servicer receives the funds, then the compensatory fee is determined as provided in Section 8303.5(g) rather than this Section 8303.5(i). (ii) Compensatory fee calculation method Freddie Mac calculates this compensatory fee by the amount of the payoff funds, multiplied by the number of calendar days the payoff draft was late as a result of the late reported payoff, multiplied by the highest quoted prime rate on the last Business Day of the month in which the late payoff draft occurred in the print edition of The Wall Street Journal in its regular column entitled “Money Rates” plus 3% divided by 365. If the prime rate is not published, then Freddie Mac will determine a comparable rate. (iii) Compensatory fee with respect to principal and interest or payoffs With respect to principal and interest or payoffs, Freddie Mac assesses this compensatory fee when the Servicer fails to have sufficient funds available for Freddie Mac to draft on the P&I Draft Date or on the Payoff Draft Date, as applicable. Freddie Mac calculates this compensatory fee by the amount of the principal and interest, or payoff, as applicable, multiplied by the number of calendar days the draft of principal and interest, or payoff, was late as a result of the failure of the Servicer to have sufficient funds available, multiplied by the highest quoted prime rate on the last Business Day of the month in which the draft failure occurred in the print edition of The Wall Street Journal in its regular column entitled “Money Rates” plus 3% divided by 365. If the prime rate is not published, then Freddie Mac will determine a comparable rate. The minimum monthly compensatory fee will be based on the number of noncompliance violations the Servicer commits in any consecutive 12-month period starting with the month in which the first violation occurred and as shown below: Minimum monthly compensatory fee IF the noncompliance violation within a consecutive 12-month period is the Servicer’s... THEN the draft delay compensatory fee will be... First instance No less than $250 in any given month Second instance No less than $500 in any given month Third instance or more in 12 months No less than $1,000 in any given month Freddie Mac will submit an ACH draft transaction for all cash remittance interest reimbursement compensatory fees the Servicer owes Freddie Mac on the last Business Day of the month in which the Servicer receives the Performing Loans monthly Servicer Billing Statement stating the amount of the compensatory fee. Refer to Section 8303.5(b) for information on establishing the ACH draft. Note: See Section 9603.3(f) for the compensatory fee assessed for late execution of a repurchase request for an REO. (i) Contract noncompliance and contract change compensatory fee Except as set forth in Section 6303.1(c), Freddie Mac may assess a contract noncompliance and contract change compensatory fee based on the circumstances listed below. (i) Purchase/funding corrections – post-fund data corrections (PFDCs) When a Seller or Servicer submits a PFDC more than 60 days after the close of the Accounting Cycle in which the loan was funded (purchased), Freddie Mac will assess a compensatory fee of $500 per Mortgage when Freddie Mac processes the database correction necessary to complete an approved PFDC request and the associated cash transaction. (ii) Servicing data corrections (SDC) (A) Postsettlement correction (loss mitigation workouts) In the case of Mortgage modification, when a Servicer submits a postsettlement data correction request more than 60 days after the settlement of the loss mitigation workout, Freddie Mac will assess a compensatory fee of $500 per Mortgage when Freddie Mac processes a database correction required to correct the loan-level data discrepancy and the associated cash transaction. (B) Loan-level reporting correction When a Servicer submits a loan-level reporting correction more than 60 days after the close of the Accounting Cycle in which the initial edit or data discrepancy occurred, Freddie Mac will assess a compensatory fee of $500 per Mortgage when Freddie Mac processes a database correction required to correct the loan-level data discrepancy and the associated cash transaction. (iii) Drafting compensatory fees Freddie Mac will submit an ACH draft transaction for all contract noncompliance and contract change compensatory fees on the last Business Day of the month in which the Servicer received the Performing Loans monthly Servicer Billing Statement and/or the Non-Performing Loans Monthly Servicer Invoice. Note: See Section 8303.5(b) for information on establishing the ACH draft.