Freddie Mac Single-Family Seller/Servicer Guide Section 9701.5 — Audit and compliance requirements

Freddie Mac Single-Family Seller/Servicer Guide Section 9701.5 — Audit and compliance requirements

9701.5: Audit and compliance requirements (09/10/25) This section contains requirements related to: ■ Standard supporting documentation for expense reimbursement ■ Expense reimbursement audits ■ Consent Agreement terms and conditions (a) Standard supporting documentation for expense reimbursement With the exception of Mortgages insured by the FHA or guaranteed by the VA or RHS not subject to recourse or indemnification, Freddie Mac generally will not require the Servicer to submit supporting documentation with its expense reimbursement requests and resubmission of denied reimbursement requests. However, there are situations, such as audits of reimbursement requests, where Freddie Mac will instruct the Servicer to provide standard supporting documentation. Standard supporting documentation for expense reimbursement requests includes, but is not limited to: 1. Proof of all disbursements: Copies of original bills/invoices of services performed for expenses submitted on the claim that include, but are not limited to, the following: ■ Legal fees and costs, ■ Property inspection, ■ Property preservation costs, ■ Primary mortgage insurance premiums, and Freddie Mac Single-Family Seller/Servicer Guide Chapter 9701 As of 04/08/26 Page 9701-23 ■ Condominium/homeowners association (HOA) or Cooperative Corporation assessments. (See Chapter 8801 for special Servicing requirements for Cooperative Share Loans.) 2. A copy of the project declaration highlighting, if applicable, the portion of the condominium/HOA assessments that may take priority over the Mortgage. For Cooperative Share Loans, refer to Section 8801.2(d) regarding standard supporting documentation for reimbursement of expenses incurred on a Cooperative Share Loan. 3. Copy of the Mortgage history beginning 12 months prior to the DDLPI through the date Freddie Mac requests the Mortgage history. Proof of payment of normal Escrow items is not required if shown in the history. However, if property tax payments are not consistent with the other taxes or if they were paid in a lump sum, the Servicer must submit documentation from the taxing authority providing the breakdown of the tax amount, including any late charges, penalties and interest (if applicable). 4. The buydown account balance, if applicable For expense reimbursement requests on Mortgages insured by the FHA or guaranteed by the VA or RHS not subject to recourse or indemnification, Freddie Mac requires the Servicer to provide supporting documentation, including, but not limited to: ■ A copy of the claim for benefits filed with the applicable entity ■ Any communication or requests for information from the applicable entity regarding the claim, including any response, and ■ Documentation showing the itemization of the distribution of the claim payment received from the applicable entity (e.g., loss claim packet or advice of payment letter) In the event a Servicer is required to submit supporting documentation for Freddie Mac to process the claim, the Servicer’s submission must meet the appropriate submission deadline in Section 9701.1(e) or any deadline given in Freddie Mac’s request for documentation. (b) Expense reimbursement audits Freddie Mac will perform audits of expenses to ensure compliance with Freddie Mac’s requirements. If Freddie Mac finds that an expense is not in compliance with applicable requirements, Freddie Mac may deny the reimbursement or adjust the claim. Freddie Mac will communicate an audit request to the Servicer via PAID (Payments Automated Intelligent and Dynamic) (see Exhibit 88, Servicing Tools). The Servicer will then be required to submit the standard supporting documentation via PAID within seven Business Days (refer to Section 9701.5(a)). If the Servicer fails to submit the required documentation by the deadline, the Servicer’s expense reimbursement request will be denied, and the Servicer will not be permitted to resubmit the claim to Freddie Mac. Freddie Mac Single-Family Seller/Servicer Guide Chapter 9701 As of 04/08/26 Page 9701-24 If Freddie Mac determines through the audit that an expense was not eligible for reimbursement, Freddie Mac will: ■ Provide the Servicer with an explanation of Freddie Mac’s audit findings, and ■ Release the expense back to the Servicer or adjust the expense based on Freddie Mac’s audit findings If Freddie Mac determines through an audit that a previously reimbursed expense was not eligible for reimbursement, Freddie Mac will bill the Servicer for the amounts due back to Freddie Mac on its monthly Servicer Non-Performing Loans Invoice. (Refer to Section 9102.1 for information on the payment of Servicing Non-Performing Loans Invoices via an Automated Clearing House draft.) If Freddie Mac determines through the audit that Freddie Mac owes funds to the Servicer, Freddie Mac will remit the funds to the Servicer within 30 calendar days of the date Freddie Mac notifies the Servicer of the audit findings. (c) Consent Agreement terms and conditions (i) Defined terms For purposes of this Section 9701.5(c), the following terms have the prescribed meaning: Definitions from Exhibit 103, Consent Agreement Incorporated Provisions A Advances Advances of delinquent principal and interest (subject to the provisions of Article III of this Exhibit 103), advances of taxes and insurance, and all other advances, including foreclosure and liquidation and related expenses required to be made by Servicer under the Guide and/or the other Purchase Documents, including, but not limited to, the requirements of Guide Chapter 9701, and Guide Sections 8301.4(g) and 7101.6(a), or other replacement chapters or sections of the Guide governing reimbursement of advances, with respect to the Covered Mortgages. Advance Financing Financing made by Secured Party to Servicer to fund Advances subject to reimbursement from Freddie Mac. Freddie Mac Single-Family Seller/Servicer Guide Chapter 9701 As of 04/08/26 Page 9701-25 C Consent Agreement The agreement entered into by and among Freddie Mac, Servicer and Secured Party pursuant to which Freddie Mac gives its consent to an Advance Financing (as such term is defined in Exhibit 103) as set forth in Section 9701.5(c) and Exhibit 103, and any modifications, supplements or amendments to the same. R Reimbursement Amounts Amounts available for reimbursement to Servicer by Freddie Mac in connection with Advances related to the Covered Mortgages. (ii) Eligibility This Section 9701.5(c) is not a general offering and is only available to specific Servicers. This Section 9701.5(c) does not apply unless and until Freddie Mac and the Servicer execute and deliver a Consent Agreement, in form and substance acceptable to Freddie Mac in its sole and absolute discretion, implementing these terms and conditions. (iii)Consent Agreements With the prior express written consent of Freddie Mac, a Servicer, in order to obtain Advance Financing, may grant a security interest to a third-party lender in all of such Servicer’s present and future rights, as expressly set forth in and subject to the limitations of the Guide and/or the other Purchase Documents, for the reimbursement of Advances required to be made by the Servicer under the Guide and/or the other Purchase Documents, including, but not limited to, the reimbursement of expense requirements of Chapter 9701, Servicer advances required in Section 8301.4(g) and transfer of funds requirements in Section 7101.6(a). If Freddie Mac consents to an Advance Financing, it will indicate its consent only by executing a Consent Agreement, which must also be executed by the Servicer and its Secured Party, in form and substance acceptable to Freddie Mac in its sole and absolute discretion. All Consent Agreements must include the following language: This Consent Agreement incorporates the provisions of Section 9701.5(c) of the Guide and the provisions of Guide Exhibit 103 by reference and such provisions are a substantive contractual part of this Consent Agreement such that each of the Servicer and its Secured Party expressly agrees: Freddie Mac Single-Family Seller/Servicer Guide Chapter 9701 As of 04/08/26 Page 9701-26 ■ That Guide Section 9701.5(c) is operative as to the Servicer and its Secured Party and ■ Each of the Servicer and its Secured Party is bound by the terms and conditions set forth in Guide Section 9701.5(c) and Guide Exhibit 103 Any purported or attempted assignment, sale, hypothecation, pledge or transfer of, or grant of a security interest in Reimbursement Amounts or any other purported or attempted Advance Financing transaction, without execution and delivery of a Consent Agreement is prohibited and shall be null and void. The Reimbursement Amounts are not an interest in nor a component of Servicing Contract Rights, nor are they proceeds or cashflow derived from Servicing Contract Rights. No Advance Financing shall be construed as a division of the Servicing Contract Rights. A Servicer may make a separate request to Freddie Mac for consent to enter into a financing transaction secured by Servicing Contract Rights, and the proceeds and cashflow derived from the Servicing Contract Rights (a “Servicing Contract Rights Financing”), pursuant to Guide Section 1101.2(c) and Guide Exhibit 33A, Acknowledgment Agreement Incorporated Provisions, Exhibit 33B, Acknowledgment Agreement (Syndication) Incorporated Provisions, Exhibit 33C, Acknowledgment Agreement (Cashflow) Incorporated Provisions, or Exhibit 33D, Acknowledgment Agreement (Combination) Incorporated Provisions, as applicable. In no event shall any Advance Financing be cross-collateralized with any Collateral under any Servicing Contract Rights Financing. Any collateral under any Advance Financing is and will continue to be at all times separate and distinct from any and all Collateral under any Servicing Contract Rights Financing.” (iv) Collateral Pledge Agreements Freddie Mac reserves the right to condition its entry into a Consent Agreement on the Servicer’s pledge of collateral pursuant to a Collateral Pledge Agreement in substantially the form and substance of Exhibit 104, Collateral Pledge Agreement.

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