Fannie Mae Servicing Guide A4-2.2-02 — Law Firm Management and Oversight

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Fannie Mae Servicing Guide A4-2.2-02 — Law Firm Management and Oversight.

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      paragraph_quote: 'A4-2.2-02, Law Firm Management and Oversight (11/12/2014) Introduction This topic contains the following: Overview of Law Firm Management and Oversight Establishing Written Policies and Procedures Related to Law Firm Oversight and Compliance Conducting Law Firm Compliance Reviews and Training Reporting Law Firm Performance to Fannie Mae Escalations of Law Firm and Servicer Issues and Government and Media Inquiries Overview of Law Firm Management and Oversight The servicer is fully responsible for managing and overseeing all aspects of the performance and compliance of any law ﬁrm to which it makes a referral, including foreclosure prevention activities and timeline performance. The servicer must interact with the law ﬁrm as necessary throughout the course of the foreclosure or bankruptcy proceedings in order to ensure that the matters are completed in a timely manner, in accordance with applicable law, and in accordance with the requirements of the Servicing Guide, including the requirement that the servicer timely deliver good and marketable title to Fannie Mae following a foreclosure. The servicer must obtain, review, and analyze data and reports from the law ﬁrms and take appropriate action as necessary. The servicer is accountable and responsible to Fannie Mae for any delays or losses resulting from deﬁciencies in the law ﬁrm’s performance. The servicer must reimburse Fannie Mae for any losses suﬀered because a law ﬁrm did not meet its responsibilities. The following table lists the servicer''s ongoing responsibilities following referral to a law ﬁrm. ✓ After referral, the servicer must… Continue pursuing foreclosure prevention eﬀorts. Keep the law ﬁrm apprised about the status of any workout proposals, bankruptcy ﬁlings, or other events that aﬀect the matter. Provide any additional documentation, information, or signatures to the law ﬁrm, as needed. Published May 13, 2026 154 ✓ After referral, the servicer must… Advance funds to pay attorney fees and costs. Provide bidding instructions. File applicable IRS forms related to paying attorney fees. Monitor timeline performance. Obtain and review data and reports from law ﬁrms and take appropriate actions as necessary. Fulﬁll all of its other servicing obligations. The servicer must also ensure that the law ﬁrm is able to process foreclosures and bankruptcies in a timely and eﬃcient manner, recognize and facilitate foreclosure prevention whenever possible, and quickly obtain relief from the bankruptcy so that foreclosure proceedings may be initiated or continued, when appropriate. Establishing Written Policies and Procedures Related to Law Firm Oversight and Compliance The servicer must develop and have in place policies and procedures regarding oversight and compliance relating to law ﬁrms handling Fannie Mae default-related matters. The servicer must have policies and procedures reasonably designed to ensure that the law ﬁrms handling of Fannie Mae default-related matters are in compliance with the Mortgage Default Counsel Retention Agreement with Fannie Mae, the applicable provisions of the Servicing Guide, and applicable law. Conducting Law Firm Compliance Reviews and Training The servicer must conduct periodic law ﬁrm compliance reviews and training as appropriate. In determining the frequency of ﬁrm compliance reviews, the servicer must consider the overall risk posed by the ﬁrm (legal, reputational, and ﬁnancial), ﬁrm volume, performance, any changes in staﬃng ratios or levels, any litigation against the ﬁrm alleging systemic issues, any media coverage regarding the ﬁrm, and the prior results of any ﬁrm compliance reviews. Compliance Reviews: The servicer''s ongoing compliance monitoring must address the following minimum elements. Published May 13, 2026 155 ✓ Elements of the servicer’s ongoing compliance monitoring that must be maintained Ongoing eligibility under Fannie Mae minimum requirements. Compliance with the limited retention agreement with Fannie Mae, including the fee and cost guidelines. Compliance with the applicable provisions of the Servicing Guide. Compliance with applicable law. Law ﬁrm capacity. Reputational risk issues, for example, complaints against the law ﬁrm, bar complaints, sanction proceedings, or investigations by regulatory or law enforcement authorities. Veriﬁcation that the law ﬁrm has eﬀective controls in place related to information security, data management, and fraud prevention. Document custody practices. Business continuity. Maintenance of appropriate errors and omissions coverage. Financial viability. Adequacy of staﬃng. Applicable ratios (attorney to staﬀ; attorney to ﬁle, and staﬀ to ﬁle) and the law ﬁrm’s management of the ratios. Training. Quality of work. The servicer must make available to Fannie Mae upon request the materials relating to its performance and compliance monitoring of law ﬁrms providing default-related legal services, including Published May 13, 2026 156 information regarding the servicer''s compliance monitoring, including scope and methodology, the schedule of law ﬁrm compliance reviews conducted, the identity of any vendors used in the law ﬁrm compliance reviews, any documentation from the law ﬁrm compliance reviews, and any ﬁndings, reports or remediation plans resulting from the law ﬁrm compliance reviews. Fannie Mae reserves the right to review and require changes to the servicer''s compliance process, as well as to require the servicer to conduct additional compliance activities related to law ﬁrms handling its default matters. In addition, Fannie Mae may require the servicer to change the scope of its compliance process in connection with Fannie Mae mortgage loans. Fannie Mae also reserves the right to directly conduct law ﬁrm audits and law ﬁrm on-site visits as deemed necessary. Ongoing Training: The servicer must ensure that law ﬁrms receive any necessary training, including information regarding Fannie Mae requirements, such as Servicing Guide Announcements that may aﬀect the law ﬁrms. Although Fannie Mae may conduct mandatory law ﬁrm training from time to time, the servicer is responsible for ensuring that law ﬁrms are aware of Fannie Mae’s requirements. Reporting Law Firm Performance to Fannie Mae The servicer must generate and provide in a timely manner data and reports requested by Fannie Mae related to, among other things, servicer performance in managing the foreclosure and bankruptcy processes and oversight of law ﬁrm performance and compliance. The servicer must provide Fannie Mae access, as requested, to data in its servicing systems regarding Fannie Mae mortgage loans. Fannie Mae will periodically specify the required data and reports on Fannie Mae’s website. Escalations of Law Firm and Servicer Issues and Government and Media Inquiries Within two business days of discovery, or sooner if circumstances warrant, the servicer must notify Fannie Mae of matters requiring Fannie Mae''s attention, including the following: any information regarding a law ﬁrm that might warrant a suspension of referrals, the transfer of matters to another law ﬁrm, and/or termination of the law ﬁrm; information suggesting legal or reputational risk posed by a law ﬁrm, e.g., bar complaints, sanction proceedings, or litigation asserting systemic issues with the law ﬁrm or its practices; any actual or suspected data security breach involving the law ﬁrm; any actual or alleged fraud on the part of a law ﬁrm; federal, state, or local governmental inquiries, including Congressional inquiries, that involve a signiﬁcant legal or reputational risk issue related to a law ﬁrm selected and retained to perform default-related legal services on Fannie Mae mortgage loans or that involve a signiﬁcant legal or reputational risk issue related to default-related practices of the servicer on Fannie Mae mortgage loans; media inquiries related to a law ﬁrm selected and retained to perform default-related legal services on Fannie Mae mortgage loans or default-related practices of the servicer on Fannie Mae mortgage loans; Published May 13, 2026 157 volume or capacity issues with a law ﬁrm; a breach of the limited retention agreement between Fannie Mae and a law ﬁrm; any systemic issues with a law ﬁrm; signiﬁcant issues with the servicer''s process for handling delinquent mortgage loans, e.g., an issue that causes widespread foreclosure delays or an issue that requires remediation eﬀorts be taken with respect to mortgage loans in one or more jurisdictions; or any material change in the ownership, partnership, or organization of the law ﬁrm after executing the limited retention agreement, including instances where a named partner leaves the law ﬁrm or a practice group separates from the law ﬁrm. Fannie Mae reserves the right to issue direction to servicers and law ﬁrms regarding escalated matters. Escalation Process: Escalated matters must be reported to Fannie Mae’s Legal department via email (see F-4-02, List of Contacts). The following table provides additional instructions for escalating matters to Fannie Mae. ✓ When the servicer provides Fannie Mae notice of a matter requiring Fannie Mae’s attention, the servicer must… Designate in its email one or more points of contact. Promptly obtain and provide Fannie Mae with any additional information requested from the law ﬁrm. Recent Related Announcements There are no recently issued Announcements related to this topic. A4-2.2-03, Prohibition Against Servicer-Speciﬁed Vendors for Fannie Mae Referrals, Use of Vendors, and Outsourcing Companies (04/12/2017) The servicer cannot directly or indirectly require or encourage law ﬁrms to use speciﬁed vendors in connection with Fannie Mae referrals, including, but not limited to title companies, Published May 13, 2026 158 posting and publication vendors, and service of process vendors. The law ﬁrm must be allowed to select vendors of its choice based on its assessment of factors such as the cost eﬃciency, quality, reliability, and timeliness of the services provided by the vendor. Arrangements with vendors and other service providers, particularly aﬃliates, must not be inﬂuenced by an actual or perceived conﬂict of interest. The servicer and law ﬁrm must use the most cost-eﬃcient and eﬀective vendors to assist in processing foreclosures and bankruptcy cases without regard to arrangements that could provide a ﬁnancial beneﬁt directly or indirectly to the servicer. The law ﬁrm must obtain Fannie Mae’s prior written approval if it wishes to use a vendor that is the servicer itself, an outsourcing company, or other third-party vendor utilized by the servicer to assist in servicing defaulted mortgage loans, or an aﬃliate of the servicer, outsourcing company, or third-party vendor. Requests for approval must be directed to Fannie Mae’s Legal Department via email (see F-4-02, List of Contacts). The servicer must not enter into or participate in any arrangements with an outsourcing company or third-party vendor pursuant to which the servicer receives a direct or indirect beneﬁt of any kind (such as a lower charge for services or a payment) for referring a foreclosure or bankruptcy matter relating to a Fannie Mae mortgage loan to a particular law ﬁrm. In addition, the servicer must obtain prior written approval from Fannie Mae’s Legal Department before entering into any arrangement with an outsourcing company or third-party vendor that is not an approved Fannie Mae servicer involving the outsourcing company or third-party vendor undertaking all or substantially all of the servicer’s responsibilities with respect to servicing loans in bankruptcy (see F-4-02, List of Contacts). Outsourcing companies or third-party vendors must not be permitted to directly or indirectly select, or inﬂuence the selection of, the law ﬁrms to be used on Fannie Mae mortgage loans. The servicer, its agents, or any outsourcing ﬁrm it employs may not charge either directly or indirectly any outsourcing fee, referral fee, packaging fee, or similar fee in connection with any Fannie Mae mortgage loan. This requirement is in place, in part, to deter actual and potential conﬂicts of interest that may arise and compromise the overall eﬀectiveness of service provided to Fannie Mae. To help ensure compliance with this requirement, Fannie Mae explicitly prohibits the following parties from directly or indirectly charging any amounts to (or receiving any payments or any beneﬁts from) law ﬁrms or their aﬃliates in connection with any Fannie Mae mortgage loan or service provided directly or indirectly with respect to any Fannie Mae mortgage loan except as Fannie Mae may expressly permit the servicer, any outsourcing company or other third-party vendor utilized by the servicer to assist in servicing defaulted mortgage loans (for example, referring loans to foreclosure or bankruptcy, monitoring law ﬁrm performance, or providing administrative support services), and any aﬃliate of the servicer, outsourcing company, or third-party vendor. Fannie Mae does expressly permit the beneﬁt that servicers may receive from law ﬁrms having access to and utilizing data obtained from the servicer''s systems through "direct sourcing" arrangements. Any other charges, payments, or beneﬁts from law ﬁrms or their aﬃliates in connection with Fannie Mae mortgage loans will require Fannie Mae''s prior written approval. Published May 13, 2026 159 The servicer is responsible for ensuring compliance with these requirements. The servicer must diligently monitor and manage any outsourcing company or vendor it utilizes to assist with the servicing of defaulted mortgage loans to ensure all Fannie Mae servicing guidelines are fully met in a timely and cost-eﬀective manner. Recent Related Announcements There are no recently issued Announcements related to this topic.'

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Verbatim provisions from Fannie Mae Servicing Guide A4-2.2-02 — Law Firm Management and Oversight — 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.

Fannie Mae Servicing Guide A4-2.2-02 — Law Firm Management and Oversight

A4-2.2-02, Law Firm Management and Oversight (11/12/2014) Introduction This topic contains the following: Overview of Law Firm Management and Oversight Establishing Written Policies and Procedures Related to Law Firm Oversight and Compliance Conducting Law Firm Compliance Reviews and Training Reporting Law Firm Performance to Fannie Mae Escalations of Law Firm and Servicer Issues and Government and Media Inquiries Overview of Law Firm Management and Oversight The servicer is fully responsible for managing and overseeing all aspects of the performance and compliance of any law ﬁrm to which it makes a referral, including foreclosure prevention activities and timeline performance. The servicer must interact with the law ﬁrm as necessary throughout the course of the foreclosure or bankruptcy proceedings in order to ensure that the matters are completed in a timely manner, in accordance with applicable law, and in accordance with the requirements of the Servicing Guide, including the requirement that the servicer timely deliver good and marketable title to Fannie Mae following a foreclosure. The servicer must obtain, review, and analyze data and reports from the law ﬁrms and take appropriate action as necessary. The servicer is accountable and responsible to Fannie Mae for any delays or losses resulting from deﬁciencies in the law ﬁrm’s performance. The servicer must reimburse Fannie Mae for any losses suﬀered because a law ﬁrm did not meet its responsibilities. The following table lists the servicer's ongoing responsibilities following referral to a law ﬁrm. ✓ After referral, the servicer must… Continue pursuing foreclosure prevention eﬀorts. Keep the law ﬁrm apprised about the status of any workout proposals, bankruptcy ﬁlings, or other events that aﬀect the matter. Provide any additional documentation, information, or signatures to the law ﬁrm, as needed. Published May 13, 2026 154 ✓ After referral, the servicer must… Advance funds to pay attorney fees and costs. Provide bidding instructions. File applicable IRS forms related to paying attorney fees. Monitor timeline performance. Obtain and review data and reports from law ﬁrms and take appropriate actions as necessary. Fulﬁll all of its other servicing obligations. The servicer must also ensure that the law ﬁrm is able to process foreclosures and bankruptcies in a timely and eﬃcient manner, recognize and facilitate foreclosure prevention whenever possible, and quickly obtain relief from the bankruptcy so that foreclosure proceedings may be initiated or continued, when appropriate. Establishing Written Policies and Procedures Related to Law Firm Oversight and Compliance The servicer must develop and have in place policies and procedures regarding oversight and compliance relating to law ﬁrms handling Fannie Mae default-related matters. The servicer must have policies and procedures reasonably designed to ensure that the law ﬁrms handling of Fannie Mae default-related matters are in compliance with the Mortgage Default Counsel Retention Agreement with Fannie Mae, the applicable provisions of the Servicing Guide, and applicable law. Conducting Law Firm Compliance Reviews and Training The servicer must conduct periodic law ﬁrm compliance reviews and training as appropriate. In determining the frequency of ﬁrm compliance reviews, the servicer must consider the overall risk posed by the ﬁrm (legal, reputational, and ﬁnancial), ﬁrm volume, performance, any changes in staﬃng ratios or levels, any litigation against the ﬁrm alleging systemic issues, any media coverage regarding the ﬁrm, and the prior results of any ﬁrm compliance reviews. Compliance Reviews: The servicer's ongoing compliance monitoring must address the following minimum elements. Published May 13, 2026 155 ✓ Elements of the servicer’s ongoing compliance monitoring that must be maintained Ongoing eligibility under Fannie Mae minimum requirements. Compliance with the limited retention agreement with Fannie Mae, including the fee and cost guidelines. Compliance with the applicable provisions of the Servicing Guide. Compliance with applicable law. Law ﬁrm capacity. Reputational risk issues, for example, complaints against the law ﬁrm, bar complaints, sanction proceedings, or investigations by regulatory or law enforcement authorities. Veriﬁcation that the law ﬁrm has eﬀective controls in place related to information security, data management, and fraud prevention. Document custody practices. Business continuity. Maintenance of appropriate errors and omissions coverage. Financial viability. Adequacy of staﬃng. Applicable ratios (attorney to staﬀ; attorney to ﬁle, and staﬀ to ﬁle) and the law ﬁrm’s management of the ratios. Training. Quality of work. The servicer must make available to Fannie Mae upon request the materials relating to its performance and compliance monitoring of law ﬁrms providing default-related legal services, including Published May 13, 2026 156 information regarding the servicer's compliance monitoring, including scope and methodology, the schedule of law ﬁrm compliance reviews conducted, the identity of any vendors used in the law ﬁrm compliance reviews, any documentation from the law ﬁrm compliance reviews, and any ﬁndings, reports or remediation plans resulting from the law ﬁrm compliance reviews. Fannie Mae reserves the right to review and require changes to the servicer's compliance process, as well as to require the servicer to conduct additional compliance activities related to law ﬁrms handling its default matters. In addition, Fannie Mae may require the servicer to change the scope of its compliance process in connection with Fannie Mae mortgage loans. Fannie Mae also reserves the right to directly conduct law ﬁrm audits and law ﬁrm on-site visits as deemed necessary. Ongoing Training: The servicer must ensure that law ﬁrms receive any necessary training, including information regarding Fannie Mae requirements, such as Servicing Guide Announcements that may aﬀect the law ﬁrms. Although Fannie Mae may conduct mandatory law ﬁrm training from time to time, the servicer is responsible for ensuring that law ﬁrms are aware of Fannie Mae’s requirements. Reporting Law Firm Performance to Fannie Mae The servicer must generate and provide in a timely manner data and reports requested by Fannie Mae related to, among other things, servicer performance in managing the foreclosure and bankruptcy processes and oversight of law ﬁrm performance and compliance. The servicer must provide Fannie Mae access, as requested, to data in its servicing systems regarding Fannie Mae mortgage loans. Fannie Mae will periodically specify the required data and reports on Fannie Mae’s website. Escalations of Law Firm and Servicer Issues and Government and Media Inquiries Within two business days of discovery, or sooner if circumstances warrant, the servicer must notify Fannie Mae of matters requiring Fannie Mae's attention, including the following: any information regarding a law ﬁrm that might warrant a suspension of referrals, the transfer of matters to another law ﬁrm, and/or termination of the law ﬁrm; information suggesting legal or reputational risk posed by a law ﬁrm, e.g., bar complaints, sanction proceedings, or litigation asserting systemic issues with the law ﬁrm or its practices; any actual or suspected data security breach involving the law ﬁrm; any actual or alleged fraud on the part of a law ﬁrm; federal, state, or local governmental inquiries, including Congressional inquiries, that involve a signiﬁcant legal or reputational risk issue related to a law ﬁrm selected and retained to perform default-related legal services on Fannie Mae mortgage loans or that involve a signiﬁcant legal or reputational risk issue related to default-related practices of the servicer on Fannie Mae mortgage loans; media inquiries related to a law ﬁrm selected and retained to perform default-related legal services on Fannie Mae mortgage loans or default-related practices of the servicer on Fannie Mae mortgage loans; Published May 13, 2026 157 volume or capacity issues with a law ﬁrm; a breach of the limited retention agreement between Fannie Mae and a law ﬁrm; any systemic issues with a law ﬁrm; signiﬁcant issues with the servicer's process for handling delinquent mortgage loans, e.g., an issue that causes widespread foreclosure delays or an issue that requires remediation eﬀorts be taken with respect to mortgage loans in one or more jurisdictions; or any material change in the ownership, partnership, or organization of the law ﬁrm after executing the limited retention agreement, including instances where a named partner leaves the law ﬁrm or a practice group separates from the law ﬁrm. Fannie Mae reserves the right to issue direction to servicers and law ﬁrms regarding escalated matters. Escalation Process: Escalated matters must be reported to Fannie Mae’s Legal department via email (see F-4-02, List of Contacts). The following table provides additional instructions for escalating matters to Fannie Mae. ✓ When the servicer provides Fannie Mae notice of a matter requiring Fannie Mae’s attention, the servicer must… Designate in its email one or more points of contact. Promptly obtain and provide Fannie Mae with any additional information requested from the law ﬁrm. Recent Related Announcements There are no recently issued Announcements related to this topic. A4-2.2-03, Prohibition Against Servicer-Speciﬁed Vendors for Fannie Mae Referrals, Use of Vendors, and Outsourcing Companies (04/12/2017) The servicer cannot directly or indirectly require or encourage law ﬁrms to use speciﬁed vendors in connection with Fannie Mae referrals, including, but not limited to title companies, Published May 13, 2026 158 posting and publication vendors, and service of process vendors. The law ﬁrm must be allowed to select vendors of its choice based on its assessment of factors such as the cost eﬃciency, quality, reliability, and timeliness of the services provided by the vendor. Arrangements with vendors and other service providers, particularly aﬃliates, must not be inﬂuenced by an actual or perceived conﬂict of interest. The servicer and law ﬁrm must use the most cost-eﬃcient and eﬀective vendors to assist in processing foreclosures and bankruptcy cases without regard to arrangements that could provide a ﬁnancial beneﬁt directly or indirectly to the servicer. The law ﬁrm must obtain Fannie Mae’s prior written approval if it wishes to use a vendor that is the servicer itself, an outsourcing company, or other third-party vendor utilized by the servicer to assist in servicing defaulted mortgage loans, or an aﬃliate of the servicer, outsourcing company, or third-party vendor. Requests for approval must be directed to Fannie Mae’s Legal Department via email (see F-4-02, List of Contacts). The servicer must not enter into or participate in any arrangements with an outsourcing company or third-party vendor pursuant to which the servicer receives a direct or indirect beneﬁt of any kind (such as a lower charge for services or a payment) for referring a foreclosure or bankruptcy matter relating to a Fannie Mae mortgage loan to a particular law ﬁrm. In addition, the servicer must obtain prior written approval from Fannie Mae’s Legal Department before entering into any arrangement with an outsourcing company or third-party vendor that is not an approved Fannie Mae servicer involving the outsourcing company or third-party vendor undertaking all or substantially all of the servicer’s responsibilities with respect to servicing loans in bankruptcy (see F-4-02, List of Contacts). Outsourcing companies or third-party vendors must not be permitted to directly or indirectly select, or inﬂuence the selection of, the law ﬁrms to be used on Fannie Mae mortgage loans. The servicer, its agents, or any outsourcing ﬁrm it employs may not charge either directly or indirectly any outsourcing fee, referral fee, packaging fee, or similar fee in connection with any Fannie Mae mortgage loan. This requirement is in place, in part, to deter actual and potential conﬂicts of interest that may arise and compromise the overall eﬀectiveness of service provided to Fannie Mae. To help ensure compliance with this requirement, Fannie Mae explicitly prohibits the following parties from directly or indirectly charging any amounts to (or receiving any payments or any beneﬁts from) law ﬁrms or their aﬃliates in connection with any Fannie Mae mortgage loan or service provided directly or indirectly with respect to any Fannie Mae mortgage loan except as Fannie Mae may expressly permit the servicer, any outsourcing company or other third-party vendor utilized by the servicer to assist in servicing defaulted mortgage loans (for example, referring loans to foreclosure or bankruptcy, monitoring law ﬁrm performance, or providing administrative support services), and any aﬃliate of the servicer, outsourcing company, or third-party vendor. Fannie Mae does expressly permit the beneﬁt that servicers may receive from law ﬁrms having access to and utilizing data obtained from the servicer's systems through "direct sourcing" arrangements. Any other charges, payments, or beneﬁts from law ﬁrms or their aﬃliates in connection with Fannie Mae mortgage loans will require Fannie Mae's prior written approval. Published May 13, 2026 159 The servicer is responsible for ensuring compliance with these requirements. The servicer must diligently monitor and manage any outsourcing company or vendor it utilizes to assist with the servicing of defaulted mortgage loans to ensure all Fannie Mae servicing guidelines are fully met in a timely and cost-eﬀective manner. Recent Related Announcements There are no recently issued Announcements related to this topic.

Source: Fannie Mae Servicing Guide A4-2.2-02 — Law Firm Management and Oversight · source URL · snapshot cf63a82bbb4adfba