융자지식200- FHA UNDERWRITING GUIDELINES/PROCESSES AND PROCEDURES

융자지식200- FHA UNDERWRITING GUIDELINES/PROCESSES AND PROCEDURES

PROCESSES AND PROCEDURES
Processes and Procedures describe how to use Flagstar’s systems and tools to achieve FHA, GNMA and
Flagstar requirements.
4506-C
• If the 4506-C transcripts do not match the borrower’s income and the borrower is a victim of
taxpayer identification theft, the following conditions must be met in order to validate the borrower’s
income.
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o Proof of identification theft as evidenced by one of the following:
 Proof ID theft was reported to and received by the IRS (IRS form 14039) OR
 Copy of notification from the IRS alerting the taxpayer to possible identification theft
o In addition to one of the documents above, all applicable documents below must be
provided:
 W2 or 1099 transcripts which match the W2 or 1099 income shown on the 1040s
 1099 mortgage interest must match the reported interest on Schedule A or Schedule
E
 1099G unemployment must match the reported amount of unemployment
 1099 dividend and interest income must match the reported dividend and interest
 Validation of prior tax year’s income (income for current year must be in line with
prior years)
APPRAISALS
The required method for ordering appraisals is based on each lender’s approval type with Flagstar and
FHA.
• If Flagstar must be the client on the appraisal, order the appraisal through Loantrac Appraisal
Management
• For additional information and links to Flagstar-approved appraisal management companies, refer
to Appraisal Management Companies, Doc. #4903
Description Underwriting Close in Own Name Client on Appraisal
FHA Authorized Agent Flagstar Yes Flagstar or Correspondent 1,3
FHA Test Case Phase Lender Yes Correspondent 3
FHA Direct Endorsement Lender Yes Correspondent 3
FHA Sponsored Originator Flagstar No Flagstar
TCP2 Dual/Sponsored Originator Flagstar Yes Correspondent 3
TCP2 Dual/Sponsored Originator Lender Yes Correspondent 3
FHA Dual/AA Flagstar Yes Flagstar or Correspondent 1
FHA Dual/AA Lender Yes Correspondent 3
FHA SO AA Flagstar Yes Correspondent 3
1. Flagstar must approve the correspondent for appraisal independence compliance. If the correspondent is not approved for appraisal independence
compliance, the appraisal must be ordered through Loantrac Appraisal Management.
2. TCP refers to an FHA lender in its test case phase.
3. Appraiser must be Flagstar-eligible and must not be on Flagstar’s ineligible or denied appraiser list. If the eligible appraiser search indicates the
appraiser is inactive, expired or suspended, prior to ordering the appraisal, submit the appropriate documentation to Appraiser.Approval@flagstar.com.
PORTABILITY
• To transfer a Flagstar appraisal to another lender, refer to the Transfer Appraisal From Flagstar
to Another Lender section of Conventional Underwriting Guidelines
• Appraisals already performed for a case number that was subsequently transferred to Flagstar
must be emailed in .xml format to appraisal.review@flagstar.com by one of the following:
o The original DE lender to whom the loan was initially submitted or
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o The appraisal management company providing the appraisal or
o The appraiser
PROPERTY ADDRESSES
The property addresses on the appraisal, case number assignment, flood certification, mortgage, note
and in Loantrac must be identical. However, abbreviation of Street, Road, etc. is acceptable, even if
Street or Road is fully spelled in another document. This is the only acceptable variance.
• Use the standardized USPS address. Compare the USPS address to the legal description on
the title commitment and use the address in the legal description if that differs from the USPS
address
• Appraisers are required to state the USPS address as the property address on the appraisal. If
the legal address differs from the USPS address, the appraiser must reference the legal
address in a comment on the appraisal or an addendum to the appraisal
SECOND APPRAISAL POLICY – DEFICIENT APPRAISALS
Flagstar DE underwriters adhere to the following policies and processes when determining whether an
appraisal contains material deficiencies:
• If the underwriter determines there are flaws and/or material deficiencies, he or she contacts the
appraiser and requests necessary revisions, clarification, additional supporting documentation
and/or missing data
• If the appraiser fails to provide the information or provides insufficient data and the appraisal still
contains material deficiencies, the appraisal is forwarded to the Appraisal Review team for
analysis
• A prior-to-close condition indicating the appraisal has been forwarded to Appraisal Review is
added to the loan
• Upon receipt of the Appraisal Review team member’s comments, the DE underwriter
determines whether a new appraisal is warranted
o If not warranted, the conditional commitment is issued based on the original appraisal
o If the original appraisal contains significant flaws, the DE Underwriter requests a second
Appraisal through the Appraisal Review team. Even if the originating lender has been
approved for Appraiser Independence Compliance, second appraisals due to significant
flaws may never be ordered by anyone other than the DE Underwriter
BORROWERS
BORROWER’S NAME
• The borrower’s name on the case number assignment must match the borrower’s name in
Loantrac and the note and mortgage
o The following name discrepancies are the only acceptable variations:
 James Everett Brown, James E. Brown, James Brown
 William Smith Jr., William Smith, William R. Smith, William Ryan Smith, Jr.,
William Ryan Smith, William R. Smith, Jr.
o The following name discrepancies must be resolved prior to the loan closing (this list is
not all-inclusive and name discrepancies are reviewed on a case-by-case basis):
 Name discrepancies due to marriage (Case number shows Mary Smith, but
documentation in Loantrac and/or the note and mortgage shows Mary Jones)
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 Hyphenated name discrepancies (Case number shows Bill Smith, but
documentation in Loantrac and/or the note and mortgage shows Bill SmithJones)
 Middle name discrepancies (Case number shows Bill John Smith, but
documentation in Loantrac and/or the note and mortgage shows Bill Robert
Smith)
 First name discrepancies (Case number shows Bill Smith, but documentation in
Loantrac and/or the note and mortgage shows William Smith)
 Last name prefix discrepancies (Case number shows Bill St. Pete, but
documentation in Loantrac and/or the note and mortgage shows Bill Stpete)
CASE NUMBER ASSIGNMENT/TRANSFER
CASE NUMBER FUNCTIONS
• Case numbers for Sponsored Originators must be ordered through Flagstar Bank’s Loantrac
System.
• Case numbers for lenders in “eligible for pre-closing” status with FHA (test case phase) must be
ordered by Flagstar. Submit a completed Case Number Assignment Request, Doc. #9301 to
fsgovlend@flagstar.com.
• If the case number cannot be ordered through Loantrac because the loan was submitted to
underwriting prior to case number assignment or update of an existing Flagstar case number is
required, complete FHA Case Number Assignment Request, Doc. #9301 and submit to
fsgovlend@flagstar.com.
• To obtain a copy of the Refinance Authorization screen for FHA to FHA refinance transactions,
complete FHA Refinance Credit Query/Authorization Request, Doc. #9353 and submit to
fsgovlend@flagstar.com. Note: When requesting an FHA to FHA refinance case number
through Loantrac, a Refinance Authorization is automatically provided.
• To obtain a case number transfer from Flagstar to another DE lender, complete FHA Case
Number Transfer Request, Doc. #9352 and submit to fsgovlend@flagstar.com.
• If a Flagstar case number requires cancellation, email fsgovlend@flagstar.com. The email
request must contain the borrower’s name, loan number, FHA case number and reason for case
cancellation.
• Flagstar cannot perform case number functions for case numbers that are not already in
Flagstar’s name. The DE lender to whom the case number is assigned is responsible for all
case number functions.
CASE NUMBER ASSIGNMENT – DATA ENTRY
When entering the case number assignment date in Loantrac, enter the “Case Received” date from the
Case Query screen in FHA Connection.
CLOSING REQUIREMENTS
NOTARY POLICY
Refer to the Notary Policy stated in Settlement/Closing Requirements, Doc. #4601
ESCROW CREDITS
• For refinances of Flagstar serviced loans only, the borrower’s existing escrow balance on the
payoff may be used for one of the following purposes:
o Reduce the payoff amount
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 When calculating the maximum mortgage amount, escrow credits applied for this
purpose must be deducted from the existing balance
 The payoff amount on the Closing Disclosure will be reduced by the amount of
the existing escrow balance
o As a credit to the closing costs on the new loan
 The credit must appear on the Closing Disclosure
 The maximum mortgage is calculated using the existing principal balance on the
payoff statement
 If, instead of entering a credit on the Closing Disclosure, the payoff amount is
reduced by the amount of the escrow credit, the borrower’s authorization must be
updated and the maximum loan amount must be recalculated. If the loan closes
prior to adjustment, a principal reduction will be required
o As a credit toward the establishment of the new refinance loan’s escrow account
 The credit must appear on the Closing Disclosure
 The maximum mortgage is calculated using the existing principal balance on the
payoff statement
 If, instead of entering a credit on the Closing Disclosure, the payoff amount is
reduced by the amount of the escrow credit, the borrower’s authorization must be
updated and the maximum loan amount must be recalculated. If the loan closes
prior to adjustment, a principal reduction will be required
o In all cases, borrowers wishing to use their existing escrow balance for one or more of
the above purposes must complete FHA Escrow Account Authorization, Doc. #9356.
Borrowers who do not complete the form prior to the loan being cleared to close are
ineligible for escrow credits.
CLOSING – MISCELLANEOUS
• For FHA to FHA refinance transactions, the up-front mortgage insurance premium refund must
be credited to the borrower on the Closing Disclosure
• All closing/funding conditions must be collected and provided in the closing package
• Any changes to loan amount, upfront MIP, cash-to-close, interest rate, points, PITI, etc. must be
reviewed by underwriting prior to closing and disbursing loan
• Principal reductions are required when the total of lender and/or seller credits reflected on the
Closing Disclosure exceeds the total of the actual closing costs, pre-paid expenses and
discount points
• Principal reductions are required when the borrower is receiving more than $500 cash at closing
on a rate and term or streamline refinance loan. However, if the borrower has requested to
apply the existing escrow balance to the closing costs and pre-paid expenses on the new loan
and the existing escrow balance exceeds the amount required to pay closing costs and
establish the new escrow account by more than $500, the borrower may receive the excess
funds in cash at closing. This is the only acceptable reason for a borrower to receive more than
$500 cash back at closing on a rate and term or streamline refinance.
• Closing documents must be signed and notarized on or before the closing date indicated on the
closing documents, regardless of the state in which the property is located and/or whether it’s
an escrow state
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CONFLICT OF INTEREST
The loan officer cannot receive compensation from any other person or entity involved in the mortgage
transaction, (i.e. compensation as the real estate agent).
CREDIT REPORTS
AGE OF CREDIT REPORTS
• To achieve Flagstar’s and FHA’s minimum credit requirements, a new credit report may be repulled after a borrower has repaired derogatory credit, and Flagstar will honor the new credit
score. The new credit report must be imported to Loantrac
• The following credit report discrepancies require a new credit report:
o Social Security number is incorrect
o Last name is incorrect
o Middle initial is incorrect
o Misspelled first names and/or missing or incorrect suffixes (Jr./Sr.) require a new credit
report unless the name variation appears in the AKA section of the credit report
DE CUSTOMERS ONLY
• Credit report must contain Office of Foreign Assets Control (OFAC) screening
• If credit report indicates a potential OFAC match, the credit report must be e-mailed to
Delegated.Underwriting@Flagstar.com for review by Flagstar Bank’s Secrecy Act Compliance
Department – The loan may not close without clearance from Flagstar’s BSA Department
(violation of this policy is a federal crime)
DISCLOSURES/FORMS
REQUIRED DISCLOSURES AND FORMS
• In addition to the other forms listed in Government Forms and Disclosures, Doc. #9005,
HUD/VA Addendum to Uniform Residential Loan Application, HUD Form 92900-a is required for
all FHA loans. Lender and sponsor information on the form is based on the originating lender’s
relationship with FHA and/or Flagstar Bank. Complete the fields described below in the following
manner:
o Sponsored Originators (TPOs), including loans underwritten by Flagstar for an
Authorized Agent who is still in their test case phase and has only conditional FHA
approval (pre-closing review status)
 Page 1:
• Box 13 – Enter Flagstar’s FHA Lender ID – 7127400001
• Box 14 – Leave Blank
• Box 15 – Enter Flagstar’s name and address: Flagstar Bank, 5151
Corporate Drive, Troy, MI 48098
• Box 16 – Leave Blank
• Box 17 – Enter Flagstar’s phone number: (800) 945-7700
• FHA Sponsored Originations Section – Enter the loan originating lender’s
company name, company Tax ID and company NMLS ID
• A Flagstar officer must sign page one at the time the loan is insured – No
originator signature is required – Must not be signed prior to the borrower
signing page 2
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 Page 2:
• No Lender/sponsor info
• Form must be signed by borrower(s) at initial application
 Page 3:
• Form is signed by Flagstar’s underwriter
 Page 4:
• Mortgagee – Flagstar Bank
• Title of Lender’s Officer and Signature – A Flagstar officer must sign at
the time of insuring – No originator signature is required
• Form must be signed by borrower(s) at closing
o Loans Underwritten by Flagstar as Authorized Agent for an FHA-approved DE Lender
who has completed their test cases and is unconditionally approved by FHA
 Page 1:
• Box 13 – Enter originating lender’s FHA lender ID
• Box 14 – Enter Flagstar’s FHA Lender ID – 7127400001
• Box 15 – Enter originating lender’s name and address
• Box 16 – Enter Flagstar’s name and address: Flagstar Bank, 5151
Corporate Drive, Troy, MI 48098
• Box 17 – Enter originating lender’s phone number
• FHA Sponsored Originations – Leave Blank
• An officer (not the loan officer or originator) of the originating lender’s
company must sign – No originator signature is required – Must not be
signed prior to the borrower signing page 2
 Page 2:
• No Lender/sponsor info
• Form must be signed by borrower(s) at initial application
 Page 3:
• No Lender/Sponsor info
• Form is signed by Flagstar’s underwriter
 Page 4:
• Mortgagee – Originating lender’s name
• An officer (not the loan officer or originator) of the originating lender’s
company must sign – No originator signature is required
• Form must be signed by borrower(s) at closing
o Loans Underwritten by Flagstar-approved DE Delegated Correspondents
 Page 1:
• Box 13 – Enter DE Delegated correspondent’s FHA lender ID
• Box 14 – Leave blank
• Box 15 – Enter DE Delegated correspondent’s name and address
• Box 16 – Leave Blank
• Box 17 – Enter DE Delegated correspondent’s phone number
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• FHA Sponsored Originations – Leave Blank
• An officer (not the loan officer or originator) of the DE Delegated
correspondent’s company must sign – No originator signature is required
-– Must not be signed prior to the borrower signing page 2
 Page 2:
• No Lender/sponsor info
• Form must be signed by borrower(s) at initial application
 Page 3:
• Form is signed by DE Delegated correspondent’s underwriter
 Page 4:
• Mortgagee – DE Delegated correspondent’s name
• An officer (not the loan officer or originator) of the DE Delegated
correspondent’s company must sign – No originator signature is required
• Form must be signed by borrower(s) at closing
For additional FHA document and disclosure requirements, refer to Government Forms and
Disclosures, Doc. #9005.
ELECTRONIC SIGNATURES
Electronic signatures are permitted for all FHA loan documents except the following:
• Powers of attorney
• Form SSA-89
• Note
ESCROW STATES
• Arizona
• California
• Colorado
• Hawaii
• Idaho
• Montana
• Nevada
• New Mexico
• Oregon
• Utah
• Washington
• Wyoming
ESCROWS
• Escrow waivers not allowed
• Escrows are required for all of the following:
o Real estate taxes
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o Monthly mortgage insurance premiums
o Hazard insurance premiums, including flood insurance, wind insurance, etc.
o Special assessments
o Ground rents
• Unless the loan has one of the following characteristics, property tax escrows are calculated using
the taxes stated on the title commitment, regardless of the rate used to calculate the borrower’s
debt-to-income ratios:
o When calculating the real estate tax payment for existing (not new construction) properties,
the following documentation may be used:
 Taxes listed on the title commitment or property tax bill/cert or
 Evidence from the local assessor’s office of the current tax rate
o For properties being purchased from a seller who paid non-homestead taxes, the title
commitment will indicate the non-homestead tax rate. Homestead tax rates may be used to
calculate the borrower’s ratios, provided evidence of the homestead tax rate is obtained
from the local tax assessor’s office. Lenders must collect escrows based on the amount
shown on the title commitment.
o Generally, property tax escrows for all new construction properties must be calculated based
on the fully assessed property value. Obtain actual tax amounts from the local tax
assessor’s office. If the new construction property taxes charged by the municipality will not
be based on the fully improved property within 12 months of closing, escrows may be based
on one of the following. Note: Regardless of assessment dates, ratios and reserves must
be calculated based on the fully assessed property value.
 Lot only; or
 A partial assessment; or
 Actual or estimated amount based on fully assessed value
o The Closing Department will require the borrower(s) to confirm that once the property is fully
assessed, they are aware of the potential escrow shortage
o For purchases of new and existing properties in California only, property taxes may be
calculated using 1.25% of the purchase price or the actual tax rate
ESCROW HOLDBACKS – REPAIRS
In addition to FHA’s repair escrow requirements and Flagstar’s overlays above, the following
documents and clarifications apply:
• Fully executed Escrow Holdback Agreement, Doc. #3655 required in closing package
• For additional repair escrow information, refer to Escrow Holdback Procedures, Doc. #4634
• For new construction properties, items such as pools, decks, sod, etc. may remain incomplete
due to weather-related situations. Escrow holdback will be amount indicated on building
agreement, contract and/or vendor agreement.
For purchases of bank-owned properties, approval of repair escrow is granted on a case-bycase basis for completion of exterior repairs that cannot be completed due to inclement
weather.
HIGHER PRICED MORTGAGE LOANS (HPML)
Loans having an APR that is ≥ 1.5% above the APOR on the date the loan locked are classified as an
HPML. All HPMLs must meet the following requirements:
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• Pre-payment penalties are not permitted
• The interest rate cannot adjust within the first seven years of the loan – FHA ARMs classified as
HPMLs are ineligible
• Escrows must be collected for the life of the loan
• Streamline refinance transactions are eligible, provided they are credit qualified
• For FHA transactions that are considered Safe Harbor QM that are HPML for purposes of Section
35, please reference Higher Priced Mortgage Loans (HPML), Doc. #4813. Loans that have a QM
status of Rebuttable Presumption are required to have a Residual Income Worksheet, this form is
not applicable to delegated loans.
INDUSTRY LINKS/FLAGSTAR LINKS/CONTACTS
• FHA Mortgage Limits Search Engine
• FHA Approved Condos Search Engine
• HUD Training Archives
• HUD Training and Events Page
• HUD’s Lender Page
• FHA Connection
• Government Services Administration (GSA) Excluded Parties Search Engine
• Limited Denials of Participation (LDP) Excluded Parties Search Engine
• Flagstar Bank Wholesale Website
• Flagstar Bank Government Underwriting Help Desk
o E-Mail: GovernmentUW@Flagstar.com
o Phone: 866-945-9872, Option 1 for Underwriting, then Option 2 for Government
Underwriting
• HUD’s Listserv email distribution that announces FHA changes and available training:
o Email answers@HUD.gov
INSURANCE
HAZARD INSURANCE
Hazard Insurance Requirements, Doc. #4602
FLOOD INSURANCE
• Flood Insurance – Broker & Non-Delegated Correspondent, Doc. #4603
• Eligible Flood Provider Companies, – FEMA Flood Insurance Company List
• Flood insurance policy must be a NFIP policy and must cover all improvements, including
detached structures. Flood insurance provided by private providers is not permitted
• If the subject property is a condominium-unit, the NFIP policy must be obtained by the
homeowner’s association. Borrower purchased flood insurance is not permitted unless the
property is a site condominium. Loans must be denied if the HOA does not maintain adequate
flood insurance, regardless of FHA condominium approval status
CONDOMINIUM FIDELITY/LIABILITY INSURANCE
• Hazard Insurance Requirements, Doc. #4602
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• Each project must have $1,000,000 business liability insurance coverage with the HOA named
as the insured
• Projects having > 20 units must show evidence of Fidelity (employee dishonesty) coverage ≥
three months HOA income with the HOA named as the insured
• Site Condominiums – Liability insurance is not required
• Must be provided prior-to-close
HO-6 POLICY
For coverage requirements, refer to Hazard Insurance Requirements, Doc. #4602
LOAN TERMS
FIXED RATE MORTGAGES
10, 15, 20, 25 and 30-year fixed rate mortgages
ARMS
3/1 and 5/1 CMT adjustable-rate mortgages
MAXIMUM LOAN AMOUNT
Maximum Loan calculations are published in the 9000 series of our Sellers Guide:
• FHA Maximum Mortgage Worksheet – Purchase, Doc. #9328
• FHA Maximum Mortgage Worksheet – Rate & Term Refinance, Doc. #9342
• FHA Maximum Mortgage Worksheet – Simple Refinance, Doc. #9346
• FHA Maximum Mortgage Worksheet – Cash-Out Refinance, Doc. #9345
• FHA Maximum Mortgage Worksheet – Streamline Refinance, Doc. #9347
NET TANGIBLE BENEFIT
NET TANGIBLE BENEFIT CALCULATION WORKSHEETS
To calculate the borrower’s net tangible benefit for Streamline refinances, use FHA Refinance Net
Tangible Benefit Worksheet, Doc. #9348.
STATE-REQUIRED NET TANGIBLE BENEFIT FORMS
FHA Refinance Net Tangible Benefit Worksheet, Doc. #9348 may not be used in lieu of any staterequired net tangible benefit forms. When a state requires a net tangible benefit form, the appropriate
form must be completed.
POWER OF ATTORNEY
• All signatures on the power of attorney must be notarized, and the power of attorney must be
reviewed by a Flagstar underwriter. All signatures must match the signatures in the file
• Unless the POA is a military Durable POA, the POA must be specific to Flagstar Bank’s loan and
indicate the property address
• POA is not allowed for single borrower transactions unless Flagstar Bank has borrower experience
and the underwriter can compare signatures from previous transaction(s)
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REFINANCE TRANSACTIONS
STREAMLINE REFINANCES AND CASH-OUT REFINANCE LOANS
• Refinances must meet all FHA 4000.1 occupancy requirements; and
• Must meet the following seasoning requirements when the loan being paid off is a government
loan (FHA, VA or USDA); and
• The borrower made at least six consecutive monthly payments on the loan being refinanced,
beginning with the date the payment was made for the first payment due date; and
• The first payment due date of the refinance loan occurs no earlier than 210 days after the first
payment due date of the initial loan.
SHORT PAYOFF ON A RATE AND TERM REFINANCE
A specific written principal reduction (short payoff) agreement between the existing lender and borrower
is required. The agreement must reference the borrower and the loan being paid off.
SOCIAL SECURITY AND DISABILITY BENEFITS
When the Notice of Award or equivalent document does not have a defined expiration, the Mortgagee
must not inquire or request additional documentation for continuance of the nature of the disability or the
medical conditions. If any disability income from (Social Security Administration (SSA), Department of
Veterans Affairs (VA), or a private disability insurance provider) is due to expire within three years from the
date of mortgage application, that income cannot be used as Effective Income. Refer to HUD Single
Family Handbook 4000.1 for complete details.
TITLE
The title commitment must be dated within 90 days of closing. If greater than 90 days, a gap letter will be
required, which will allow the title to be extended an additional 90 days
ENERGY LOAN TAX ASSESSMENT PROGRAM (ELTAP) LIENS
Not permitted
MINERAL RIGHTS – EXCEPTIONS TO TITLE
Exceptions to title for Mineral Rights are acceptable as long as the title company states in writing that
there are no active mineral rights on the property at the time of loan closing
DEED RESTRICTIONS
• In addition to any deed restriction that does not meet FHA’s requirements, deed restrictions with
the following characteristics are ineligible:
o Single-family use restrictions when the property is a two- to four-family property
o Deed restriction creates or provides for a lien that would be prior to the lien of the home
mortgage or provides for the elimination of the home mortgage lien
• The terms and provisions of the restrictive agreements or restrictive covenants must be
commonly acceptable to the private institutional mortgage investors in the area where the
mortgaged premises are located
• Title company must provide an endorsement to the title policy that affirmatively insures that no
violation of any such restrictive agreement or restrictive covenant exists and that any future
violation shall not result in forfeiture or reversion of title is required
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UNEXPIRED RIGHTS OF REDEMPTION
• All States Except Alabama:
o Unless the property is located in the State of Alabama, Flagstar will not approve and/or
purchase any loan having an unexpired right of redemption unless the purchase
agreement, title and appraisal all show the same seller who is the original mortgagor
 Title may show lis pendens notices from the bank or mortgagee
 Purchase contract may indicate a short sale
• Alabama Only:
o Purchase agreement, title and appraisal will be in the name of the lender and not the
original mortgagor.
o Title commitment will show one or both of the following acceptable recorded deeds:
 Foreclosure from John Doe (original mortgagor) to Anybank (foreclosing lender)
followed by the date on the deed and the recording date
 When the foreclosing lender deeds the property to HUD, Fannie Mae, Freddie
Mac, VA or GNMA, there will be a special warranty deed from Anybank
(foreclosing lender) to one of the GSEs listed above followed by the date on the
deed and the recording date
• If the above referenced deeds are dated within the most recent 12 months, the title commitment
must contain a specific exception for the unexpired right of redemption and affirmatively insure,
without qualification, the mortgagee (Flagstar Bank) against all losses arising out of the exercise
of any outstanding right of redemption
UNDERWRITING TURN TIMES
Current underwriting turn times are posted on Flagstar’s website.

융자지식199- FHA UNDERWRITING GUIDELINES/OVERLAYS

융자지식199- FHA UNDERWRITING GUIDELINES/OVERLAYS

FHA UNDERWRITING GUIDELINES
• HUD Handbook 4000.1 – Single Family Housing Policy Handbook
• FHA Single Family Housing Policy Handbook Glossary
OVERLAYS
4506-C
• A fully executed IRS Form 4506-C must be included in all loan files, except for FHA Non-Credit
Qualifying Streamlines
• 1040 transcripts are required for the following income types:
o Self-employed
o Rental income documented on Schedule E
o Employed by family
o Fixed income types such as disability, social security, retirement, child support, alimony,
etc., when the 1040s are obtained in lieu of alternative documentation such as award letters,
1099s, bank statements, etc.
APPRAISALS
APPRAISAL MANAGEMENT COMPANIES
If Flagstar will underwrite the loan, appraisals for the following properties must be ordered through a
Flagstar approved appraisal management company:
• Property is a doublewide manufactured home
• Borrower is an employee in the sales or production function of any mortgage originating branch
or company
ASSETS
SWEAT EQUITY
Not allowed
BUY-DOWNS
Ineligible
GIFT FUNDS/DPA
• Gift Funds – FHA transactions using gift funds the maximum DTI will follow AUS and allow gift
funds from blood relatives, employers and close friends only.
• Down Payment Assistance (DPA) with credit scores below 680: The total debt-to-income (DTI)
cannot exceed 43%.
CLOSING
CLOSING IN TRUST
• For loans closing in a trust, a Certificate of Trust (Lending), Doc. #3954 or similar form is
required. For properties located in California, the California Trust Certificate, Doc. #3951 or
similar form may be used.
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ESCROW CREDITS
• If the refinance transaction pays off any servicer other than Flagstar, escrow credit for the
borrower’s existing escrow balance is not permitted.
• Flagstar does not provide an interest-free advance for the payment of closing costs or
establishing escrows
CONDOMINIUMS
Flagstar does not participate in DELRAP
CREDIT REPORTS
Credit reports for Streamline refinances must be tri-merge credit reports
CREDIT SCORES
MINIMUM CREDIT SCORES
Minimum FHA Credit Scores
Loan Purpose Minimum Credit Score
Purchase 1-2 Unit/PUD/Condo/203k 1 620
Purchase 3-4 Units (excludes 203k) 660
Rate and Term Refinance and Simple Refinance 1-2 Unit/PUD/Condo/203k 1 620
Rate and Term Refinance and Simple Refinance 3-4 Units (excludes 203k) 660
Cash-Out Refinance 1-2 Unit/PUD/Condo 2 620
Cash-Out Refinance 3-4 Units 2, 3 660
Streamline Refinance 1-2 Unit/PUD/Condo 620
Streamline Refinance 3-4 Units 660
1. 203k available for approved DE Delegated Correspondents only
2. Cash-out refinances maximum DTI cannot exceed 50%
3. Cash-out refinances 3-4 Unitsmaximum cash-in-hand $300,000
DOWN PAYMENT ASSISTANCE
All community second and grant programs must be Flagstar-eligible. Refer to Gift/Grant Programs, Doc.
#5935 or Community Seconds Programs, Doc. #5932.
ESCROW HOLDBACKS – REPAIRS
• Closing documents must be prepared through Flagstar’s Web-Based Closing Documents (WBCD),
and all repair escrows for Flagstar-underwritten loans are held by Flagstar
• Two bids required for all repair escrows except HUD REO
o Escrow holdback will be 1½ times the highest bid – Bids may not exceed $6,666 for
maximum escrow holdback of $10,000. Note: Overlay does not apply to purchases of HUD
REO properties where FHA permits $10,000 in repairs and $11,000 repair escrow or
properties subject to disaster repairs where FHA limits the repair escrow to $5,000.
• One draw only permitted upon completion of repairs
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INSURANCE
If Flagstar underwrites the loan, HO-6 insurance coverage for condominiums and PUDs having any
coverage maintained under a master policy must be at least 20% of the property’s appraised value or
replacement cost.
MANUALLY UNDERWRITTEN TRANSACTIONS
Manual Underwrites/Refer Responses/Non-Traditional, Alternative Credit or No Credit Score loans are
currently suspended.
MAXIMUM NUMBER OF FLAGSTAR BANK LOANS
Flagstar will not approve and close or purchase loans for borrowers having more than five loans with
Flagstar Bank or having an aggregate loan amount ≥ $4,000,000. The maximum number of loans and
aggregate loan amount calculations include all of the following:
• Non-closed loans with Flagstar Bank
• Loans that are closed and currently serviced by Flagstar Bank
• Loans that were closed with Flagstar Bank but the servicing rights have been sold to another lender
within the most recent 24 months
MCC CREDITS
Permitted for Correspondent lenders who close in their own names
POWER OF ATTORNEY
• Permitted for purchase or rate and term refinance only. Cash-out transactions may not close with
any power of attorney other than a military durable power of attorney
• Powers of Attorney may not be e-signed
PRODUCTS AND PROGRAMS
INELIGIBLE PROGRAMS
• 203(K) and Limited 203(K)
• Title I Loans
• Home Equity Conversion Mortgages (Reverse Mortgages)
• Section 247 – Hawaiian Homelands
• Section 248 – Indian Reservations
• Section 184 – Indian Home Loan Guarantee Program
• Section 223(e) – Declining Neighborhoods
• FHA Negative Equity Refinance (ADP Codes 821, 822, 831, 832)
• Energy Efficient Mortgages
PROPERTY ELIGIBILITY
INELIGIBLE
• Properties with a PACE lien that will not be paid off prior to or at closing. Note: HERO loans
are issued under the PACE financing program.
• Properties located in Puerto Rico
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VI. Underwriting Guidelines 6 of 18 04/16//2021
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• Manufactured homes unless the loan is a Flagstar to Flagstar rate and term or Streamline
refinance:
o Manufactured homes are not permitted in the following states: Colorado, Illinois,
Kentucky, Louisiana, Missouri, New York, Pennsylvania, Texas, or U.S. Virgin Islands
• 3-4 unit properties when one or more borrowers does not have credit scores
• Properties having both a stick-built and manufactured home located on the same parcel or
property unless the manufactured home is unoccupied and utilities are not hooked up
• Investment properties under the HUD REO program
PROPERTY INSPECTIONS FOR PRESIDENTIALLY DECLARED DISASTER AREAS
If the Streamline refinance pays off any servicer other than Flagstar, an inspection meeting FHA’s disaster
inspection requirement is required when the loan is cleared to close within 120 days of the disaster
inspection.
PURCHASES
PURCHASES OF SHORT SALES
• Copy of the fully executed short sale agreement is required
• Must be an arms-length transaction
RATIOS
• If the credit score is below 660 and the loan receives an AUS approve/accept the maximum DTI
ratio cannot exceed 55%.
RECENTLY LISTED PROPERTIES
Cash-out, rate and term and Simple refinance:
• Property must be off the market at least one day prior to application
REFINANCE TRANSACTIONS
CASH-OUT REFINANCE
• Maximum cash-in-hand for 1-2 Unit – Follow AUS
• Maximum cash-in-hand for 3-4 Units – $300,000
• Maximum DTI ratio for cash-out 1-4 Unit refinances cannot exceed 50%.
SECTION 8 HOUSING VOUCHERS
Due to system constraints, subsidies paid directly to the servicer are not permitted and may not be
deducted from the borrower’s proposed housing payment when calculating the ratios.

융자지식198- CONVENTIONAL UNDERWRITING OVERLAYS

융자지식198- CONVENTIONAL UNDERWRITING OVERLAYS

CONVENTIONAL UNDERWRITING OVERLAYS
Bulk correspondent transactions are not subject to Flagstar’s underwriting overlays except in the following
categories: credit score, LTV/CLTV/HCLTV, purpose, property type, and AUS response.
CHINESE DRYWALL
If Chinese Drywall is currently or previously existed in the home, the property is ineligible
MANUFACTURED HOMES
• Manufactured homes are only allowed on Flagstar-to-Flagstar refinances
• Property must be a double-wide (multi-width) manufactured home
• Not permitted in CO, IL, KY, LA, MO, NY, PA, TX or VI
• Subordinate financing is not allowed
• All closing documents must be ordered through Flagstar Bank’s Web-Based Closing Documents
(WBCD)
• Manufactured homes that have been deconstructed and moved to another property are not eligible
MANUFACTURED HOME AS AN ACCESSORY UNIT ONLY
• Manufactured home accessory unit must be recorded on title as real property prior to closing or at
time of purchase.
• An appraisal is required to verify compliance with all manufactured home standards, regardless of
DU/LPA response offerings for an appraisal waiver
• The addition of or improvements to a manufactured home accessory unit are not eligible under the
Homestyle Renovation product.
MULTIPLE LOANS TO THE SAME BORROWER
Flagstar Bank will not approve or close more than 5 loans to any one borrower or an aggregate loan
amount total of $4,000,000. When determining if the limit has been met, new loan submissions for a
borrower must take into consideration any of that borrower’s outstanding loans with Flagstar Bank that are:
• Non-closed
• Closed and currently serviced by Flagstar Bank, or
• Closed but the servicing rights have been sold within the last 24 months.
If a borrower is applying for more than one loan through Flagstar Bank, all loans must be submitted to
Underwriting at the same time and each loan must reference the other loan(s).
OCCUPANCY
If the borrower applies for an owner occupied transaction after closing on a previous owner occupied
transaction with Flagstar on a different property in the last 12 months, the new transaction will be ineligible.
This guideline will not apply if the previous property has been sold or refinanced as a non-owner occupied
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residence. For owner occupied transactions, the borrower warrants he or she will occupy the property for at
least 12 months.
POWER OF ATTORNEY
• Purchase or rate/term refinance transaction only.
• Not allowed on cash-out transactions. Freddie Mac allows the use of a POA Fannie Mae does not.
However, no exceptions regardless of targeted investor.
• Not allowed on investment transactions.
TITLE COMMITMENT EFFECTIVE DATE
Generally, title commitments have a 90 day effective date, however a title commitment cannot exceed 120
days. If the title commitment exceeds 120 days, the title insurer is required to provide a gap letter (good for
an additional 60 days) or an updated/new title commitment. Under no circumstances can a title
commitment with a gap letter exceed 180 days.

융자지식197- REPAIR ESCROWS FOR POSTPONED OR INCOMPLETE IMPROVEMENTS

융자지식197- REPAIR ESCROWS FOR POSTPONED OR INCOMPLETE IMPROVEMENTS

REPAIR ESCROWS FOR POSTPONED OR INCOMPLETE IMPROVEMENTS
New construction and existing properties with repair conditions, which do not impact the ability to obtain an
occupancy permit (if applicable) may be eligible for a repair escrow if the following requirements are met:
Requirements for Postponed or Incomplete Improvements
Requirement Fannie Mae with Approve Freddie Mac with Accept
Loan Purpose Purchase Transactions
Occupancy • All occupancy types are acceptable
• LTV/CLTV/HCLTV based on product limitations
Property Type Manufactured Homes are not eligible
Mortgage
Insurance
MI is available through
• Arch
• MGIC
• Genworth
• Radian
Repair Limits
Escrow costs of improvements must not
exceed 10% of the ‘as completed’ value of the
property
One-unit Owner Occupied and Second
Homes only, the costs may not exceed 15% of
the ‘as completed’ value of the of property
Escrow costs of improvements must not
exceed 10% of the value of the property
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Requirements for Postponed or Incomplete Improvements
Requirement Fannie Mae with Approve Freddie Mac with Accept
Eligible
Repairs
Improvements must not affect the livability, soundness or structural integrity of the property.
New construction:
• Valid reason for postponed completion including weather related delays in cold weather
states (e.g. cement work for driveways and sidewalks or landscaping such as sod or
sprinklers) or shortage of materials (shortage must be verified by builder); and
• Do not impact the ability to obtain an occupancy permit (if applicable)
• Fannie Mae only- swimming pools are eligible for one-unit owner occupied and second
homes
Existing construction:
• Minor exterior repairs with weather related delays in cold weather states (e.g. siding
repairs); and/or
• Minor interior repairs such as carpet, minor plumbing leaks, cracked window glass, that
are typically due to normal wear and tear; and
Interior repairs are not eligible unless subject is an REO property.
Ineligible
Repairs
Repairs affecting soundness and safety are ineligible, including but not limited to:
• Plumbing, electrical, septic, or HVAC systems not fully functional
• Kitchen not fully functional
• Foundation cracks or settlement issues
• Water in basement
• Siding or fascia along eaves that is missing or has significant damage
• Mold of any significance
Roof Repairs or replacement including past or present leaks.
Sales Contract
Sales contract must be inclusive of all repairs
and improvements.
One-unit Owner Occupied and Second
Homes new construction only, improvements
may be contracted through a third party (e.g.
swimming pool or landscaping) however the
third party contract cost may not be
considered in the calculation of interested
party contribution limits.
Investment property with a separate sales
contract for construction of the pool by a third
party, refer to Fannie Mae HomeStyle
Renovation, Doc. #5719.
Sales contract must be inclusive of all repairs
and improvements.
Escrow Funds
Determination
Equal to 120% of the repair cost as determined by the following:
• Two bids obtained. The higher of the two bids estimates will be used.
• Fully executed contract for improvements.
For new construction, if the builder offers a guaranteed-fixed price contract for completion of
improvements, the funds held only need to equal the amount of the contract price.
Note: Funds are an overage above the loan amount and does not factor into the max loan or
LTV
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Requirements for Postponed or Incomplete Improvements
Requirement Fannie Mae with Approve Freddie Mac with Accept
Escrow
Account
All repair escrows are to be held by Flagstar Bank, No exceptions.
• For seller funded repairs, any funds remaining after the repairs must be applied to the
principal balance.
• Funds contributed from borrower’s own funds may be returned to the borrower if any
remain after completion of repairs.
Completion of
Repairs All repairs and improvements must be completed with 180 days of the Note date.
Appraisal
The initial appraisal must be made subject to the completed improvements and repairs. All
contracts and addendums must be provided to the appraiser.
A final inspection by the appraiser, with photos, to confirm repairs have been completed will be
required after closing
Underwriting
Process
All repair escrows require underwriting manager approval
The following must be completed:
• Full amount of escrow holdback to be added to fee screen as Misc. Fee line 1319
(escrow holdback)
• The following at close conditions will apply:
o Borrower to sign the Flagstar Escrow Holdback Agreement, Doc. #3655. A
repair escrow to be established for $_____________ for the following
repairs:__________________.
o Final inspection by the appraiser, with photos, to confirm completion of the
following repairs: ___________________. Repairs to be completed within 180
days of closing date. For repairs involving mechanical work such as electrical,
plumbing or heating, proof of permit required prior to escrow disbursement.
Waiver of
Escrow
Account
For one-unit owner occupied and second
homes, an Escrow Account may be waived
with the following requirements being met:
• The improvements are related to
inclement weather or shortage of
building materials, or lack of qualified
labor: and
• The cost does not exceed the lesser
of $6,000 or 2% of the ‘as completed’
appraised value.
If the postponed improvements are related to
a lack of qualified labor, the following must be
documented:
• A copy of the contract signed by
borrower and contractor which shows
the date the remaining work will begin
or the anticipated date of completion,
or
• A letter from the contract indicating
they are not available to begin the
remaining work until a specified date.
Not applicable
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Requirements for Postponed or Incomplete Improvements
Requirement Fannie Mae with Approve Freddie Mac with Accept
Special
Feature Code SFC 263
Annotation of “Incomplete Improvements with
Escrow Account” must be included on the
Transmittal

융자지식196- MIXED-USE PROPERTIES

융자지식196- MIXED-USE PROPERTIES

MIXED-USE PROPERTIES
For both Fannie Mae and Freddie Mac we will accept mixed-use properties, e.g., beauty shops, doctor’s
office, small grocery, etc., as long as the following guidelines are met:
• Property must be a 1-unit property that the borrower occupies as his or her principal residence
• The mix-use of the property must represent a legally permissible use of the property under local
zoning requirements
• The borrowers must be both the owner and the operator of the business
• The property must be primarily residential in nature
• The market value of the property must be primarily a function of its residential characteristics, rather
than the business use or any special business use modifications that were made.
• The mortgaged premises must be residential. We do not purchase mortgages secured by vacant
land or property used primarily for agriculture, farming, or commercial enterprise.
MULTIPLE PARCELS UNDER ONE MORTGAGE
FANNIE MAE
When the security property consists of more than one parcel of real estate, the following requirements
must be met:
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• Each parcel must be conveyed in its entirety.
• Parcels must be adjoined to the other, unless they comply with the following exception:
o Parcels that otherwise would be adjoined, but are divided by a road, are acceptable if
the parcel without a residence is a non-buildable lot, e.g., waterfront property where the
parcel without the residence provides access to the water. Evidence that the lot is nonbuildable must be provided.
 Each parcel must have the same basic zoning, e.g., residential, agricultural
 The entire property may contain only one dwelling unit. Limited additional nonresidential improvements, such as a garage, are acceptable. For example, a
home built across both parcels where the lot line runs under the home is
acceptable.
 The mortgage must be a valid first lien that covers each parcel.
FREDDIE MAC
When the security property consists of more than one parcel of real estate, the parcels must meet the
following conditions:
• Each parcel must be conveyed in its entirety
• Parcels must be adjoined to the other
• Each parcel must be eligible zoning and residential in nature
• Only one parcel may have a dwelling-unit; limited non-residential improvements such as a
garage are acceptable
• The mortgage must be a valid first lien on each parcel
Flagstar may amend the security instrument to include the conditions under which the adjoining lot
subsequently may be released as security for the mortgage. One such condition is that the outstanding
unpaid principal balance of the mortgage must have the same, or better, relationship to the current
appraised value of the property after release of the adjoining lot that the original mortgage amount had to
the original value of the property at the time we purchased or securitized the mortgage. This can be the
result of property appreciation or the borrower making an additional principal payment to reduce the
mortgage balance to the required level.
OIL, GAS, WATER, AND MINERAL RIGHTS
APPRAISAL REQUIREMENTS
If upon inspection of the property the appraiser observes active drilling, fracking, etc., the appraiser
must comment that the active drilling, fracking, etc. does not materially alter the contour of the property,
the usefulness, or value as of the date of the appraisal. If upon inspection of the property the appraiser
does not observe any active drilling, fracking, etc., no action is require by the appraiser.
FINAL TITLE POLICY REQUIREMENTS
The final title policy must include Environmental Protection, ALTA 9 – Restrictions, Encroachments,
Minerals – Loan Policy.
OIL TANKS
Specific to oil tanks located on a residential property, buried or not buried, Flagstar Bank requires
properties with an oil tank to meet the following guidelines:
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• The appraiser must state oil tanks are common to the area and have no adverse effect on
marketability.
• The appraiser must make a statement that he/she detected no evidence of leakage from the oil
tank.
PLANNED UNIT DEVELOPMENTS (PUD)
For both Fannie Mae and Freddie Mac a planned unit development (PUD) is a development that has all of
the following characteristics:
• The individual unit owners own or have a leasehold interest in a parcel of land improved with a
dwelling. This ownership is not in common with other unit owners.
• The development is administered by a homeowners’ association that owns or has a leasehold
interest in and is obligated to maintain property and improvements within the development, i.e.,
greenbelts, recreation facilities, and parking areas, for the common use and benefit of the unit
owners.
• The unit owners have an automatic, non-severable interest in the homeowners’ association and pay
mandatory assessments.
• Zoning is not a basis for classifying a project or subdivision as a PUD.
• Cannot be an ineligible project. Refer to the Ineligible Projects section of the Conventional
Condominium Guidelines
LIABILITY INSURANCE
Liability Insurance is not required for Type E Projects. Liability Insurance will not be required on Type F
Projects if common areas consist of only minimal amenities, such as entrance gates, parking areas,
greenbelts and grass median strips and does not include any structural improvements or amenities
such as recreational facilities and retention ponds.
FLOOD INSURANCE
Refer to Flood Insurance, Doc. #4603 for coverage requirements
For the purposes of these guidelines, a condominium is not considered a PUD. If a condominium unit is
located in a PUD, the lender must comply with all condominium requirements and warranties. If the PUD
unit or any PUD common property is on a leasehold estate, the project must comply with leasehold estate
requirements.
PRESALE
Fannie Mae
Fannie Mae makes a distinction between an established and a new project as follows:
• A Type E PUD Project is an established planned unit development project in which control
of the owners’ association has been turned over to the unit purchasers. Standard property
guidelines apply to an established PUD property.
• A Type F PUD Project is a new planned unit development project, or in some cases, an
existing PUD project that has not had control of the owners’ association turned over to the
unit purchasers:
o The project cannot have been created by the conversion of existing buildings into a
PUD.
o The project must not include any multi-dwelling units.
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A review of the project is not required for a Type E or Type F if the subject property is a detached
dwelling.
Freddie Mac
Freddie Mac has no pre-sale or other additional guidelines pertaining to the nature of the PUD
project.
PRIVATE WELLS
Subject properties with a water source provided by a shared well, with the well located on another property
must be approved by management. A recorded shared well agreement and title commitment must be
submitted for review. The shared well agreement must provide irrevocable water rights to the subject
property.
REO PROPERTIES
UNEXPIRED RIGHTS OF REDEMPTION
Flagstar will not approve and/or purchase any loan having an unexpired right of redemption unless the
purchase agreement, title, and appraisal all show the same seller who is the original mortgagor.
• Title may show lis pendens notices from the bank or mortgagee
• Purchase contract may indicate a short sale

융자지식195- MODULAR, PREFABRICATED, PANELIZED, OR SECTIONAL HOUSING ELIGIBILITY- FANNIE MAE MODULAR HOMES

융자지식195- MODULAR, PREFABRICATED, PANELIZED, OR SECTIONAL HOUSING ELIGIBILITY- FANNIE MAE
MODULAR HOMES

MODULAR, PREFABRICATED, PANELIZED, OR SECTIONAL HOUSING ELIGIBILITY- FANNIE MAE
MODULAR HOMES
Fannie Mae purchases loans secured by modular homes built in accordance with the Uniform Building
Code administered by state agencies responsible for adopting and administering building code
requirements for the state in which the modular home is installed.
PREFABRICATED, PANELIZED, AND SECTIONAL HOMES
Loans secured by prefabricated, panelized, or sectional housing are eligible for purchase. These
properties do not have to satisfy HUD’s Federal Manufactured Home Construction and Safety
Standards or the Uniform Building Codes that are adopted and administered by the state in which the
home is installed. The home must conform to local building codes in the area in which it will be located.
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MODULAR, PREFABRICATED, PANELIZED, ANDSECTIONAL HOUSING REQUIREMENTS
Factory-built housing such as modular, prefabricated, panelized, or sectional housing is not considered
manufactured housing and is eligible under the guidelines for one-unit properties. These types of
properties must:
• be built of the same quality of materials as and assume the characteristics of site-built housing,
• be legally classified as real property, and
• conform to all local building codes in the jurisdiction in which they are permanently located.
The purchase, conveyance, and financing (or refinancing) must be evidenced by a valid and
enforceable first-lien mortgage or deed of trust that is recorded in the land records, and must represent
a single real estate transaction under applicable state law. The lender is responsible for perfecting the
real estate title and obtaining any needed title endorsements before selling the loan to Fannie Mae
when a unit is titled as personal property similarly to manufactured homes.
All factory-built units must be permanently attached to a foundation that meets the standards for local
building codes where the unit will be placed and in accordance with the recommendations prescribed
by the unit’s manufacturer (when applicable). If the unit had axles, wheels, tow hitch, or other hardware
to facilitate ease of transportation to the site, the lender is responsible for ensuring that all such
hardware is removed prior to selling the loan to Fannie Mae.
Fannie Mae affords modular, prefabricated, panelized, or sectional housing homes the same treatment
as site-built housing. Therefore, Fannie Mae does not have minimum requirements for width, size, roof
pitch, or any other specific construction details.
MODULAR CONSTRUCTION TECHNIQUES ON MULTI-UNIT BUILDINGS
Multi-unit buildings such as condos, co-ops, and townhomes may be constructed, in whole or in part,
through the use of modular construction techniques. All buildings must conform to local building codes
in the jurisdiction in which they are permanently located. Units in these buildings are provided the same
treatment as units in multi-unit buildings constructed with site-built techniques.