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Q: What is the timeline for Post-Closing Quality Control ("QC") audits?
A: Post-closing QC audit timelines vary by Agency:
i. Fannie Mae requires the loan selection to take place within 30 days of closing, the QC audit and rebuttal should be completed within 60 days of the loan selection, and the final report should be issued within 30 days of the rebuttal. Total timeline is 120 days. A lender must notify Fannie Mae within 30 days of confirmation that one or more defects in the loan file results in it being ineligible for delivery to Fannie Mae.
ii. Freddie Mac requires the results of the QC audit be reported in writing to the senior management team within 90 days of the loan selection. Total timeline is 90 days. If a lender determines that post-closing QC findings affect the eligibility of a mortgage sold to Freddie Mac the lender must notify Freddie Mac in writing within 30 days of such determination.
iii. FHA requires the loan selection to take place on a monthly basis, selection must be comprised of loans closed within the prior (1) one-month period, and the review must be completed within 60 days of the end of the prior (1) one month period. The initial findings must be provided to senior management within 30 days of completion of the initial findings report. A lender must issue its final report within 60 days from the date the initial review findings were reported to senior management. Total timeline is 150 days. A lender must report all material findings it is unable to mitigate to FHA no later than 90 days after the completion of the initial findings report.
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