Back to top
Join us on LinkedIn Follow us on Twitter Like us on Facebook Follow us on Instagram
 
  OCTOBER RESEARCH STORE Already a subscriber? LOG IN
AddControlToContainer_DynamicNavigation5

Conference Coverage

Fannie, Freddie QC experts discuss loan monitoring, source of loan defects

Email A Friend Printer Friendly Version
0 comments
Conference Coverage
Monday, November 3, 2025

Quality control (QC) experts from Fannie Mae and Freddie Mac shared insights about the trends they are seeing among performing and non-performing loans while speaking at the Mortgage Bankers Association’s (MBA) 2025 Compliance and Risk Management Conference.

MBA Chief Economist Mike Fratantoni facilitated the discussion, which featured Fannie Mae Senior Director, Loan Quality Compliance Duane Gilkison and Freddie Mac Senior Director, Quality Control Stephen Nally.

More than 99 percent of loans reviewed by Fannie Mae in the first two quarters of 2025 were performing loans, they noted. The two companies have taken slightly different approaches to strengthen their early defect detection capabilities, improve data analytics and utilize artificial intelligence (AI) and machine learning (ML) to help prevent both fraud and performance deterioration.

Random, targeted sampling rates

Fannie Mae and Freddie Mac have similar core quality control objectives with some nuanced differences in sampling approaches. Both use random and targeted sampling with a focus on performing loan samples — stratified based on their largest customers — and track defect rates across multiple categories.

Nally explained Freddie Mac’s method emphasizes performing loan (PL) samples over non-performing loan (NPL) samples, particularly when assessing emerging new products or policy changes. The company recently expanded its PL repurchase alternative pilot program to include more than 500 sellers.

“Our PL targeted sample is used to evaluate the effectiveness of a new product or policy change,” Nally said. “We also use this sample when we see emerging issues and need to take a deeper look and the feedback from this sample is used by internal groups such as credit policy to adjust policies if necessary.”

Gilkison described Fannie Mae’s sampling methodology as a bit more granular, relying on supplemental random samples to ensure coverage across the entire delivering lender base, which helps when assessing loan quality. Random sampling provides a broad measure of portfolio quality, while targeted samples focus on loans flagged by data analytics as higher risk, he said.

“For our random sample, we sample it within the three weeks of the acquisition month closing out, and we have our statistically valid defect rate probably before you do,” Gilkison told Fratantoni, noting Fannie Mae had already begun sampling work for its September portfolio. The QC team will then stratify that data into subgroups to provide a detailed perspective on which quality issues are having the most notable effects on the overall defect rate among loans purchased by the enterprise.

Targeted samples utilized by Fannie Mae are based on data indicators pointing to potential quality issues, he explained.

“When the defect rate moves either up or down, people always ask questions,” Gilkison said. In discussing the random sample he stated, “If you don’t have some more granular cuts of that data, at least for the size of the book we have, it’s hard for us to really pinpoint what can be driving defect rates. So, for our largest customers, we do have a specific, statistically balanced slice. Outside of those larger customers, we do other customer groupings and bigger buckets so that we have some visibility into what drives that defect rate.”

He credited Candace Kubida, Fannie Mae’s senior director of loan quality, for her work disseminating articles detailing the enterprise’s findings on the most prevalent types of defects affecting loan performance, repurchase data and emerging risks.

Top defect drivers

Among the most prevalent defect categories tracked by the GSEs over the first two quarters of the year, half were income-related. These included incorrect rental income/loss calculations and incorrect base income calculations.

However, the top source of loan defects was one that has also been the most heavily discussed in the news cycle — misrepresentation of occupancy.

Occupancy discrepancies are typically not the result of attempted fraud and the best way for a borrower or a lender to prove that is through documentation.

“Our defects are misrepresentation defects, meaning the facts have been misrepresented,” Gilkison explained. “We look at those on a case-by-case basis. Sometimes we’ll see where a borrower closed on a loan and got relocated for work. That happens. And you have documentation from your employer that you got relocated. There would be documentation for a change of circumstances like that. We also have people who decide after closing that they don’t like the house. Well, that’s not a change in circumstances.”

The bottom line for the GSEs when looking into defects is determining the right outcome, he said. Typical fraud scenarios include:

  • Borrowers claiming owner occupancy while intending to rent the property
  • Misrepresenting reasons for property changes
  • Listing properties for rent shortly after closing

The GSEs’ strategies for detecting these misrepresentations rely on a mix of traditional verification practices and advanced analytics, including reviewing transactions with borrowers substantially buying-down in price, checking online rental listings, analyzing inconsistencies in property data, validating insurance policies and examining public property records.

The majority of defects involving occupancy misrepresentation occur when borrowers claim owner-occupancy status for a property they intend to use as a rental property. These incidents become apparent when these buyers misrepresent the reasons behind property changes or list these homes for rent soon after closing.

Both organizations have emphasized to lenders they should shift their QC insights earlier in the loan origination process, using data and technology to identify potential issues before loan closing. Concurrently, they are both also exploring ways to apply new technologies to improve loan quality, reduce fraud and create more efficient processes.

Recognizing the potential to make their defect detection processes more efficient, Freddie Mac is investing in technological modernization by upgrading its core QC systems, including its AI-powered tool for conducting property condition assessments. Gilkison described Fannie Mae’s work in applying AI to its work to standardize repurchase letter writing, while also using machine learning to analyze loan performance patterns and develop tools that can flag potential issues faster.

Today's other top stories
21st Century ROAD to Housing Act becomes law without president’s signature
Experts analyze CFPB’s request for information on TRID rule
How to successfully mentor future women leaders
Court considers validity of ‘injury’ claim in RESPA suit
FHFA suggests legislation to promote ‘safe and sound’ oversight


COMMENT BOX DISCLAIMER:
October Research is not responsible for the comments posted on its websites by readers. We will do our best to remove comments that include profanity or personal attacks or other inappropriate comments.
Comments:

Be the first to leave a comment.

Leave your comment
Please enter a comment.
CAPTCHA Validation
CAPTCHA
Code:
Please enter the word displayed in the image above. Please enter the word displayed in the image above.
: 
Please enter your name.
: 
Please enter your email address.
This field must contain a valid email address.
Your Email is for reporting purposes only. It will NOT be displayed.
Popularity:
This article has been viewed 768 times.

Monthly Newsletter

RESPA News Monthly
July 2026

Cover Story:

RESPert Marx Sterbcow speaks on MLS changes, RESPA compliance


News by Topic   News by Edition   Reports   Events   Subscribe
All Rise
Case Law
Enforcement Update
Industry News
Legislation
Regulatory News
The Week in Washington
The TRID Journey
TILA News
 
 
RESPA News Monthly
May 2026
RESPA News Monthly
June 2026
RESPA News Monthly
July 2026
Archives
 
Housing Inventory Solutions
2026 State of the Industry
Adapting to NAR Settlement's New Realities
Real Estate Compliance Outlook
The ABCs of RESPA
Fair Lending
Archives
 
 
National Settlement Services Summit (NS3)
Women's Leadership Summit (WLS)
Webinars
 
Subscriptions
Free Email Updates
Try a Free Edition
Library       RESPA Defined   About   Other Publications
NAR Settlement Resources
Affiliated Compliance
Blog - Tuesdays with Mary
Case Law
CFPB Guidance Documents
Enforcement Documents
Federal and State Legislation
Federal Register Notices
HUD's FAQ's - General
HUD's RESPA final rule FAQs
 
Keys to Real Estate Podcast
Model Disclosure Forms
Other Guidance Documents
Position Papers
Proposed Disclosure Forms
Proposed Rules and Regulations
Settlement Agreements
Statements of Policy
Studies and Proposals
 
Timeline of revisions
Disclosure requirements
Prohibited practices
RESPA enforcement
Dodd-Frank Amendments
Current Issues
The RESPA Statute
 
RESPA News
Contact / Editors
Advertise
Request a Media Kit
Social Media
Are You An Expert?
Subscriber Agreement
 
The Title Report
The Legal Description
Dodd Frank Upate
Copyright © 2005-2026 RESPA News
An October Research, LLC publication
3046 Brecksville Road, Suite D, Richfield, OH 44286
(330) 659-6101, All Rights Reserved
www.respanews.com | Privacy Policy
VISIT OUR OTHER WEBSITES
> Dodd Frank Update
> The Legal Description
> The Title Report
> NS3 The Summit
> Women's Leadership Summit
> October Research, LLC
> The October Store


Loading... Loading...
12 USC Section 2605 or Section 6 is titled Servicing of mortgage loans and administration of escrow accounts. It pertains to qualified written requests, notices of transfer of servicing and the administration of escrow accounts.
An arrangement that involves a person who is in a position to refer business as part of a real estate settlement service and who has an interest in a settlement services provider.

In the arrangement, the person, who has either an affiliate relationship with or a direct or beneficial ownership interest of more than one percent in a settlement services provider, directly or indirectly refers business to that provider or influences a consumer to select that provider.
An arrangement that involves a person who is in a position to refer business as part of a real estate settlement service and who has an interest in a settlement services provider.

In the arrangement, the person, who has either an affiliate relationship with or a direct or beneficial ownership interest of more than one percent in a settlement services provider, directly or indirectly refers business to that provider or influences a consumer to select that provider.
A mortgage disclosure that lists all estimated charges and fees associated with your loan. In addition to fees and charges, it will list your loan amount, mortgage rate, loan term and estimated monthly payment. Your escrows due at closing for insurance and taxes will also be outlined. Mortgage lenders are legally required to provide a GFE within three days of receiving your application.
A mortgage disclosure that lists all estimated charges and fees associated with your loan. In addition to fees and charges, it will list your loan amount, mortgage rate, loan term and estimated monthly payment. Your escrows due at closing for insurance and taxes will also be outlined. Mortgage lenders are legally required to provide a GFE within three days of receiving your application.
Under RESPA Section 2605(e)(1)(B), a qualified written request is a written correspondence that includes: 1) the name and account of the borrower, or has enough information to allow the servicer identify that information; and 2) a statement of the reasons for the belief of the borrower that the account is in error or provides sufficient detail to the servicer regarding other information sought by the borrower.

A QWR cannot be written on a payment coupon or other payment medium supplied by the servicer.
Under RESPA Section 2605(e)(1)(B), a qualified written request is a written correspondence that includes: 1) the name and account of the borrower, or has enough information to allow the servicer identify that information; and 2) a statement of the reasons for the belief of the borrower that the account is in error or provides sufficient detail to the servicer regarding other information sought by the borrower.

A QWR cannot be written on a payment coupon or other payment medium supplied by the servicer.
12 USC Section 2609 or Section 10 is titled Limitation on requirement of advance deposits in escrow accounts. It governs escrow accounts including notifications and statements to borrowers. Section 10 also sets out penalties for those who violate the section.
RESPA Section 3 provides that a thing of value includes any payment, advance, funds, loan, service or other consideration

Regulation X says thing of value includes: monies, things, discounts, salaries, commissions, fees, duplicate payments of a charge, stock, dividends, distributions of partnership profits, franchise royalties, credits representing monies that may be paid at a future date, the opportunity to participate in a money-making program, retained or increased earnings, increased equity in a parent or subsidiary entity, special bank deposits or accounts, special or unusual banking terms, services of all types at special or free rates, sales or rentals at special prices or rates, lease or rental payments based in whole or in part on the amount of business referred, trips and payment of another person’s expenses or reduction in credit against an existing obligation.
A form used by a settlement or closing agent itemizing all charges imposed on a borrower and seller in a real estate transaction. This form represents the closing transaction and provides each party with a complete list of incoming and outgoing funds. RESPA requires the HUD-1 to be used as the standard real estate settlement form in all transactions in the U.S. involving federally related mortgage loans.
Featuring:
  • Delivery 3X a week plus breaking news as it happens
  • Comprehensive title insurance industry news
  • Recent acquisitions, mergers, real estate stats
  • Exclusive in-depth coverage of the industry's hottest stories
Featuring:
  • Delivery 2X a week plus breaking news as it happens
  • Comprehensive Dodd-Frank coverage
  • The latest information from the CFPB
  • Full coverage of Congressional hearings
  • Updates on all agency actions
  • Analysis of controversial provisions
  • Release of newest studies and reports
Sign up today and...
  • Be one of the first to know where NS3 is being held
  • Learn about NS3 speakers and sessions
  • Save on registration with Super-Early Bird rates
  • Discover the networking opportunities NS3 offers
  • Find out if CE credits will be offered for your area
  • And much more
Featuring:
  • Delivery 2X a week plus breaking news as it happens
  • Preview the latest RESPAnews.com Top Story
  • RESPA related headline news
  • Quote of the Week
Featuring:
  • Delivery 2X a week plus breaking news as it happens
  • Legal, regulatory and legislative information impacting the settlement services industry
  • News from HUD, Congress, state legislatures and other regulatory agencies
  • Follow the lobbying efforts of all the major national real estate services organizations.
Featuring:
  • Delivery 2X a week plus breaking news as it happens
  • The industry's only full-time newsroom
  • Relevant, up-to-date appraisal industry news
  • Covering the hottest stories and industry trends
NEWS BY TOPIC
NEWS BY EDITION
REPORTS
WEBINARS
EVENTS
LIBRARY
FREE EMAIL NEWS
ABOUT
SUBSCRIBE
All Rise
Case Law
Conference Coverage
Enforcement Update
Industry News
Legislation
Regulatory News
This Week in Washington
The TRID Journey
TILA News
Current Edition
June 2026
May 2026
April 2026
Archives
NEW Housing Inventory Solutions
2026 State of the Industry
NAR Settlement's New Realities
Real Estate Compliance Outlook
The ABCs of RESPA
Archives
NEW Next-Level Leadership
2026 Economic Outlook Series
Life After RESPA
Evolving Realtor Relationships
FinCEN Real Estate Report Demo
2026 Industry and Regulatory Outlook
RESPA Review: Navigating Multi-level Oversight
Evolving Technology
AI-Driven Innovation
FinCEN's Residential Rule Explained
Webinar Archives
National Settlement
Services Summit (NS3)
Women's Leadership
Summit (WLS)
Housing Inventory & Attainability Watch
Podcast - Keys to Real Estate
NAR Settlement Resources
Blog - Tuesdays with Mary
Cyber Solutions Showcase
Executive Interview Series
eClosing Solutions Showcase
RESPA DEFINED
Affiliated Compliance
Case Law
Disclosure Forms
Enforcement
Federal and State Legislation
Guidance Documents
HUD's FAQ's - General
HUD's RESPA final rule FAQs
In-Depth Reports
Position Papers and Studies
Rules and Regulations
Timeline of revisions
Disclosure requirements
Prohibited practices
RESPA enforcement
Dodd-Frank Amendments
RESPA Glossary
Current Issues
The RESPA Statute
Model Disclosure Forms
Proposed Disclosure Forms
Enforcement Documents
Settlement Agreements
CFPB Guidance Documents
Other Guidance Documents
Statements of Policy
Position Papers
Studies and Proposals
Federal Register Notices
Proposed Rules and Regulations
RESPA News
Contact Us
Advertise
Request a Media Kit
Social Media
Are You An Expert?
Subscriber Agreement
Try a Free Edition