On non-seller (e.g., refinance) transactions, do the GSEs require the use of the “Alternate†form, Form H-25(E), published by the CFPB? (Refer to Federal Register vol. 78, No. 251 on p. 80187).
Both GSEs require use of form H-25(E) for all refinance transactions on the loans they acquire (refer to Federal Register website for additional details on this regulation). If a non-seller transaction is submitted on the “Model†form, the GSE collection systems will issue warning messages at the outset of the mandate and will not prevent a submission from being considered “successful.†However, the warnings may be changed to a hard stop at a later date. More information will be provided by the GSE regarding the timeframe for these hard stops.
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