For lenders selling to FNMA, tax transcripts are part of their required QC so we routinely provide a 4506T, which is only good for 120 days, for signature with the early disclosures. We would order the transcript but go ahead with the closing anticipating receipt of the transcript to have for QC.

However, our vendor recently sent us the following:
Order Cancelled—This order had been sent to the IRS during the shutdown for COVID-19 and we have been waiting for processing. However, it has become apparent that the IRS “missed” or “deleted” thousands of orders that were waiting in their queue. Due to the unpredictable way that they are processing orders, there is no way to determine status on this order. We are cancelling the order WITHOUT CHARGE to you. THEREFORE, if you still need transcripts for this/these borrowers, you MUST place a NEW order(s). We sincerely apologize for the inconvenience, but this is beyond our control.

Curious how others are handling this. Are you going back to the borrowers for an updated form? Has anyone heard that FNMA has made an exception for transcripts ordered during the shutdown period?
I don't want to sweep this under the rug if it's going to come back on me later.

https://selling-guide.fanniemae.com...D-19-FAQs-Quality-Control-06-03-2020.htm

What if I cannot obtain tax transcripts that are required as part of my post-closing QC process?


If verbal or electronic reverifications cannot be completed, lenders can complete the file review without the reverification. However, lenders must:
•internally track all loans that did not have a successful reverification attempt during this time, and
•conduct a special discretionary sample of such mortgages and perform the required reverifications on the sample population upon the expiration of the flexibilities contained in Lender Letter LL-2020-03, Impact of COVID-19 on Originations

As a reminder, the reporting requirements of D1-3-06, Lender Post-Closing Quality Control Reporting, Record Retention, and Audit continue to apply with respect to this special discretionary sample(s).

Reminder: Lenders should prioritize execution of IRS Form 4506-T in the special discretionary sample(s) based on the expiration date of the IRS Form 4506-T.

Thanks, Randy.

My next question would be, if we go the discretionary sample route, would we be obligated to return the fee on those loans that we couldn't/didn't order the transcript on? Seems to me that even tho FNMA is offering somewhat of an out, it would put us in a TRID bind not to just reorder transcripts until we have them, agreed?

If you are charging the borrowers for post closing QC transcripts and then do not do them, I think that might present some issues under RESPA Section 8, especially if these are listed in Section B.