Fannie Mae 10% Sampling Requirement

Just wondering what population others are using for Fannie Mae's 10% audit sampling QC requirement? Are you including loans kept in-house in the population or just secondary market loan originations?

The requirement for Fannie Mae's QC requirement requires random 10% sampling on "ALL residential mortgage loans a lender originated". The loans must also represent the lender's "overall book of business." This seems like an odd requirement, since the purpose of the LQI is to ensure that Fannie Mae guidelines are met. Why would Fannie Mae want to include in-house loans that aren't subject to the same underwriting requirements?

I have always done a 10% sample of loans sold to FNMA and a 10% sample of loans kept in portfolio.
For us that only works out to around 10-15 loans a month so it is manageable to do both.
I use the same QC checklist for both.

Thanks for your input river girl.