Ginnie Mae is introducing recovery planning requirements for Issuers that are not subject to federal regulation by the agencies listed in Chapter 03, Part 8 §A(3)(a) whose portfolios equal or exceed a remaining principal balance (“RPB”) of $50,000,000,000 ($50 billion) at the end of the calendar year. Covered Issuers with the requisite portfolio size as of December 31, 2024 will be required to prepare and submit recovery plans to Ginnie Mae no later than June 30th, 2025 via email to GNMARecPln@hud.gov. Ginnie Mae is making this change as part of its holistic approach to program governance to assure rapid and orderly servicing transfer in the case of an Issuer’s material distress or failure. These plans must contain all relevant material, as described in MBS Guide Appendix VI-23 of the Ginnie Mae Mortgage-Backed Securities Guide 5500.3, Rev-1 (MBS Guide), including but not limited to the elements described below:
- Corporate structure—Organizational charts; location; key personnel; contact information for the Issuer, any parent or subsidiary; mapping of critical operations and core business lines. Identification of interdependencies within the company and with material entities; counterparties that could have a material impact on business operations; and those to whom the Issuer has pledged MBS collateral and where that collateral is held.
- Information systems--Detailed inventory and mapping of key management information systems and applications; and the process by which supervisory or regulatory agencies could access those systems and applications.
- Recovery planning—Plan to meet the requirements of the Ginnie Mae Guaranty Agreement; Plan to unwind its Ginnie Mae MBS portfolio in a timely and efficient manner; and business continuity plans.
Covered Issuers must demonstrate that they have assessed the challenges that their organizational structure and business activities pose, and that they have taken actions to address and mitigate the related risks. Ginnie Mae will not issue any penalties or punitive actions related to information submitted in the recovery plans. All information provided in the recovery plans will be treated by Ginnie Mae as confidential and will not be publicly released.
Every two years, covered Issuers will be required to update and resubmit their recovery plans or attest that the most recently approved recovery plan remains current. These submissions are due no later than June 30th of the following calendar year. Notwithstanding this requirement, if the covered Issuer makes a material change to its recovery plan between required submissions, covered Issuers must report the change to Ginnie Mae by submitting an updated version of the entire recovery plan, with all changes highlighted, no later than 60 days after making the material change. See MBS Guide Chapter 3 Part 18, § D and Appendix VI-23 for more details.
If you have questions, please contact your Account Executive in the Office of Issuer and Portfolio Management directly.
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