Freddie Mac Single-Family Seller/Servicer Guide Section 1301.2 — Compliance with applicable law

Freddie Mac Single-Family Seller/Servicer Guide Section 1301.2 — Compliance with applicable law

1301.2: Compliance with applicable law (12/17/25) This section contains requirements related to: ■ Seller/Servicer obligations ■ Office of Foreign Assets Control (OFAC) screening; notice of OFAC match ■ Anti-money laundering (AML) compliance; reporting AML non-compliance and Suspicious Activity ■ FHFA Suspended Counterparty Program ■ Seller lending practices ■ Servicer-maintained fair lending data elements ■ Servicer responsibility for incident response program and notice of an incident ■ Servicer diversity practices – minority, women and disabled inclusion ■ Servicer adverse action notices Freddie Mac Single-Family Seller/Servicer Guide Chapter 1301 As of 05/06/26 Page 1301-2 ■ Repurchase requests related to compliance with laws representations and warranties ■ Address confidentiality programs (ACPs) (a) Seller/Servicer obligations The Seller/Servicer agrees to comply with all applicable federal, State and local laws, ordinances, regulations, orders and regulator guidance (collectively, “Applicable Laws”), including, without limitation and as amended, the following Applicable Laws: ■ Title VI of the Civil Rights Act of 1964 ■ Title VIII of the Civil Rights Act of 1968, as amended ■ Section 527 of the National Housing Act ■ The Equal Credit Opportunity Act ■ The Fair Credit Reporting Act ■ All Applicable Laws governing consumer protection, data privacy and/or the safeguarding of Borrower personal information including, without limitation, the Gramm-Leach-Bliley Act ■ Executive Order 11063, Equal Opportunity in Housing, issued by the President of the United States on November 20, 1962 ■ The foreign assets control regulations, 31 C.F.R. Chapter V, as amended, and any authorizing legislation or executive order relating thereto, as administered by OFAC within Treasury (collectively “OFAC Regulations”) ■ The Bank Secrecy Act, the Money Laundering Control Act and Title III of the USA PATRIOT Act and the Anti-Money Laundering Act of 2020 ■ Section 5 of the Federal Trade Commission Act and similar laws that prohibit unfair or deceptive acts or practices ■ The Truth in Lending Act ■ The Real Estate Settlement Procedures Act ■ The Fair Debt Collections Practices Act ■ The Homeowners Protection Act of 1998 Freddie Mac Single-Family Seller/Servicer Guide Chapter 1301 As of 05/06/26 Page 1301-3 ■ Judicial and professional rules of conduct governing discussions with opposing parties in litigation when represented by counsel (e.g., solicitation of delinquent Borrowers in bankruptcy or Borrowers engaged in litigation with the Servicer) ■ The U.S. Bankruptcy Code ■ The Electronic Signatures in Global and National Commerce Act, as enacted by the United States government (“E-SIGN”) ■ The Uniform Electronic Transactions Act, as enacted by the applicable State (“UETA”) unless superseded by E-SIGN Without limiting the preceding provisions of this Section 1301.2, the Seller/Servicer must comply with and make such disclosures to Borrowers and other individuals as are required by, and must otherwise comply with, the requirements of applicable State privacy and consumer protection laws, including, without limitation (i) the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”), and (ii) similar State laws and regulations now existing or that may be effective in the future. The Seller/Servicer certifies that it is and will continue to be aware of the requirements of such laws and regulations and covenants that it will comply with their requirements and restrictions. In addition, upon Freddie Mac’s request, the Seller/Servicer must cooperate with Freddie Mac in connection with responding to and complying with consumer requests and other requests received by Freddie Mac or on behalf of persons who wish to exercise their rights under the CCPA and similar State laws and regulations. The Seller/Servicer’s obligation to comply with the requirements of the applicable State privacy and consumer protection laws, as well as to cooperate with Freddie Mac, will survive the termination of the Seller/Servicer’s right to sell or service Mortgages pursuant to the Guide. This obligation lasts for the greater of: ■ The life of the subject Mortgage(s) plus 7 years ■ The expiration of applicable retention requirements pursuant to Applicable Laws ■ The period until the Seller/Servicer lawfully destroys the Mortgage files or Freddie Mac information in the Seller/Servicer’s possession and certifies the destruction in compliance with Section 1301.3 The Seller/Servicer agrees to indemnify and hold Freddie Mac harmless from and against all claims, judgments, losses, costs and expenses incurred by Freddie Mac arising out of the Seller/Servicer’s violation of any Applicable Law. Freddie Mac Single-Family Seller/Servicer Guide Chapter 1301 As of 05/06/26 Page 1301-4 The Seller/Servicer agrees and acknowledges that it cannot assume that, because it complies with all applicable Freddie Mac requirements, that the Seller/Servicer therefore complies with all Applicable Laws. (b) OFAC screening; notice of OFAC match Seller/Servicers must comply with OFAC Regulations and must maintain a compliance program that establishes policies and procedures for complying with OFAC Regulations. The OFAC compliance program must include: ■ Clear policies and procedures ■ Periodic and on-going screening against the list of Specially Designated Nationals and Blocked Persons (“OFAC SDN List”) ■ Process for investigating and escalating potential matches, blocking and rejecting transactions and managing blocked accounts ■ Record retention requirements ■ System of internal controls ■ Independent testing ■ Documented training program Sellers must screen each Borrower and Guarantor against OFAC’s most recent OFAC SDN List prior to delivery to Freddie Mac. If a Borrower or Guarantor is on the OFAC SDN List, the Mortgage is ineligible for sale to Freddie Mac. The Servicer must periodically screen the Mortgages that it services for Freddie Mac against the OFAC SDN List. Such screening must occur on a periodic and ongoing basis and, when there are updates to the OFAC SDN List, be based on the Servicer’s OFAC compliance program and be commensurate with the Servicer’s OFAC risk profile (i.e., Servicers must screen Freddie Mac Mortgages with at least the same frequency as they do their own portfolio). If a valid match is identified, the Servicer must notify Freddie Mac via e-mail within 24 hours of identifying to discuss potential changes to the Servicing of the associated Mortgage, which may include, but are not limited to, the blocking and/or segregation of Mortgage-related funds and ceasing certain Servicing-related activities (see Directory 1). Such e-mail notification must include: ■ Freddie Mac loan number ■ Borrower name Freddie Mac Single-Family Seller/Servicer Guide Chapter 1301 As of 05/06/26 Page 1301-5 ■ Name, title, e-mail address and telephone number for the point of contact at the Servicer who will be able to discuss the OFAC SDN List match Upon receipt of the notice, a representative from Freddie Mac will contact the Servicer to discuss the OFAC SDN List match and any next steps. Freddie Mac may require the Servicer to provide additional documentation or information regarding the OFAC SDN List match. Notifying Freddie Mac of a confirmed match against the OFAC SDN List does not relieve the Servicer of any of its responsibilities under OFAC Regulations. (c) AML compliance; reporting AML non-compliance and Suspicious Activity Seller/Servicers subject to the AML provisions of the Bank Secrecy Act must establish and maintain a compliance program that ensures compliance with all applicable provisions of the Bank Secrecy Act and implementing federal regulations. Seller/Servicers must, as permitted by law, notify Freddie Mac (see Directory 1) within seven Business Days of confirmation of any instances of the Seller/Servicer’s own non- compliance or compliance failure related to the AML requirements of the Bank Secrecy Act, the Money Laundering Control Act, Title III of the USA Patriot Act, the Anti-Money Laundering Act of 2020 and applicable implementing federal regulations. Seller/Servicers, including those not subject to the AML provisions of the Bank Secrecy Act, must establish and maintain a program designed to detect and report Suspicious Activity in the origination, delivery or Servicing of Mortgages delivered to Freddie Mac. The program must include: ■ A designated employee responsible for overseeing the program ■ Policies, procedures and internal controls designed to detect Suspicious Activity and report to Freddie Mac (see Directory 1) in accordance with Section 3201.2 ■ A documented training program with training delivered to appropriate employees at the time of hire and at least annually thereafter ■ Independent testing to monitor and maintain an adequate program (d) FHFA Suspended Counterparty Program Seller/Servicers must comply with the requirements set forth in Section 3101.2 applicable to FHFA’s Suspended Counterparty Program. (e) Seller lending practices Freddie Mac Single-Family Seller/Servicer Guide Chapter 1301 As of 05/06/26 Page 1301-6 The Seller must employ business practices that promote fair lending. (f) Servicer-maintained fair lending data elements Servicers must maintain the following fair lending data elements for all Freddie Mac Mortgages originated on or after March 1, 2023, provided they were obtained during the origination process: ■ Race of Borrower(s) ■ Age of Borrower(s) ■ Ethnicity of Borrowers(s) ■ Gender of Borrower(s) ■ Preferred language of Borrower(s) These data elements must be stored in a format that can be searched, queried and transferred. For each Transfer of Servicing on or after March 1, 2023, if the fair lending data was obtained during the origination process and is available, the Transferor Servicer must transmit the fair lending data listed above to the Transferee Servicer. Upon Transfer of Servicing, the Transferee Servicer must begin to maintain this data in accordance with the above requirements. As of the Effective Date of Transfer, the Transferee Servicer must begin to maintain this data in accordance with the above requirements. Note: In the event of a future Transfer of Ownership or assumption of the Mortgage, Servicers may, but are not required to, update these data elements. (g) Servicer responsibility for incident response program and notice of an incident Servicers must develop and maintain a “Response Program” consistent with the requirements of the Interagency Guidance on Response Programs for Unauthorized Access to Customer Information and Customer Notice (see 12 CFR Parts 208 and 225) and Freddie Mac’s requirement for an incident response plan pursuant to Section 1302.2(b)(xv). The Servicer’s obligation to maintain a response program and provide notice of an Incident pursuant to Section 1302.5 must survive the termination of the Seller/Servicer’s right to sell or service Mortgages pursuant to the Guide and must continue for as long as the Servicer has possession of Mortgage files or Freddie Mac information. If the Servicer knows or believes or has reasonable information from which to know or believe, or a cybersecurity professional could reasonably conclude from the circumstances Freddie Mac Single-Family Seller/Servicer Guide Chapter 1301 As of 05/06/26 Page 1301-7 and available information, that there may have been an Incident (as defined in Section 1302.5(a)) that compromises the security, confidentiality, availability, integrity or privacy of Freddie Mac confidential information or Protected Information maintained by the Servicer or in its possession or control or any other information about one or more Borrowers or other individuals that is the subject of any state breach notification law, and if that Incident is related to Mortgages owned or guaranteed by Freddie Mac, the Servicer must comply with the notification requirements under Section 1302.5. If the Servicer determines not to send notices to any Borrowers and/or other individuals affected by a certain Incident, the Servicer must provide written notice to Freddie Mac that includes a rationale and explanation for not sending notice to all affected Borrowers and other individuals as soon as practicable after the Incident. Notwithstanding the Servicer’s determination not to provide such notices, Freddie Mac may direct the Servicer to provide notices to the affected Borrowers at the Servicer’s expense. Following the termination of the Seller/Servicer’s right to sell or service Mortgages, the Servicer continues to be obligated to notify Freddie Mac of an Incident during such time as the Servicer retains the Mortgage files or Freddie Mac information. The Seller/Servicer agrees to indemnify and hold Freddie Mac harmless from and against all claims, judgments, losses, costs and expenses incurred by Freddie Mac arising out of any Incident. If the Servicer intends to refer to Freddie Mac in any notices it sends to Borrowers and others on Mortgages whose information was affected by the Incident, the Servicer must notify Freddie Mac within a reasonable time prior to sending those notices. Freddie Mac must have the opportunity to review the content of the notices prior to their delivery. As further described in Section 1302.5, in connection with all Incidents, the Servicer must cooperate with Freddie Mac, including, without limitation, by providing all requested information and assistance, such as: ■ Enabling Freddie Mac to comply with its legal obligations ■ Providing technical or forensics information to determine the extent of the Incident ■ Supplying other information and assistance to identify, evaluate and manage any issues arising out of the Incident as Freddie Mac deems necessary or advisable (h) Servicer diversity practices – minority, women and disabled inclusion In accordance with regulations adopted by FHFA, 12 C.F.R. Pt. 1207, pursuant to the Housing and Economic Recovery Act of 2008, 12 U.S.C. § 4520 (“HERA”), each Seller/Servicer will: Freddie Mac Single-Family Seller/Servicer Guide Chapter 1301 As of 05/06/26 Page 1301-8 1. Practice the principles of equal employment opportunity and non-discrimination in all its business activities 2. Contractually require each subcontractor that the Servicer engages to provide services or goods to Freddie Mac to practice the principles of equal employment opportunity and non-discrimination in all its business activities, and 3. Upon request, provide Freddie Mac with information and appropriate certifications regarding: ■ The diversity status of the Seller/Servicer ■ The diversity status of subcontractors the Seller/Servicer engages to originate Mortgage under the Purchase Documents and/or provide services or goods to Freddie Mac with respect to Servicing under the Purchase Documents ■ The amounts Freddie Mac pays to the Servicer for Servicing under the Purchase Documents ■ The amounts the Servicer pays to subcontractors to provide services or goods to Freddie Mac with respect to Servicing under the Purchase Documents, and ■ Any other information Freddie Mac requests to comply with HERA and applicable diversity and inclusion regulations (i) Servicer adverse action notices Below are Servicer responsibilities when Freddie Mac participates in evaluating a Borrower for a workout or relief option that results in a denial: ■ If Freddie Mac participated in evaluating a Borrower for a workout or relief option that is not approved, Freddie Mac will provide the reasons for denial ■ If Freddie Mac participated in the decision and if the decision gives rise to an obligation to provide the Borrower with a notice or notices under applicable law, including, but not limited to, adverse action notices required by the Equal Credit Opportunity Act or the Fair Credit Reporting Act, then the Servicer must provide such notices to the Borrower on behalf of Freddie Mac ■ In these cases, the notices provided by the Servicer to the Borrower must identify both the Servicer and Freddie Mac as having participated in the evaluation of the workout or relief option and the decision to deny the request. (j) Repurchase requests related to compliance with laws representations and warranties Freddie Mac Single-Family Seller/Servicer Guide Chapter 1301 As of 05/06/26 Page 1301-9 Freddie Mac will only issue a repurchase request for Seller violations of law that: ■ Could be expected to impair Freddie Mac’s or its Servicer’s ability to enforce the Note or Mortgage ■ Impose assignee liability, or ■ Are found to have been violations of, or if Freddie Mac has made a finding based on the facts available to Freddie Mac that a violation may have occurred of, one or more of the following laws or related regulations: ❑ OFAC Regulations ❑ The Fair Housing Act ❑ Anti-discrimination provisions of the Equal Credit Opportunity Act (ECOA) ❑ The Securities Exchange Act of 1934, and ❑ Unfair, deceptive, or abusive acts or practices under federal and State laws (UDAAP) With respect to UDAAP, Freddie Mac will take into consideration published federal and State announcements of interpretations as well as all published judicial and administrative decisions and will not enforce a repurchase if the matter can be cured by remediation to the injured party and the Seller makes such remediation. However, three or more years after the Settlement Date of a Mortgage, Freddie Mac may not seek repurchase on UDAAP grounds regarding a specific practice unless: ■ A lender self reports ■ A federal or State enforcement authority has indicated, asserted or claimed that such practice violates or may violate UDAAP ■ A federal or State court has held that a specific practice violates UDAAP A repurchase demand based on a compliance with law violation by the Seller will include supporting facts and findings made by Freddie Mac in the course of considering the facts and circumstances before it. Freddie Mac’s determination that a violation has occurred must be consistent with the facts and circumstances provided by the Seller and any other information obtained by Freddie Mac as part of its evaluation of the situation. When Freddie Mac issues a repurchase request to the Seller in connection with a failure to comply with laws and there is pending litigation underway involving that same issue or a Freddie Mac Single-Family Seller/Servicer Guide Chapter 1301 As of 05/06/26 Page 1301-10 government agency with authority to make a determination regarding the issue has publicly stated that it is reviewing the issue, the Seller will not be required to repurchase until 30 days after the litigation has been dismissed, settled or concluded at trial in an adjudication or the governmental agency has made a final determination, as applicable (collectively, “the Resolution”). After the Resolution, the Seller may request that Freddie Mac review the appropriateness of the repurchase request in light of the Resolution. Freddie Mac will withdraw the repurchase request where appropriate. Freddie Mac will not issue a repurchase request to the Seller based on violations of the ability to repay provisions under the Truth in Lending Act (“ATR”) unless a court or regulator concludes the Mortgage did not comply with ATR. This section does not limit Freddie Mac’s rights to issue repurchase requests for Servicer breach of its obligations regarding compliance with Applicable Laws. (k) ACPs A Borrower may be a participant in a State-sponsored ACP that provides the Borrower with a substitute mailing address to be used instead of the Borrower’s home address for all mail correspondence. Sellers must comply with the applicable federal and State laws related to ACPs. Within five Business Days after the Funding Date of any Mortgage for which the Borrower is a participant in an ACP, the Seller must provide the following information to Freddie Mac at the e-mail address Loan_Delivery_Funding_Ops@FreddieMac.com: ■ Freddie Mac loan number ■ Borrower name ■ Borrower ACP mailing address (including, when applicable, any lot number or required uniquely identifiable number) Freddie Mac will use the provided substitute ACP mailing address when required by law for mailing correspondence to the Borrower, such as the Mortgage transfer disclosures required under the Truth in Lending Act. Freddie Mac Single-Family Seller/Servicer Guide Chapter 1301 As of 05/06/26 Page 1301-11

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