Freddie Mac Single-Family Seller/Servicer Guide Section 1402.4 — eNote custodian requirements

Freddie Mac Single-Family Seller/Servicer Guide Section 1402.4 — eNote custodian requirements

1402.4: eNote custodian requirements (12/17/25) This section contains requirements related to: ■ Becoming a Freddie Mac-approved third-party eNote custodian ■ Notice of significant changes to the eNote Vault System ■ Ongoing reviews ■ Contracting with Seller/Servicer Freddie Mac Single-Family Seller/Servicer Guide Chapter 1402 As of 12/17/25 Page 1402-33 ■ Freddie Mac-approved third-party eNote custodian’s duties to Freddie Mac (a) Becoming a Freddie Mac-approved third-party eNote custodian A Document Custodian who wishes to be approved for eNote custody must contact the Freddie Mac eMortgage Team (eMortgage_Team@FreddieMac.com) to determine its eligibility and obtain Freddie Mac’s prior written approval. As part of Freddie Mac’s review and approval process, Freddie Mac will review the Document Custodian’s eNote Vault System in accordance with the processes described in the table below to assess compliance with requirements specified in Section 1402.2(b). eNote vault system review requirements If the eNote Vault System was not previously reviewed by Freddie Mac (Note: Some of these steps can be performed simultaneously): If the eNote Vault System was previously reviewed by Freddie Mac (https://sf.freddiemac.com/working-with- us/electronic-loan-documents/emortgage- ready-participants#vendors): ■ The Document Custodian must (or cause its System Provider to) provide a demonstration of these Systems for Freddie Mac’s review ■ The Document Custodian must complete testing that includes verification of integration with MERS® eRegistry and eDelivery systems, among other things ■ If using System Provider’s eNote Vault System, the Document Custodian must submit to Freddie Mac an attestation executed by the System Provider’s Chief Technology/Security Officer (or comparable titled officer of the System Provider) using the attestation letter provided by Freddie Mac ■ If using proprietary eNote Vault System, the Document Custodian must submit to Freddie Mac an attestation executed by the Document Custodian’s Chief Technology/Security Officer (or comparable titled officer of Document Custodian) using the attestation letter provided by Freddie Mac ■ The System review process will consist only of testing to verify integration of the Systems with MERS eRegistry and eDelivery systems ■ If significant changes, as detailed in Section 1402.4(b), are made to a Freddie Mac reviewed eNote Vault System: ❑ The Document Custodian must (or cause its System Provider to) provide a demonstration of the modified eNote Vault System for Freddie Mac’s review ❑ The Chief Technology/Security Officer (or comparable titled officer) of Document Custodian (or its System Provider) must execute and submit an attestation letter provided by Freddie Mac ■ Freddie Mac may, at its sole discretion, request additional information concerning the Systems and associated processes and procedures for further analysis Freddie Mac Single-Family Seller/Servicer Guide Chapter 1402 As of 12/17/25 Page 1402-34 eNote vault system review requirements If the eNote Vault System was not previously reviewed by Freddie Mac (Note: Some of these steps can be performed simultaneously): If the eNote Vault System was previously reviewed by Freddie Mac (https://sf.freddiemac.com/working-with- us/electronic-loan-documents/emortgage- ready-participants#vendors): ■ Freddie Mac may, at its sole discretion, request additional information concerning the Systems and associated processes and procedures for further analysis If Freddie Mac, in its sole discretion, determines that the Document Custodian’s eNote Vault System is acceptable and the Document Custodian is otherwise in good standing with Freddie Mac, the Document Custodian will be approved for eNote custody and certification of eMortgages, subject to any terms and conditions set forth by Freddie Mac in Form 1035A and the related third-party agreement. Despite Freddie Mac’s review of the Document Custodian and the eNote Vault System: i. The Document Custodian remains solely responsible and liable for any error, omission, System malfunction and/or negligence caused by the System Provider, eNote Vault System and/or the Document Custodian; and ii. Freddie Mac undertakes no responsibility and/or liability whatsoever in connection with any error, omission, System malfunction and/or negligence caused by the System Provider, eNote Vault System and/or the Document Custodian in connection with the Document Custodian’s use of such eNote Vault System In addition to the requirements set forth below, the Document Custodian must also abide by the requirements of Chapter 2202. (b) Notice of significant changes to eNote Vault System The Document Custodian must provide the Freddie Mac eMortgage Team (eMortgage_Team@FreddieMac.com) with 90 days’ advance written notice and complete the Freddie Mac review process outlined in Section 1402.4(a) in case of any significant proposed change to the Document Custodian’s eNote Vault System. Significant proposed changes to the Document Custodian’s eNote Vault System are those that may materially and adversely affect the performance of the Document Custodian’s eNote Vault System and include, but are not limited to, any change that would be reasonably likely Freddie Mac Single-Family Seller/Servicer Guide Chapter 1402 As of 12/17/25 Page 1402-35 to adversely affect the enforceability of the eNotes or other eMortgage documents or compliance with E-SIGN and/or the UETA. Additionally, if the Document Custodian wishes to use an eNote Vault System that is different from what was communicated at the time of initial approval, the Document Custodian must provide the Freddie Mac eMortgage team with 90 days’ advance written notice and complete the Freddie Mac review process outlined in Section 1402.4(a). (c) Ongoing reviews The Document Custodian must confirm compliance with Freddie Mac information security requirements provided in Chapters 1302 and 1402, as part of completing the Annual Document Custodian Eligibility Certification. Freddie Mac may require an audit of the eNote Vault System conducted in accordance with the Statement on Standards for Attestation Engagements (SSAE) 18 or other comparable type of audit acceptable to Freddie Mac, in its sole discretion. Freddie Mac will provide the Document Custodian with 30 days’ notice before the Document Custodian (and/or the System Provider) is required to provide an SSAE 18 or other comparable type of audit report or information requested by Freddie Mac concerning the Systems and associated processes and procedures, unless such review is being conducted pursuant to Guide Series 1000, 2000 or 3000. A copy of the final audit report must be provided to Freddie Mac within 30 days of its completion. At all times, the Document Custodian’s eNote Vault System must comply with the requirements set forth in Sections 1402.2(b), 1402.2(c) and 1402.5(d). (d) Contracting with Seller/Servicer A Freddie Mac-approved eMortgage Seller/Servicer choosing to use a Freddie Mac-approved third-party eNote custodian must execute: ■ An Addendum to Document Custodial Agreement (Form 1035A) with the Freddie Mac- approved third-party eNote custodian and Freddie Mac; and ■ Any other agreements required by the Guide, including Section 2202.2 The Freddie Mac-approved third-party eNote custodian or Freddie Mac can terminate the Form 1035A in accordance with the provisions set forth in Section 2202.4. Termination of the Form 1035A will not impact or interfere with the continuation of the Tri- Party Agreement (Form 1035), but termination of the Form 1035 will terminate the Form 1035A unless the parties agree otherwise in writing, in advance. (e) Freddie Mac-approved third-party eNote custodian’s duties to Freddie Mac Freddie Mac Single-Family Seller/Servicer Guide Chapter 1402 As of 12/17/25 Page 1402-36 In addition to the requirements set forth in Chapter 2202, the Freddie Mac-approved third- party eNote custodian covenants to Freddie Mac that it will do the following: 1. Accept eNote Authoritative Copy deliveries and Transfers of Location of eNotes coming into their eNote Vault System after validating the Tamper Evident Seal against the MERS eRegistry 2. Accept and store Electronic Custodial Documents in their eNote Vault System or eStorage System 3. Review the eNote per certification requirements set forth in Section 1402.3(b) 4. Maintain additional ancillary paper documents related to the eMortgage in a related Note file and have a cross reference between paper and Electronic documents as required by Section 1402.5(d) 5. Manage the administration of outgoing Transfers of Control and Location on behalf of Freddie Mac and the incoming Transfer of Control requests to Freddie Mac 6. Validate the Tamper Evident Seal, Controller, and Location of the eNotes received through transfers of custody 7. Semi-annually revalidate the Tamper Evident Seal of each eNote against the MERS eRegistry and verify that Freddie Mac is the Controller, and Document Custodian is the Location of the eNotes, and notify Freddie Mac (Loan_Delivery_Funding_Ops@FreddieMac.com) of any issues

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