Freddie Mac Single-Family Seller/Servicer Guide Section 9501.3 — Firm selection and retention

Freddie Mac Single-Family Seller/Servicer Guide Section 9501.3 — Firm selection and retention

9501.3: Firm selection and retention (09/10/25) This section contains requirements related to: ■ Selection of firm ■ Retention of firm (a) Selection of firm (i) Servicer selects firm If the Servicer determines that a firm meets the Firm Minimum Requirements specified in Section 9501.2 and all other Guide requirements, then the Servicer must complete and submit a Servicer Selection Form to Freddie Mac via https://www.freddiemacsats.com/Security/Login and receive Freddie Mac’s “no objection” determination before entering into an agreement with a firm to handle Freddie Mac Default Legal Matters. If Freddie Mac requests additional information from the Servicer as part of this process, the Servicer must provide the requested information within the time frame requested by Freddie Mac. Servicers may not rely upon a previous submission of a Servicer Selection Form by another Servicer with respect to a firm that received a “no objection” determination. Each Servicer must: ■ Conduct its own due diligence ■ Submit a Servicer Selection Form; and Freddie Mac Single-Family Seller/Servicer Guide Chapter 9501 As of 09/10/25 Page 9501-15 ■ Receive a “no objection” determination for each firm that the Servicer wishes to retain to handle Freddie Mac Default Legal Matters If a firm practices in multiple jurisdictions, the Servicer must submit a Servicer Selection Form for each jurisdiction for which the Servicer wishes to retain the firm. (ii) Servicer Attorney Tracking System (SATS) registration Servicers must use SATS, an online process, to submit a Servicer Selection Form to Freddie Mac for each law firm selected to handle Freddie Mac Default Legal Matters. To establish access to SATS, Servicers must first register to create a user ID and password at https://www.freddiemacsats.com/Security/Login. After completing the registration process, SATS will allow users to submit the information required in the Servicer Selection Form to Freddie Mac for review. SATS will also allow Servicers to respond to Freddie Mac’s requests for additional information, as necessary, and will allow Servicers to track each submission’s status during the review process. Freddie Mac will not review any Servicer Selection Form completed and submitted to any Freddie Mac e-mail address. Servicers must complete and submit the Servicer Selection Form via https://www.freddiemacsats.com/Security/Login. (iii)Freddie Mac review of Servicer Selection Form After Freddie Mac receives the Servicer Selection Form, Freddie Mac will notify the Servicer via the Servicer’s registered e-mail address with SATS whether Freddie Mac: ■ Objects to the Servicer’s retention of the firm to handle Freddie Mac Default Legal Matters ■ Has no objection to Servicer’s retention of the firm to handle Freddie Mac Default Legal Matters; or ■ Needs additional information or documentation or due diligence to be conducted before deciding whether the firm may be retained. If requested, the Servicer must provide any additional information or documentation to Freddie Mac via https://www.freddiemacsats.com/Security/Login and must conduct any further due diligence requested by Freddie Mac within the time period stated in Freddie Mac’s request. Freddie Mac Single-Family Seller/Servicer Guide Chapter 9501 As of 09/10/25 Page 9501-16 (iv) Freddie Mac’s response to Servicer firm selection (A) Freddie Mac provides a “no objection” response The Servicer must enter into a contract with the firm (if a contract does not already exist) as further specified in Section 9501.3(b) to handle Freddie Mac Default Legal Matters. (B) Freddie Mac provides an “objection” response If the Servicer determines not to retain a particular firm or if Freddie Mac objects to the retention of a particular firm, the Servicer must notify the firm that the firm cannot be hired for Freddie Mac Default Legal Matters. (v) The Servicer decides not to retain firm The Servicer is not obligated to inform Freddie Mac: ■ If the Servicer determines that a firm does not meet the Firm Minimum Requirements; or ■ If the Servicer decides not to retain a firm (vi) Diversity Servicers are reminded that they must be aware of and comply with Freddie Mac’s requirements in Sections 1201.10 and 1301.2. The Servicer must commit to practice the principles of equal employment opportunity and non-discrimination in all its business activities, including the retention and hiring of firms retained pursuant to this section. (b) Retention of firm (i) Servicer contract with firm If the Servicer has not already entered into a contract with a selected firm and Freddie Mac has provided a “no objection” determination, then the Servicer must: ■ Enter into a contract with the firm ■ Notify Freddie Mac when the contract has been executed by updating SATS via https://www.freddiemacsats.com/Security/Login, and ■ Provide a copy of the contract to Freddie Mac, upon request (ii) Freddie Mac limited retention agreement with firm Freddie Mac Single-Family Seller/Servicer Guide Chapter 9501 As of 09/10/25 Page 9501-17 Freddie Mac will enter into a limited retention agreement that sets forth certain key retention provisions with each selected firm for each jurisdiction in which the firm has received a “no objection” determination. (iii)Conflict between Servicer’s contract and limited retention agreements; Servicer’s respective consent The Servicer acknowledges that the limited retention agreement recognizes and reflects a joint attorney-client relationship between the law firm, Freddie Mac and the Servicer, and the Servicer consents to such joint representation. The Servicer consents, in advance, to the selected firm’s representation of Freddie Mac in any Freddie Mac Default Legal Matter that is or might be adverse to the Servicer, and the Servicer further agrees that the firm can use in such representation any information the firm gained in the course of jointly representing the Servicer and Freddie Mac. In the event of any inconsistency or conflict between the terms and conditions of the Servicer’s contract with the selected firm and the terms and conditions of Freddie Mac’s limited retention agreement with the firm, Freddie Mac’s limited retention agreement shall control. 9501.4: Firm training requirements, referrals and prohibitions related to Freddie Mac default legal matters (09/10/25) This section contains requirements related to: ■ Training of firms ■ Referral of Freddie Mac Default Legal Matters to firm ■ Prohibitions related to Freddie Mac Default Legal Matters (a) Training of firms (i) Training prior to referral The Servicer must not refer any Freddie Mac Default Legal Matters to a firm until the Servicer verifies that the firm has executed a limited retention agreement with Freddie Mac and has completed Freddie Mac’s new firm training. A firm is only required to attend Freddie Mac’s new firm training once, regardless of the number of Servicers that select and retain the firm. Freddie Mac Single-Family Seller/Servicer Guide Chapter 9501 As of 09/10/25 Page 9501-18 (ii) Ongoing training The Servicer must ensure that each firm obtains appropriate training to keep the firm apprised of updated Freddie Mac requirements. If the Servicer provides its own standard training and/or other communication materials to a firm, the Servicer must include information regarding Freddie Mac’s requirements. (b) Referral of Freddie Mac Default Legal Matters to firm (i) Requirements prior to referral Prior to referring a Freddie Mac Default Legal Matter to a firm, the Servicer must confirm that the firm is eligible to receive a referral by ensuring that: ■ The firm meets the Firm Minimum Requirements, as specified in Section 9501.2 ■ Freddie Mac has provided a “no objection” determination, as specified in Section 9501.3(a) ■ The firm has executed a contract with the Servicer requiring the firm to comply with all applicable Freddie Mac requirements, as specified in Section 9501.3(b) ■ The firm has executed a limited retention agreement with Freddie Mac, as specified in Section 9501.3(b) ■ The firm has completed Freddie Mac training and any additional Servicer training, as specified in Section 9501.4(a); and ■ There are no conflicts of interest with respect to the retention of the firm and referral of Freddie Mac Default Legal Matters to the firm (ii) Diversification of referrals The Servicer must diversify its referrals of Freddie Mac Default Legal Matters to an appropriate number of firms in each jurisdiction to protect the interests of Freddie Mac and to mitigate the risks related to a high concentration of Freddie Mac files. In selecting firms for referrals, the Servicer must consider firm capacity and management of staff to file ratios. (iii)Bankruptcy and foreclosure matters The Servicer must not refer foreclosure matters directly to trustees listed on the deeds of trust. Note: Refer to Section 9401.3(b) for additional referral requirements. Freddie Mac Single-Family Seller/Servicer Guide Chapter 9501 As of 09/10/25 Page 9501-19 (iv) Providing documentation to firm The Servicer must identify a file as a Freddie Mac Default Legal Matter when sending the file to a firm. When referring a file to a firm, the Servicer must provide all documentation required to initiate a foreclosure. If the firm requests any additional information and/or documentation at any time, the Servicer must provide such requested information and/or documents within three Business Days after receipt of the request or within such earlier time frame, if necessary, to comply with timing requirements under applicable law or court orders and procedures. For any Mortgage that the Servicer refers for foreclosure that is subsequently repurchased by the Servicer, whether voluntarily or involuntarily, the Servicer must notify foreclosure and/or bankruptcy counsel within two Business Days of the completed repurchase. Note: See Chapter 3602 for additional information about repurchases. (v) Contingency plan All Servicers must have a contingency plan in place, either in the form of a standalone document or incorporated into policies and procedures, to redirect new foreclosure and bankruptcy referrals. (c) Prohibitions related to Freddie Mac Default Legal Matters Servicers must not require the firm to perform any foreclosure or bankruptcy-related services on any Freddie Mac Default Legal Matter without compensation. (i) Prohibition against charging for, contracting for or making arrangements to receive benefits for Servicing obligations A Servicer, whether acting directly or through an affiliate, service provider, vendor or outsourcing company, must not directly or indirectly: ■ Charge Freddie Mac or the firm for any foreclosure or bankruptcy-related Servicing obligations, including expenses covered by the Servicing Spread; or ■ Contract or make any arrangements with the firm whereby the Servicer (or its affiliate, service provider, vendor or outsourcing company) receives, directly or indirectly, any financial or other benefits (including, but not limited to, payments, the provision of employees or free or discounted services or products) from the firm in connection with any Freddie Mac Default Legal Matter or Freddie Mac-owned or guaranteed Mortgage Note: Refer to Section 8103.2(b) for additional information on Servicing obligations. Freddie Mac Single-Family Seller/Servicer Guide Chapter 9501 As of 09/10/25 Page 9501-20 (ii) Prohibitions with respect to use of specific vendors, services and/or products The Servicer, and not a service provider, vendor or outsourcing company assisting the Servicer in Servicing defaulted Mortgages, must select the firm to handle Freddie Mac Default Legal Matters, and Servicers must not permit service providers, vendors, outsourcing companies or others to participate in or influence, in any way, the Servicer’s referral process. A Servicer must not, whether acting directly or through an affiliate, service provider, vendor or outsourcing company: ■ Require the firm to contract with or use a particular service provider, vendor or outsourcing company or to use or pay for a particular service or product ■ Refuse to refer a file to the firm because the firm chooses not to contract with or use a particular service provider, vendor or outsourcing company or chooses not to use or pay for a particular service or product; or ■ Charge the firm for any aspect of the file referral or management process, including, but not limited to, the use of connectivity or invoice processing systems (e.g., licensing or subscription fees, “click” charges or any other payment) in order for the firm to provide services necessary to handle Freddie Mac Default Legal Matters (e.g., to prosecute the foreclosure or bankruptcy case) However, a Servicer may require the firm to use certain connectivity or invoice processing systems, provided that the firm is not required to pay for the use of or access to such systems. Note: Refer to Section 9501.5(a) for information about use of and reimbursement for connectivity and invoice processing systems.

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