Post-Closing QC Collateral Risk Assessment Analysis (Form 1033) FAQ

By SingleSource | June 30, 2021

In order to answer many of the questions our customers have about the new Post-Closing QC Collateral Risk Assessment Analysis (FNMA Form 1033), we have put together an FAQ. For more information on the form and the new requirements, check out the announcement here.

Question: Does the reporting Form 1033 being Fannie Mae issued need to be completed by a licensed appraiser?

SingleSource Response: No, one of the benefits of this form is that it is acceptable for the collateral risk assessment to be completed by an individual who is not a licensed or certified appraiser. However, the collateral risk assessor or analyst must be competent in appraisal theory and must be able meet the additional (6) FNMA specific qualification requirements.

Question: Why was the process and using the form 1033 for QC collateral risk assessment adopted? 

SingleSource Response: The Fannie Mae Selling Guide Announcement (SEL-2021-04) May 5,2021¹ states the reasoning as follows: “We are updating this policy to better align QC processes with available collateral data and industry-leading collateral tools. The combination of standardized data and Collateral Underwriter® allows for a more robust QC process, which reduces or eliminates the need for a field review in most circumstances. Therefore, the new policy replaces the current appraisal QC requirements with a new collateral risk assessment for all loans selected for a QC review in the random sample.”

Question: What are the specific qualification requirements that a collateral risk assessor or analyst must possess and/or obtain to be qualified to complete the 1033 report form?

SingleSource Response: Per the Selling Guide: Fannie Mae Single Family, May 5, 2021²:

“The collateral risk assessor or analyst must be competent in appraisal theory and must be able to specifically:

• Determine that a property meets eligibility requirements including the LTV, CLTV, and HCLTV ratios;
• Assess appropriateness of comparable sales;
• Assess appropriateness of the data presented in the appraisal report;
• Conclude that the rationale for the reconciliation of value is supported;
• Prescribe corrective actions for defects identified in the appraisal process; and
• Reconcile flags and messages that were identified in Collateral Underwriter (CU) if the property was able to be scored in CU. If the property was not able to be scored in CU then reconcile any known quality messages (messages, alerts, flags) that are reflected in other third-party tools if utilized.”

Lenders must ensure that all property eligibility requirements in the Selling Guide are met; use of the optional 1033 checklist alone does not indicate complete compliance with the Guide.

Question: Is the FNMA 2000 form and desk review being retired and discontinued?

SingleSource Response: No, these products can still be used for a variety of other scenarios. However, regarding the 1033 form, if the lender is unable to complete an adequate assessment or appropriately determine the quality of the origination appraisal, they may order either a desk review or field review from a licensed appraiser.

Question: What is the process if any defects are identified through its collateral risk assessment process results in the value not being supported or the loan being ineligible?

SingleSource Response: Per Fannie Mae’s Selling Guide²: “If the lender determines that the mortgage loan was not eligible as delivered, the lender must advise Fannie Mae of these findings using the self-report functionality in Loan Quality Connect.”

Question: When does the FNMA 1033 form go into effect?

SS Response: According to Fannie Mae – these policy changes are effective immediately. The Form 1033 can be used now.

Question: Is SingleSource qualified and able to complete the Form 1033?

SS Response: Yes, SingleSource has a valuation team of competent analysts schooled in appraisal theory with full understanding of what is required to complete the Form 1033.

Question: What additional information other than the original appraisal needs to be supplied at order placement for assignment completion of the Form 1033?

SingleSource Response: There are several items and information sections that need to be addressed on the Form 1033 that only the client (being a Fannie Mae-approved sellers and servicers) can access. Therefore, the client will need to supply an outside vendor like SingleSource with the following information:

1. A standard SSR on the original appraisal report is required for full report completion. The SSR document should provide the information that an outside vendor would need to complete the Form 1033.
2. Reporting information to be supplied (Only if not showing on the submitted SSR);
   • Confirm that the original appraiser is not on the FNMA – Appraiser Quality Monitoring (AQM) List.
   • Provide CU Risk Score (1.0-5.0)
   • Provide CU review and alert messages noted on the original appraisal report.
3. A copy of the deed or the title, to confirm that the legal description matches the appraisal.
4. Evidence that the conditions were met when a “subject to” appraisal is being reviewed.

Question: Is there a volume limit for ordering the Form 1033 product?

SingleSource Response: No, the Form 1033 can be ordered and placed to your specific needs as an individual product unit or as a bulk compliance order.

Question: What is the TAT and Fee for assignment completion of the FNMA Form 1033?

SingleSource Response: The Form 1033 offers a much faster TAT and considerably lower fees than what we are typically seeing in the market for the Field Reviews and the Desk Reviews, which this form is replacing. For specific TAT and fee information please contact SingleSource using the contact form below, or by contacting your SingleSource Client Relationship Specialist or sales representative.

Sources:

1. Fannie Mae Selling Guide Announcement (SEL-2021-04) – May 5, 2021 https://singlefamily.fanniemae.com/media/25746/display
2. Selling Guide: Fannie Mae Single Family – May 5, 2021
   https://singlefamily.fanniemae.com/media/25726/display#page=1094