# VALERI System Questions

**Q1.** What is a service bureau?

**A1.** A service bureau is a company which provides data tracking and
reporting services for loan servicing companies. Service bureaus send
event updates to VA on a daily basis for servicers.

**Q2.** Are the portal-only events also applicable to servicers with
direct connections to VA, i.e., is the reporting of these events not
included in our nightly file?

**A2.** Yes, the portal-only events are applicable to servicers who have
direct connections with VA. These events are not submitted through the
overnight file process. These events are required and VA has provided
you with the Servicer Web Portal to report them to us.

**Q3.** When a new user is set up in VALERI, do they receive an e-mail
message with their user name & password?

**A3.** Yes, an e-mail is sent with the information required to access
the Servicer Web Portal.

**Q4.** How many times can a user enter the incorrect user name or
password before their account is locked?

**A4.** Each user has the ability to make 3 attempts to log in to the
system before being locked and must then contact the administrator at
their office/company.

**Q5.** For submitting documents via the document manager on the
Servicer Web Portal, what format do they need to be?

**A5.** Almost all formats are acceptable. For example: PDF, XLS, DOC
are all acceptable formats. Executable (EXE) files are not acceptable.

**Q6.** Is the borrower\'s full Social Security Number visible anywhere
in VALERI (reports or Servicer Web Portal sections)? Do any of the
events which have to be reported require submission of the full borrower
SSN?

**A6.** The SSN will not be visible anywhere in VALERI. There are two
events that require full submission of the SSN: EDN and Transfer of
Ownership.

**Q7.** How often are the reports updated/posted?

**A7.** Reports are updated nightly. We recommend that you check them
daily.

**Q8.** Is there a way to see which user last ran a report?

**A8.** Not at this time. We will consider this for a possible
enhancement.

**Q9.** What happens if VALERI crashes for more than a day?

**A9.** Since we went live on February 20th, 2008, we have had no down
time. Should you have trouble accessing the Servicer Web Portal, please
contact the VALERI helpdesk.

**Q10.** Has VALERI been in the works for some time or is it being
implemented in part due to the current mortgage environment?

**A10.** VALERI has been in the works for some time. The redesign effort
kicked off in 2001 and it was a 13-month process, which made
recommendations to change the processes and the technology. In 2004 we
awarded the contract to have the VALERI system built to meet our new
recommendations.

**Q11.** Can we see all loans in a particular status (i.e. all loans
currently in default, foreclosure, etc)?

**A11.** Not at this time. You are able to view the status of an
individual loan by accessing the loan in the Servicer Web Portal. You
can also view the various reports to view which loans have been selected
for post-audit, which loans are being considered for refund etc.

**Q12.** Will you be posting updates on the VALERI Servicer Web Portal
regarding enhancements?

**A12.** When appropriate, we will send out notices probably through the
VALERI website of any changes to our program or the system that should
be known by all.

**Q13.** I assume there are many loans assigned to one person, can we
pull a report of all loans assigned to John Doe, for example?

**A13.** It is possible to view all loans that were assigned to one
person during a specific range of dates. This can be accomplished by
accessing the VA Contact Information report and exporting the report to
Excel. Once in Excel, you have the ability to filter the information by
the name of the VA technician.

**Q14.** Can you choose more than one report at time?

**A14.** No, only one report can be run at a time.

**Q15.** Are VA techs still being assigned based on the last 2 digits of
the LIN as they were before?

**A15.** Cases are not assigned by last 2 digits. Loans are assigned
nationally based on a balanced assignment process. All technicians will
have roughly the same caseload.

**Q16.** Will we receive a hard copy of the VALERI Servicer Guide?

**A16.** No hard copy of the Guide will be provided. You may download
the manual from the VALERI website.

**Q17.** What happens if the assigned technician is out of the office?
Will we be able to contact a manager or another technician?

**A17.** You may contact the Servicing Officer (SO) or the Loan
Administration Officer (LAO) for the office of the technician that is
assigned to the case and they will assist you.

**Q18.** On the Servicer Web Portal, under Assigned Technician, the
technician\'s name is in blue. Is that clickable to see the VA tech\'s
contact info?

**A18.** When you click on the name it provides you the ability to send
an e-mail to that technician.

**Q19.** Can more than one person access a report at the same time?

**A19.** Yes, multiple people can access the same report at once.

**Q20.** How many VALERI administrators can I have at my company?

**A20.** You can control the number of administrators that you have. VA
requires that all administrators participate in VALERI Administrator
training prior to executing administrative duties in VALERI.

**Q21.** Can we tell who and when a particular report was run?

**A21.** No, the reports application does not keep track of who runs
which reports at which time.

# General Loan Servicing Questions

**Q1.** Our department processes partial releases of vacant land. Is
there any list of charges for a partial release?

**A1.** There is no fee set by VA for a partial release of security. We
ask that you charge a customary and reasonable fee if necessary.

**Q2.** Normally, for a partial release, we get pre-approval from a VA
representative. With this system, do we make our own decisions and wait
for a post-audit request from the VA?

**A2.** Yes, servicers have been given authority to approve partial
releases of securities, and they are subject to post-audit selection.

**Q3.** What type of exemptions do you allow for disasters like
wildfires, hurricanes, flooding, and tornadoes? When/if we have
federally declared disasters, how do we report these via VALERI?

**A3.** These are considered extenuating property circumstances and are
reported by phone, email, fax, or letter. VA retains this information in
VALERI and additional fees may be allowable.

# Delinquent Loan Servicing Questions

**Q1.** Is there a requirement on the Servicing Transfer (receiving
servicer) event that the prior servicer already be reporting the loan in
VALERI? If so, how will that be addressed during the transition period?

**A1.** VA does not penalize the receiving servicer if the transferring
servicer does not report the Servicing Transfer (transferring servicer)
event to VA prior to the receiving agent. However, the receiving
servicer must report the Servicing Transfer (receiving servicer) and
Electronic Default Notification events prior to reporting any other
delinquent loan events to VA.

**Q2.** When will the property preservation allowables and regulation
changes be available? Are there changes to the requirements for
inspections and preserving the property under VALERI?

**A2.** The new 4800 series of regulations is currently available on the
VALERI website. Preservation allowables will be available by the go-live
date. You are still responsible for protecting and preserving properties
and for ordering property inspections.

**Q3.** Sometimes on an insurable loss that we filed under the mortgagee
clause, we repair the property with the proceeds. Do we still have to
report the loss on the claim?

**A3.** Yes the insurance loss proceeds must be reported on the claim
even though the property has been repaired. Some of the items required
to be reported include: claim date, amount of claim, amount applied to
repairs, and amount applied to unpaid principal balance.

**Q4.** If a loan goes into bankruptcy prior to the 61st day, can I
report the Bankruptcy Filed event?

**A4.** The Bankruptcy Filed event is not reportable prior to an
Electronic Default Notification being reported. In this situation, it
must be reported at the same time as the Electronic Default
Notification.

**Q5.** If the original loan information in WebLGY is incorrect and I
submit an Electronic Default Notification, will my Electronic Default
Notification reject?

**A5.** Yes, all events must meet certain matching criteria in order to
be accepted by VALERI. If your baseline loan data does not match what is
in WebLGY, contact VA Loan Production to resolve the issue.

# Loss Mitigation Letter Questions

**Q1.** If the customer is on an active repay, should the letter still
be mailed?

**A1.** Yes. Even though a borrower might be concerned about receiving
another collection letter if a plan is in place, the language states
that if a borrower is not already working with the sender to resolve the
delinquency, the borrower should call the servicer. VA believes the
borrower should be able to recognize that this is a standard form letter
that is sent even when a repayment plan is in place. Moreover, the
proposed rule provides requirements for the letter, but only specifies
the exact language in the 2 paragraphs stated in the rule. Therefore, an
introduction designed by the servicer could indicate that the letter is
a requirement of the Department of Veterans Affairs, notwithstanding any
existing arrangements in effect.

**Q2.** If the customer is a cease and desist customer should the letter
still be mailed? What exactly is a cease and desist customer?

**A2.** If the customer has a court order prohibiting contact or
collection actions, then it would appear that the letter should not be
sent. However, that issue should be reviewed with servicer\'s counsel
for more definitive guidance.

**Q3.** If the customer is deceased, should the letter still be mailed?

**A3.** Our experience has been that most servicers change account names
to read \"Estate of \...\" in such a situation. The letter would be
appropriate in that case to provide information to the executor of the
estate, or the heirs who may be receiving information on the affairs of
the deceased.

**Q4.** If the property is vacant, should the letter still be mailed?

**A4.** Yes. The borrower may simply not have provided the servicer with
a forwarding address, but the letter will be forwarded if the borrower
filed such a request with the Postal Service. The borrower may have made
other arrangements (with a neighbor or relative) to collect mail at the
property and pass along important communications. Since the letter
provides notice of an interest on the part of VA, it must be sent unless
otherwise prohibited.

**Q5.** If the customer is active bankruptcy should the letter still be
mailed?

**A5.** This should be discussed with your counsel. However, VA expects
that in most such cases the letter will not be sent, as it probably
could be viewed as a prohibited collection action.

**Q6.** If the customer is a chapter 7 discharge non-reaffirmed, should
the letter be mailed?

**A6.** This is probably the same as the previous question. However, we
understand some servicers send special letters under these
circumstances. Those special letters have been designed with the
assistance of counsel to provide the status of the loan and list
potential actions by the servicer, without specifically asking for
payment (which would probably be the prohibited part). If such a letter
contained advice that the loan was guaranteed by VA and provided the VA
website address, that might be beneficial to a veteran, as well as the
servicer.

**Q7.** If there\'s only a paragraph of required verbiage, can the
letter be blended with another letter?

**A7.** The regulation contains two paragraphs of specific language. VA
expects that most servicers will designate the letter with a particular
VA identification so that it can be sent in required situations, even
though it may contain some language which is similar to other collection
letters.

**Q8.** Is this letter required on VA Vendee Loans and Mobile Homes (in
other words serviced under the old guidelines)?

**A8.** The letter is not required and would not be appropriate for
vendee loans, as it mentions VA home loan entitlement, which is not used
on such loans. For manufactured home loans guaranteed under Title 38,
United States Code (U.S.C.), section 3712, the letter is not required,
as such loans are governed by the regulations at title 38, Code of
Federal Regulations (CFR), sections 36.4201 through 36.4287, inclusive.
However, loans for manufactured homes that are permanently affixed and
are guaranteed under 38 U.S.C. 3710, do fall under the new rules and the
letter must be sent. Servicers must exercise due caution in reviewing
manufactured home loans in their portfolios to ensure that they are
properly designated as guaranteed under 3710 or 3712, and if guaranteed
under 3710, that the homes are permanently affixed to the lots in
accordance with current State laws. For informational purposes, VA last
guaranteed a manufactured home loan under 3710 in Fiscal Year 2000, but
prior to that it had not guaranteed any since 1996. VA believes that
less than 300 manufactured home loans guaranteed under 3710 are still
active.

# Loss Mitigation Questions

**Q1.** We are to trying to reach out to the veteran to bring the loan
current. However, there are times when the veteran's intent is not to
keep the property. Do we still have to recommend retention options?

**A1.** No. Your records must be documented to state that you have
reviewed and considered all loss mitigation options but that the
veteran/obligor/estate did not want to keep the property.

**Q2.** If the veteran has been a chronic delinquent in the past and we
want to proceed with foreclosure, and we can justify our reasons, will
VA allow us to proceed with the foreclosure?

**A2.** You are still responsible for reviewing all alternatives and
verifying that these alternatives are not viable for the veteran.

**Q3.** Can the executor of the estate bypass retention options and
complete a liquidation option? If so, what is the required
documentation?

**A3.** Yes. Case notes simply need to be documented to indicate that
the executor does not want to consider any home retention options.

**Q4.** If a property is in probate would it be best to proceed with a
liquidation option, or wait for probate to be completed?

**A4.** You would need to consult with your attorney but prompt
termination of the loan is in the best interest of all parties.

**Q5.** If we set up a repayment plan with a veteran for 6 months and
the veteran is keeping up with the plan (lets say he makes 5 of the 6
payments), why does the loan have to cure before we receive our
incentive?

**A5.** Incentive rules are that the default must cure before the loan
is eligible for an incentive payment.

**Q6.** Can I use the special forbearance option to do a hold on
foreclosure activities in order for the veteran to complete a private
sale, thereby stopping additional costs like attorney fees? If so, will
this qualify for an incentive payment when I report the default cured
since the loan will be paid in full?

**A6.** If the loan is 61 days delinquent and the forbearance is at
least 1 month in duration, it will be eligible for an incentive payment.

**Q7.** May we take verbal financial information when considering a loan
modification?

**A7.** This is an internal process. It is not a VA requirement. VA only
requires supporting documentation that was used to complete the
underwriting of the loan to complete the loan modification at the time
of a post-audit.

**Q8.** Should the compromise sale purchase be "arms length?"

**A8.** Every case needs to be reviewed but the bottom line is that the
net proceeds of the sale must not be less than net value.

**Q9.** On compromise sales, the current owner(s) are not to receive the
proceeds; however, the current owner(s) may benefit from the compromise
sale if a relative purchases the house and allows the current
homeowner(s) to live in the house. Would this be allowable?

**A9.** Every case needs to be reviewed but the bottom line is that the
net proceeds of the sale must not be less than net value.

**Q10.** Must the loan be 61 days past due to complete a compromise
sale?

**A10.** To be eligible for a payment, either incentive payment or claim
payment, the loan must be a reportable default (i.e., 61 or more days
delinquent).

**Q11.** Do we have to get promissory notes on certain loans noted in
the old Servicer Loss Mitigation Program (SLMP) guidelines?

**A11.** No, promissory notes are no longer required.

**Q12.** Who counsels the veteran about his/her benefits that may be
affected by the compromise sale?

**A12.** The two paragraphs that are required to be placed in the VA
loss mitigation letter will explain the effects on their benefit. These
paragraphs can be found in the new 4800 series of regulations.

**Q13.** Is a private sale a full payoff?

**A13.** Yes.

**Q14.** Are we no longer comparing the compromise sale/deed-in-lieu
options to the foreclosure sale for a savings?

**A14.** The cost analysis is no longer required but the credit must be
net value or actual proceeds of sale, whichever is greater.

**Q15.** For a pre-approval for a compromise sale in which the net
proceeds will be less than net value, how do I submit my pre-approval
request?

**A15.** Contact the technician assigned to the case by phone and or
e-mail. Written documentation is required to be submitted to the
technician as well.

**Q16.** Can we have the agent short their commission to complete the
short sale?

**A16.** It\'s a good option and needs to be negotiated by you.

**Q17.** If the buyer is an agent are we required to pay a commission?

**A17.** Commissions are paid to the listing agent, through the closing
process, and the listing agent negotiates the amount payable to the
purchasing agent.

**Q18.** Are we ever allowed to put the foreclosure on hold to allow
time to complete the compromise sale or deed-in-lieu?

**A18.** Our expectation is that you consider all loss mitigation
options prior to referring a loan to foreclosure. If you put a
foreclosure sale on hold and later on follow through with the sale, keep
in mind that you will not be allowed interest beyond the maximum
timeframe, which is 210 days from the last paid installment plus the
state foreclosure timeframe.

**Q19.** If I request a pre-approval from VA in regards to a short sale
or deed-in-lieu of foreclosure where the net proceeds is less than the
net value will this not affect the tier ranking?

**A19.** This will not affect your tier ranking as you have followed our
guidance and requested a pre-approval.

**Q20.** In regards to the short sales and deeds-in-lieu of foreclosure,
if verbal financials are reviewed with the mortgagor and a surplus is
showing is the file then to be returned to retention for review since
retaining the property is the first option?

**A20.** If the homeowner does not have the desire to retain the
property, even if there is a surplus it does not necessarily mean that
you have to go back but if the homeowner does want to keep the home,
then retention options should be reviewed with the homeowner and secured
if feasible.

**Q21.** Can you pursue a deed-in-lieu immediately upon notification of
the death of a veteran as long as it meets encumbrance criteria?

**A21.** Yes. You must document your notes to reflect the situation and
that you discussed all possible options with the estate.

**Q22.** Must we have had an offer that was denied prior to considering
a deed-in-lieu?

**A22.** No, that is not required.

**Q23.** Can we complete a deed-in-lieu the day prior to the foreclosure
sale?

**A23.** Yes. Net value will still be credited to total indebtedness.

**Q24.** Would our tier ranking be affected if VA pulled the file in
house?

**A24.** Any loss mitigation option recommended by VA would not result
in an incentive payment and could affect your tier ranking in the
future. VA will be monitoring servicer performance throughout the
initiation period of the VALERI project and will gather baseline
information that will be used to develop the tier ranking criteria.

**Q25.** Should this new process decrease the amount of deed-in-lieu
requests that we receive currently?

**A25.** It should not decrease, but it could increase. You should be
reviewing loans early in the delinquency to determine the best loss
mitigation option.

**Q26.** Will there be a centralized VA office accepting the notices
(NOD & NOI) for the vendee and mobile home loans?

**A26.** At this time there is not a centralized officer accepting these
forms. You would continue to send forms to the original office of
jurisdiction. Repurchase and mobile home claims should be submitted to
the St. Paul Regional Loan Center.

**Q27:** Do we perform loss mitigation the same if the borrower is
already under Servicemembers Civil Relief Act (SCRA) protection, but
still unable to make his monthly payment?

**A27:** Loss Mitigation options should continue to be reviewed even
though there is the protection of SCRA. In reference to the interest
rate and some protection against foreclosure, it is to everyone's
benefit to discuss these options with the homeowner to avoid extensive
expenses when not necessarily the right decision. This may be a perfect
opportunity to accept partial payments from the homeowner to prevent the
delinquency from increasing at a fast pace.

**Q28:** For deeds-in-lieu, how far back should the title search be
done?

**A28:** It is recommended that you contact your legal counsel but it
would appear that an initial title search would typically be from the
date of the loan origination to the present.

# Appraisal, VA Cost Factor, Bid Amount, and Write-Off Questions

**Q1.** Will there still be a Construction & Valuation (C&V) area to
review the appraisal reports to issue the Notice of Value (NOV)?

**A1.** If you are a participant in the SAPP SAR program you can review
the appraisal and issue an NOV. If you do not participate, C&V will
issue the NOV.

**Q2.** You state that if we learn of property damage after obtaining
the appraisal but before the completion of the foreclosure sale, we need
to contact the appraiser to obtain an updated appraisal report which
considers the damage and update the net value. Will VA reimburse us for
the additional appraisal?

**A2.** Yes. This is entered on your claim as an "appraisal update"
expense.

**Q3.** In determining net value, is VA\'s cost factor always going to
be 88.13% of the appraised fair market value?

**A3.** The cost factor is 11.87% and could change on an annual basis.

**Q4.** How will we be notified of a change in the cost factor for our
calculations?

**A4.** The cost factor will be published on the Federal Register and
the VALERI website.

**Q5.** Can we order the appraisal prior to receiving an offer?

**A5.** Yes, just keep in mind that a liquidation appraisal expires
after 6 months.

**Q6.** Are interior appraisals required for a compromise sale?

**A6.** Yes, if the homeowner is seeking assistance, they need to allow
the appraiser access to the property.

**Q7.** Is a buy down still required?

**A7.** Buydowns do not exist in the new environment. The servicer will
need to write-off any amount not covered by the acquisition and claim
payments received from VA.

**Q8.** What is the deficiency waiver letter?

**A8.** The deficiency waiver letter sent to the homeowner is informing
the homeowner that you, the servicer, will not collect the balance not
covered by the claim payment.

# Refund Questions 

**Q1.** What documentation is needed for refund loans?

**A1.** Refer to the Servicer Guide for refund title document
information. You will receive notice of the required documents in the
refund approval letter from VA as well.

**Q2.** Will VA consider a refund on a loan if the loan has been
modified?

**A2.** The regulation still requires VA to review every case for
refunding and this is accomplished during our adequacy of servicing
review.

**Q3.** For refund title, will we need to record the assignments to VA
for each state? Will we need title endorsements for all assignments
going to VA?

**A3.** Yes, servicers must record the assignment to VA and the
endorsement on the note has to follow the chain of title.

**Q4.** Will the refunding letters still be sent directly to the loss
mitigation representative at my company or will they be online in
VALERI? Will all documents need to be uploaded through VALERI or can we
fax them to the VA technician?

**A4.** There is a Refund Status Report that can be accessed via the
Servicer Web Portal. The VA technician will also contact a
representative and fax or e-mail our recommendation letter with
instructions. All documents will need to be sent by e-mail or faxed. The
only item that goes through the Servicer Web Portal is the claim
submission with supporting documentation.

**Q5:** We have 60 days from the approval date to file a refund claim.
How long do we have to obtain the legal documents?

**A5:** The same time frame applies to submitting obtaining the legal
documents.

**Q6.** Will VA allow or accept an appeal for more time to procure all
the needed documents for a Refunding Claim? Especially when a loan has
gone through several different servicers and all documents may have not
been transferred to the last servicer now submitting the Refunding
claim?

**A6.** All documents are to be submitted with the claim. We understand
that there are situations that the documents are more difficult to
obtain but we encourage you to work as quickly as possible. We will
attempt to work with you to resolve any issues.

# Foreclosure Questions

**Q1.** You say that VA will postpone the foreclosure if the technician
believes a loss mitigation option is available. How has this changed
from the past Servicer Loss Mitigation Program (SLMP) era?

**A1.** VA no longer does supplemental servicing. We will review a loan
when it is referred to foreclosure and if we determine that a loss
mitigation option may have been more feasible, then VA may recommend the
foreclosure action be placed on hold to do a full review. This
recommendation should be on an exception basis in the new environment.

**Q2.** You state that we are to pursue loss mitigation options even
after the foreclosure process has started. What do we do if at the 11th
hour we receive a valid offer, which cannot close prior to the
foreclosure date? If we do not postpone, will this affect our tier
ranking? If we do postpone, will this affect our claim?

**A2.** If the timeframe to terminate the loan is extended beyond the
210 days plus the state foreclosure timeframe you may request a
pre-approval and justify the postponement. This does not currently
affect your tier ranking during the first year as we are currently
collecting data to develop our tier ranking criteria during this time
period. The claim could be affected if the proceeds of sale are not
equal or greater than the net value or if it is beyond the maximum
interest timeframe.

**Q3.** On loans where the property has been abandoned and a loss
mitigation option is not feasible, is my company only allowed the state
timeframe or do we still get the 210 days plus the state timeframe?

**A3.** Terminate as quickly as possible, but you still have 210 days
plus the state timeframe.

**Q4:** For confirmation states how will you account for the
confirmation dates? (e.g., Wisconsin, Oklahoma, Ohio, Kentucky and New
Mexico?)

**A4:** On the Transfer of Custody Event, you will enter in the date of
confirmation or ratification. VALERI knows which states require this
data and will calculate 15 days from the date of confirmation to accept
the Transfer of Custody.

**Q5:** If the servicer does not know that the property is a Mobile Home
how does the VA discover this?

**A5:** Hopefully at this point of the process (where a foreclosure
occurs and the servicer is trying to transfer custody), VA should know
that it is a mobile home. The first possible time we would know this is
at the time of the VA appraisal.

# Property and Title Transfer Questions

**Q1.** If VA returns custody, is the servicer responsible for recording
the deed transferring title back? Will VA initiate and execute this deed
or will the servicer or servicer\'s attorney be responsible for this
part of the custody transfer?

**A1.** VA will issue the deed and the servicer will need to record it.

**Q2.** If the Invalid Sale Results event is reported, do we have to
remove the Transfer of Custody event from VALERI?

**A2.** If this process takes place, VA will return custody of the
property and issue a bill of collection. You would provide the updated
Results of Sale or a new sale date, if applicable. There is no removal
of a Transfer of Custody event in this situation.

**Q3.** Where would we obtain our vendor code for reporting the Transfer
of Custody event?

**A3.** This number is provided to the management at your company and
they determine who is required to have it to process their work.

**Q4.** Will there no longer be a \"Notice of Election to Convey?\"

**A4.** No actual documents are required. The VA Form 26-8903 is no
longer valid and you simply report the Transfer of Custody event through
the Servicer Web Portal.

**Q5.** Today we are required to fax the Confirmation of Sale letter for
certain states along with the Notice of Election to Convey (NOE). Will
that still be required?

**A5.** No documentation is required for a confirmation of sale unless
the case is selected for a post-audit.

**Q6:** The servicer training course states the servicer has to submit
insurance cancellation notices. How are these documents going to be
submitted?

**A6:** VA requires that title documents and insurance policies be
submitted directly to VA's property management contractor when you
transfer custody of a property to VA. An insurance cancellation notice
may be submitted in lieu of and insurance policy.

**Q7:** Confirmation states have different timeframes for title. Will
you put the timeframes on your website?

**A7:** Yes, the timeframes have been posted on our VALERI website. The
timeframe is generally 60 days from loan termination, unless otherwise
specified.

**Q8:** Will we have to provide documentation of the Confirmation of
Sale from the Courts as we do now? Will the VA still require the
Servicer to send in the Deed In Lieu documents executed by the
homeowner?

**A8:** No, in the new environment the servicer is required to submit
the Transfer of Custody event electronically, but retain all supporting
documentation for at least 3 years for possible selection of a post
audit.

**Q9:** If Ocwen or PM contacts me to inform me that they are returning
custody of a property, do I still need to report the Invalid Sale
Results or Improper Transfer of Custody event to VA?

**A9:** Yes. VA requires you to report these events within 7 days of
discovering that a sale was invalid or a transfer of custody was
improper. If the property was acquired prior to your transition to
VALERI, you report these events via telephone to the technician assigned
to the loan.

# Claim Questions

**Q1.** On compromise sale claims, is the timeframe to submit a claim
365 calendar days from the settlement date?

**A1.** Yes, but it is to your benefit to submit it as soon as possible
as the incentive payment for a compromise sale is paid at time of claim.

**Q2.** Do we need to upload invoices for all expenses claimed for all
claim types including refunds?

**A2.** Upload is required at the time of filing a supplemental claim or
refund claim. Documents are not required on the original claim until it
is selected for post-audit.

**Q3.** Currently, we are able to change the claimant information on our
claims mailed to the VA. Will we be able to change the address of where
the payment needs to go in the VALERI system?

**A3.** The payment address is controlled by the payee vendor ID number
that you enter in the Servicer Web Portal as part of the claim event.

**Q4.** If a loan was modified twice, once prior and once after then new
regulation, how will VALERI calculate the maximum guaranty?

**A4.** The first loan modification will be the starting point for
calculating the guaranty on the 2nd modification.

**Q5.** Will the claim payment analysis be available to print?

**A5.** Yes, the analysis is available on the Claim Payment Status
Report in the Servicer Web Portal and it is printable.

**Q6:** Regarding supplemental claims, VA advises what documents will
need to be uploaded. If the document cannot be uploaded, is there going
to be an alternate method, such as fax or email to present these
documents?

**A6:** All documents should be submitted through the Document Manager
utility on the Servicer Web Portal. Documents should be scanned and
submitted electronically. Should Document Manager be unavailable, you
may request to have the documents faxed and VA will attempt to scan them
into VALERI, however this should be done on an exception basis.

**Q7.** Do you have a list of your maximum allowable fees for claims?

**A7.** Yes, the VALERI Fee Cost Schedule is on the VALERI website.

# Post-Audit Questions 

**Q1.** Why is a post-audit done on a partial release since VA doesn\'t
pay an incentive?

**A1.** This is a delegated function and we post-audit all delegated
processes that could affect the government\'s liability.

**Q2.** Will VA need to see the transaction of a charge off amount
(previously buydown) on the transaction history for a post-audit? In
addition, the claims portion in VALERI has a section for reporting a
\"buydown\" as a credit on the claim. Does the charge off amount need to
be reflected in this section of the claim in order for payment?

**A2.** The charge off amount is not required to be presented on the
history. Also, the buydown on the claim is any previous buydown that was
completed prior to your go-live date in VALERI.

**Q3.** If a loan is eligible for post-audit 60 days following payment,
for example, does that mean it will not be selected until at least 60
days? Is there a cap on how long after the 60 days a loan may be
selected?

**A3.** The case is only eligible beginning at the 60th day. VALERI
selects cases that have just become eligible for post-audit at the end
of the month. The case then only stays eligible to be selected by the
Central Office Servicer Liaison (COSL) if it is determined that
additional cases are required.

**Q4.** Can you provide any additional information on how a sample size
is determined? For instance, is it a percentage of eligible loans? Does
it vary based upon the type of sample (i.e. repayment plan incentive,
foreclosure claim, etc.)?\
**A4.** The post-audit sample is a statistically valid selection, based
on a formula approved by VA statisticians and does not vary based on the
type of action completed by the servicer.

**Q5.** Will there be functionality to filter the post-audit report in
VALERI to enable the correct business units to handle appropriate
documents needed?

**A5.** The post-audit report does not currently include the reason for
the post-audit (i.e. what action is being post-audited). We are working
to improve the post-audit report to include this information. Until this
information is displayed, you will be required to enter the loan number
into the Servicer Web Portal and view what events were submitted to
determine what type of post-audit selection was made.

**Q6.** Post-audits on foreclosure claims are eligible for audit 60 days
after claim payment. When evaluating servicer performance, will VA take
into account the fact that numerous claims will have been submitted
prior to VA identifying issues and additional training being conducted?
Will this pool of claims effect tier ranking, post-audit increases, etc?

**A6.** We are currently collecting data to establish the tier ranking
system. Business Rule failures can be viewed by servicers within each
event but will also be available on the post-audit report with details
if necessary.

**Q7.** For post-audit selections, will there be specific times, days,
and dates when these lists will be posted for review by the servicers?

**A7.** The selection of cases will be done by the end of each month. If
additional selections are made by the COSL, these may be selected at a
different time than the end of the month. It is critical therefore to
check the Post-Audit Selections and Results Report on a daily basis to
see if any new cases have been selected.

**Q8.** Can exceptions be granted to the 30 day time period in providing
required information to the VA to support the servicer's case?

**A8.** This should be the very rarest of exceptions. At the time of
post-audit, everything has been completed and all required documents
should be readily available to be submitted to VA.

#  Payment and Bill of Collection Questions

**Q1.** With a Bill of Collection (BOC), can we send a check for the
amount or does the transaction need to be completed by a wire?

**A1.** There is no wire process for VA to receive your payment on a
BOC. Please forward payment by check to: DEPT of Veterans Affairs, ALAC
(241A), ATTN: Agent Cashier; 1615 Woodward Street, Austin, TX
78772-0001.

**Q2.** Is there only the option for one appeal once a BOC is issued or
is there the opportunity for continued dialogue?

**A2.** Additional discussion can take place, if you feel an explanation
is required when submitting your appeal but only one appeal is allowed
and must be submitted within 30 days of the payment or BOC.

**Q3.** How are incentives on Repayment Plans, Special Forbearances and
Modifications going to be sent? Will these be combined with claim
payments for foreclosures, deeds-in-lieu of foreclosure and Compromise
sales?

**A3.** Deed-in-lieu and compromise sale incentives are paid at the time
of claim payment. All other incentives are paid as the events occur and
it is estimated that payment should be received within 5-10 days after
certification. Payment is through an electronic funds transfer.

**Q4.** What are the incentive payment amounts for tier 2 servicers?

**A4.** Incentive payment amounts for all tiers are listed in the 38 CFR
36.4800 series of regulations. The regulations are located on the
Servicer VALERI website at <http://homeloans.va.gov/valeri.htm>.

**Q5.** Will exceptions be granted by VA for Servicers to respond to
BOC\'s?

**A5.** No. There is a 30 day timeframe to submit the funds and on the
45th day the funds will be used to offset other payments if the payment
is not made. BOC amounts can be appealed.

**Q6.** Are there instances where we will be seeing more than one BOC
per loan? For instance, if a BOC was issued and then it was discovered
that there is more than one reason why VA would need funds returned?

**A6.** It is possible but it should occur very rarely.

**Q7.** If we have a BOC from before VALERI, will we have to continue to
follow up with the contacts we have already setup?

**A7**. Yes.

# Transition Questions 

**Q1.** If a loan has a sale held prior to the go-live date and is
invalidated and taken back to sale after the go-live date, does the
servicing of that loan fall under the previous 4300 series of VA
regulations or does it follow the new 4800 series?

**A1.** Effective on the go-live date is when the case that is not
terminated goes under the 4800 series of the regulations.

**Q2**. Does the new 4800 series of regulations apply to all loans
effective 2/1/08 (the regulation publish date) or my VALERI
implementation date?

**A2.** The series 38 CFR 36.4800 and all regulations are effective on
your go-live date with 3 exceptions. These three items are effective for
all servicers as of the regulation publication date of 2/1/2008: The
provision allowing one year for filing claims, the new maximum allowable
attorney fees, and the SAPP program.

**Q3.** Will loans for which a Notice of Delinquency was reported prior
to our go-live date be in VALERI and subject to the old requirements
(4300 series)?

**A3.** All delinquent loans will be in VALERI effective on your go live
date. All loans in VALERI will fall under the 4800 series.

**Q4.** Have the various VA offices been given an effective date that
they will no longer issue a foreclosure bid?

**A4.** The guidance given to the VA offices is not to issue any bid for
sale dates that occur after the servicer's go-live date.

**Q5.** What are we going to do with the loans that have gone to
foreclosure sale up until we go live in VALERI? Do we submit a \"paper\"
8903 (Notice of Election to Convey) or wait until our go live date to
handle these?

**A5.** All of the information you need about your implementation is
available in the Servicer Implementation Guide, which is posted on the
VALERI website.