HB-1-3555

(03-09-16) SPECIAL PN 5-1

Revised (06-28-23) PN 585

CHAPTER 5: ORIGINATION AND

UNDERWRITING OVERVIEW

5.1 INTRODUCTION [7 CFR 3555.51(b)]

Single Family Housing Guaranteed Loan Program (SFHGLP) loans are originated and 

underwritten by approved lenders. However, the process of requesting, issuing, and 

receiving the loan guarantee is one in which the lender and the Agency must cooperate 

closely. Lenders must provide the Agency with clear and accurate information so that 

Agency staff can promptly determine whether the loan qualifies for a guarantee. At the 

same time, Agency staff must process loan applications quickly and accurately to avoid 

delays that might hamper the lender’s efforts to close the loan efficiently. 

5.2 REQUESTING A GUARANTEE [7 CFR 3555.151]

Not all loans are appropriate for the SFHGLP. The lender should determine whether, 

based on preliminary information, it appears that the loan will meet the program’s criteria. 

The lender should answer the preliminary eligibility questions below to assist in making 

this determination. The lender should also ensure that the applicants are fully informed 

about the requirements of the program.

A. Preliminary Determination of Applicant Eligibility

In general, the program is most appropriately used to offset the risk of making high 

loan-to-value loans in rural areas. It is not intended to offset risks that stem from a poor 

credit history or poor property condition. In particular, the lender should review the 

following items to make a preliminary determination of the applicants’ eligibility.

• Applicant Characteristics (Chapter 8) Are the applicants able to secure 

conventional credit? Do the applicants own a dwelling? Are the applicants U.S. 

citizens or eligible non-U.S. citizens as detailed in Chapter 8? If the applicants are

not U.S. citizens, they must produce evidence per Agency guidelines to qualify as 

a non-U.S. citizen.

• Income (Chapter 9) At the time of loan approval, is the household's adjusted 

income below the applicable moderate-income limit? To determine eligibility for 

the SFHGLP, the lender is responsible for documenting the income of all adult 

members of the applicants’ household (not just those who will be signatories to the 
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note). Current income limits can be found in Appendix 5, on the USDA Income 

and Property Eligibility website at http://eligibility.sc.egov.usda.gov/eligibility/,

or by using the Agency’s automated underwriting system, GUS.

In addition to meeting adjusted annual income requirements, the applicants must 

also have sufficient repayment income and meet additional program requirements. 

Chapter 9 provides more detailed information about annual, adjusted, and 

repayment income.

• Credit (Chapter 10) Is the credit history consistent with program guidelines? 

The applicants must have a credit history that demonstrates the ability and 

willingness to repay the loan. GUS is unable to render an underwriting 

recommendation on supplemental credit reports. These should be uploaded with 

the application package.

• Ratios (Chapter 11) Do the applicants’ PITI (Principal, Interest, Taxes and 

Insurance) and total debt (TD) ratios fall at or below the limits established by the 

Agency? Ratios are calculated using repayment income from applicants who will 

be a party to the Promissory Note. 

• Appraised Value/Loan amount (Chapter 12) Is the loan amount supported by

the appraisal’s fair market value? If there is not yet a current appraisal, is the loan 

amount expected to be supported by the appraisal? 

• Site and Property (Chapter 12) Does the property appear to be in an eligible

rural area as designated by program guidelines? If warranted, did Agency staff 

confirm that the property location was rural? The Agency encourages lenders and 

those involved in the origination package to verify a property’s eligibility on the 

Agency’s property eligibility website. Property eligibility may be checked online 

at http://eligibility.sc.egov.usda.gov/eligibility/, or by using the Agency’s 

automated underwriting system, GUS.

B. Informing the Applicant

Before requesting a loan guarantee, the lender should take the following steps to 

ensure that applicants have a general understanding of the SFHGLP.

• Concept of a loan guarantee. Describe to the applicants what a loan guarantee 

is, why it is used, and the benefits of a loan guarantee. Benefits include, but are 

not limited to, no required down payment and a fixed interest rate.

• Loan guarantee fee. Inform the applicants of the upfront guarantee fee to be 

paid at loan closing.

• Annual fee. Inform the applicants of the annual guarantee fee, if applicable.
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• Occupancy. Inform the applicants that they must occupy the property as their 

principal residence.

• SFHGLP requirements. Inform the applicants of program requirements such as 

income limits, property location eligibility, debt ratio thresholds, and other 

requirements such as the certifications outlined on Form RD 3555-21, Request for 

Single Family Housing Loan Guarantee.

5.3 UTILIZING THE GUARANTEED UNDERWRITING SYSTEM

[7 CFR 3555.107(b)]

The Guaranteed Underwriting System (GUS) was developed to automate the process 

of credit risk evaluation for the SFHGLP. Automated underwriting (AU) systems are an 

efficient, consistent, objective, and accurate method of mortgage underwriting compared 

with traditional manual methods. GUS is a tool that helps evaluate the credit risk of the 

loan request. It compliments but DOES NOT replace the considered judgment of 

experienced underwriters. 

GUS incorporates applicant eligibility and underwriting requirements of this 

Handbook by utilizing a modified version of the Federal Housing Administration (FHA) 

mortgage scorecard known as Technology Open to Approved Lenders (TOTAL),

concurrently with a rules based engine. GUS is accessed through a secure web-based 

automated underwriting environment at https://usdalinc.sc.egov.usda.gov/. GUS 

considers mortgage loan application data entered by the approved lender, credit 

repository data, and income and property information to evaluate a potential applicant’s

ability to meet a proposed mortgage obligation. GUS evaluates select components in a 

mortgage loan application and provides a credit evaluation and underwriting 

recommendation within seconds. GUS is not designed to evaluate the dependability of an 

applicant’s income proposed for repayment. This remains the underwriter’s 

responsibility to determine prior to final submission. Refer to Chapter 9 of this 

Handbook to determine adequate and dependable income for repayment ability. Lenders 

are reminded that data entered in GUS must coincide with that of the lender’s permanent 

case file.

A. Functionality of GUS

Incorporated within the functionality of GUS are the following components:

Property and Income Eligibility

• The dwelling offered as collateral for the proposed mortgage loan is located in an 

eligible rural area; and

• The applicants’ adjusted annual household income meets the adjusted income 

limits in accordance with size of household, county, and state in which the 

applicants will reside.
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Rules Based Engine

• The Engine incorporates the guidelines found in this Handbook regarding 

originating SFHGLP loans. 

• Periodically new rules may be created to respond to issues analyzed within the 

SFHGLP portfolio.

Scorecard

• GUS uses a modified version of the FHA mortgage scorecard known as TOTAL,

exclusive to Rural Development. 

• The scorecard has been validated and adjusted for SFHGLP use.

• The TOTAL scorecard, including the modified version validated for SFHGLP 

use, is intellectual property that is proprietary to HUD.

• Examples of factors considered under the scorecard include but are not limited to

credit history, payment-to-income ratios, and loan-to-value ratios.

• The scorecard allows favorable consideration to applicants that exhibit positive 

compensating factors such as available reserves for housing payments after loan 

closing.

• Periodically the scorecard may be modified to react to the changing lending 

market. When modifications occur, loans remaining as a preliminary 

recommendation may not receive the same underwriting results upon a final 

submission.

Credit Bureau Interface

• GUS links with a number of credit providers nationwide. Users may link to a full 

list of credit providers at https://singlefamily.fanniemae.com/credit-informationproviders. 

• An interface occurs between GUS and the credit bureaus through a platform 

known as the Fannie Mae Credit Interface Service (CIS).

• The interface is seamless to lenders and only acts as a conduit. An attempt to 

access information from all national credit repositories will occur, but GUS can 

complete its credit risk evaluation with information from only one repository.
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• New or re-issued credit can be pulled through GUS.

• Credit reports pulled through GUS are valid for 120 days, unless the credit 

provider’s expiration is more restrictive. 

• Lenders are not required to be a Fannie Mae subscriber or partner to utilize the 

credit report interface in GUS.

B. Gaining Access to GUS

Approved lenders with active Lender Agreements will utilize GUS as part of their 

credit risk evaluation, when possible. Lenders who utilize this system will be required to 

enter into a User Agreement and obtain authorized access through the use of an 

eAuthentication account and password. GUS User Guides may be obtained at

https://www.rd.usda.gov/resources/usda-linc-training-resource-library/guaranteedunderwriting-system.

C. Underwriting Guidance for Lenders

GUS evaluates the overall creditworthiness of the applicants based upon a number of 

credit variables and, when combined with remaining functionalities of GUS, indicates a 

recommended level of underwriting to determine a loan’s eligibility for a SFHGLP 

guarantee. GUS will conclude that the credit and capacity for repayment of the mortgage 

are acceptable or will refer the loan to the lender’s underwriter for further consideration, 

review, and manual underwriting. 

Regardless of the underwriting recommendation provided, the lender remains 

accountable for compliance with SFHGLP eligibility requirements, as well as any credit, 

capacity, and documentation requirements. Applicants should not be approved or denied 

a SFHGLP guarantee solely on the basis of a risk assessment generated by GUS. 

D. Compatible Loan Origination System (LOS) and Point of Sale (POS) Vendors

A single file import feature is available in GUS. GUS currently accepts Desktop 

Underwriter® Specification exported files. For guidance on the current version GUS is 

accepting at the time of file submission, the lender may refer to the GUS Lender User 

Guide, which can be located at https://www.rd.usda.gov/resources/usda-linc-trainingresource-library/guaranteed-underwriting-system. 
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E. Cash Reserves

Although cash reserves after closing are not required for the SFHGLP, cash reserves 

are considered in the risk assessment provided by GUS. When disclosing the assets of 

applicants on the “Assets and Liabilities” page of GUS, lenders have the responsibility to 

determine if the asset is liquid or readily converted to cash and can be done so absent 

retirement or job termination. Assets such as 40l (k)s, IRAs, etc. may be included in the 

underwriting analysis up to only 60 percent of the vested value. Funds borrowed against 

these accounts may be used for loan closing, but are not to be considered as cash 

reserves. Gift funds from any source will not be included in the cash reserves calculation 

in GUS. Cash reserves are used for the purpose of qualifying applicants for a loan. Cash 

to close remains the lender’s responsibility to verify and document that applicants have

sufficient funds to facilitate loan closing. Documentation will be retained in the lender’s 

permanent case file. 

Assets should never be overvalued as it affects the risk assessment provided by the 

automated underwriting system and misrepresents the file presented for a Conditional 

Commitment for Loan Note Guarantee. Guidance on the calculation of reserves is 

explained in Chapter 9. In lieu of entering assets in GUS, the lender may underwrite to 

the most conservative approach with no consideration of assets on the “Assets and 

Liabilities” page and underwriting recommendation. 

Assets may also influence program eligible income. Refer to Paragraph 9.4 of 

Chapter 9 for additional information regarding assets and program eligible income.

F. Omitting Liabilities

If a lender omits an adverse trade line when utilizing GUS and receives an Accept 

underwriting recommendation, an applicant explanation letter and supportive 

documentation of adverse trade lines will be retained by the lender. The lender will 

indicate the justification for the omission in the “If Omit, please specify” section of the 

“Asset and Liabilities” page.

G. Established Data Tolerances

Loan application data submitted to the Agency must reflect a true and accurate 

representation of the loan to be closed. This data must match the loan file submitted to 

the Agency when requesting the Conditional Commitment for Loan Note Guarantee or 

fall within the tolerances established by the Agency.

A tolerance threshold has been established when an increase in obligations do not 

exceed a cumulative total of $50. Examples of these obligations include, but are not 
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limited to, installment loans, revolving credit lines, real estate taxes, final homeowner’s 

insurance premiums, etc. Loan files that have received a Conditional Commitment for 

Loan Note Guarantee do not require updated underwriting or resubmission of GUS when 

the cumulative total of obligations increase, but do not exceed the established thresholds. 

This tolerance threshold applies to situations where an increase in monthly debt provided 

on the loan application at time of Conditional Commitment differs from the amount 

recorded at loan closing.

Tax and Insurance Escrows: Approved lenders must ensure that an accurate 

estimate for the property tax/insurance component of an applicant’s monthly mortgage 

payment is utilized when submitting loan applications to the Agency. The threshold 

policy should not be construed to allow lender manipulation of escrow variables to obtain 

approvals. Care must be taken to assume a realistic estimate is used for computing the 

monthly escrowed amount. For existing properties, the escrowed amount for real estate 

taxes is based on the actual taxes assessed. For new construction, tax estimates must be 

based on the land and completed improvements, not just on the land value (i.e. value of 

both the property and the completed dwelling). The lender may contact the taxing 

authority which has jurisdiction over the property to obtain an estimate of the taxes to be 

assessed for newly constructed homes. The Agency reserves the right to request and 

review files from lenders that are suspected of purposely underestimating tax and 

insurance payments in order to secure a commitment or loan guarantee.

Income: Verification of income shall be obtained prior to final submission. 

Therefore, data entered in GUS must be supported with verifying documentation of 

income in the lender’s permanent loan file. Income shall be verified and documented in 

accordance with Chapter 9 of this Handbook.

Liquid Assets: Asset data reflected in GUS must be supported by verification 

documentation. The final submission will reflect the verified amount. Guidance 

regarding verifying assets can be found in Attachment 9-A. 

H. GUS Findings and Underwriting Report

The responsibilities associated with producing loans of acceptable quality for loans

guaranteed by the Agency remains the same for a GUS evaluated loan or a manually 

underwritten loan. When a lender enters mortgage loan data into GUS and requests a 

loan underwriting evaluation, a two part underwriting summary is delivered to the lender 

through a GUS Underwriting Findings Report. The first portion of the underwriting 

summary will render an underwriting recommendation of Accept, Accept with Full

Documentation, Refer, Refer with Caution, or Ineligible. The underwriting 

recommendation is followed by a risk evaluation of Eligible, Ineligible, or Unable to 
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Determine. The second portion represents a combined analysis of property, income, loan 

eligibility, and applicant eligibility. 

The GUS Findings and Underwriting Report provides important feedback messages

and conditions for the loan. The lender must review the final findings, comply with the 

conditions, and provide the Agency with any additional documents, as applicable. 

The final GUS Findings and Underwriting Report must be retained in the lender’s 

permanent loan file. Non-GUS submissions, Accept with Full Documentation, Refer, and

Refer with Caution files will be accompanied by Attachment 9-B, the Uniform 

Transmittal Summary (FNMA Form 1008/Freddie Mac Form 1077), or equivalent. The 

documentation provided must include calculations for annual, adjusted, and repayment

income. Further clarification regarding income can be found in Chapter 9.

The Agency commitment will reference the GUS underwriting findings report as a 

condition of guarantee loan approval.

I. Lender Steps When Requesting a Commitment

1. Ensure the data entered in GUS is true, complete, accurate, and supported by the 

documents retained in the lender’s permanent loan file.

2. The approved lender’s underwriter must review and confirm the entire loan 

package meets SFHGLP requirements.

3. The lender should verify all required documents have been successfully uploaded

per Attachment 15-A, Loan Origination Checklist. Underwriting documents 

should be combined into a single black and white file. The appraisal report must

be uploaded as a separate color file.

4. Submit the file in GUS as a “Final Submission” to electronically transmit the loan 

application to the Agency.

5. If the loan is a “Refer” or “Refer with Caution,” the lender’s underwriter must

manually underwrite the loan to determine if the applicants are creditworthy, in 

accordance with SFHGLP credit policies and guidelines. If approved, the lender’s 

underwriter will submit the file in GUS as a “Final Submission” to electronically 

transmit the loan application to the Agency. Additional documents are required 

for loans receiving a “Refer,” “Refer with Caution” or “Full Documentation”

recommendation.

6. Loans that are unsupported by GUS must be manually submitted and 

underwritten. However, the documents can be submitted through GUS. A job aid 
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for this type of submission is available in the USDA LINC Training and Resource 

Library in the “Loan Origination” tab located at

https://www.rd.usda.gov/page/usda-linc-training-resource-library.

J. GUS Underwriting Recommendations

Based on the analysis of credit, capacity, and other loan characteristics, GUS will 

render an underwriting recommendation. The recommendation is based upon the data 

entered in GUS with the representation from the lender that the data is true, complete,

accurate, and verified. The following represent possible underwriting recommendations 

with guidance on documentation to be submitted to the Agency when requesting a 

Conditional Commitment for Loan Note Guarantee.

ACCEPT/ELIGIBLE Underwriting Recommendation

Minimal documentation provisions apply to GUS underwriting recommendations that 

receive an Accept, unless a quality control message on the GUS Underwriting Findings 

Report indicates an Accept with Full Documentation file is required. A quality control 

message requiring a full documentation file will appear on the GUS Underwriting 

Findings Report upon final submission. Lenders should submit full additional 

documentation files as noted in Attachment 15-A, Loan Origination Checklist, for files 

for that receive GUS underwriting recommendations of Accept with Full Documentation. 

If the property is located in a community property state and there is a non-purchasing 

spouse, additional documents may be required. 

Accurate data is the responsibility of the approved lender. By submitting the 

mortgage loan application request through GUS as a final submission, the lender is 

representing that the data input is true, complete, accurate, and verified. Underwriting is 

the responsibility of the approved lender. Lenders are required to review the results of 

the GUS Underwriting Findings Report and credit reports. If necessary, make data 

changes and resubmit the loan to GUS. Approved lenders then make a lending decision 

using the Findings Report obtained from GUS, credit report(s), stable and dependable 

income, employment, assets, collateral, and other file documentation.

During the review process, should data appear to be questionable, the Agency 

reserves the right to request further supportive information. Files may be selected for full 

file review if the lender is a new user to GUS, has demonstrated a disregard for Agency 

policies and procedures, has a high first year delinquency rate, or loss payments in excess 

of the national average. Randomly, full documentation of a file in lieu of minimal 

documentation noted above will be requested when receiving an underwriting 
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recommendation of Accept. This random selection is for quality control purposes. A 

message on the lender’s final pass of underwriting will confirm when a full 

documentation file is required. Full file documentation reviews are to confirm the data 

input into the GUS file accurately reflects that of the lender’s file and documentation.

Mortgage loan documents will be delivered electronically through GUS. In cases 

when the system may be unavailable, or a transition to the system is occurring, 

documents may be delivered by encrypted email to the appropriate production team at

https://www.rd.usda.gov/page/sfh-guaranteed-lender. It is anticipated that all lenders will 

utilize the automated method when available. 

ACCEPT/INELIGIBLE Underwriting Recommendation

Loans receiving this recommendation have been determined as meeting the SFHGLP 

risk standards for loan guarantee; however, do not meet certain eligibility guidelines. 

Typical reasons for an Accept/Ineligible recommendation may include:

• Property is not located in a rural area

• Income exceeds Agency guidelines

• Non-owner occupied transaction

Loans that receive a recommendation of Accept/Ineligible may still be eligible for a 

SFHGLP loan guarantee. To achieve eligibility, the lender’s underwriter should analyze 

the findings report and determine the basis for the ineligibility and determine if the reason 

for ineligibility can be resolved in order to comply with Agency guidelines. Issues that 

caused the loan to be ineligible may be resubmitted to obtain an updated underwriting 

recommendation.

REFER or REFER WITH CAUTION Underwriting Recommendation 

GUS loans receiving an underwriting recommendation of Refer or Refer with Caution 

will require the lender’s underwriter to perform a manual underwriting evaluation of the 

mortgage loan application to determine if applicants are creditworthy in accordance with 

SFHGLP credit policies and guidelines. Risk factors have been identified based upon the 

data entered in GUS. The credit risk evaluation represented by a Refer with Caution is 

greater than the credit risk of loans that receive a Refer. Lenders should practice extreme 

care in their underwriting analysis and decisions when underwriting a loan file receiving 

a Refer or Refer with Caution recommendation. Lenders must submit additional 

documentation as noted in Attachment 15-A of this Handbook for files that receive GUS 

underwriting recommendations of Refer or Refer with Caution. Credit documentation, 
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mitigating circumstances, and compensating factors considered in the manual 

underwriting analysis should be recorded in the lender’s permanent case file. 

Compensating factors considered in the evaluation of the mortgage loan application

should be documented on the underwriting analysis and summary (typically the Uniform 

Underwriting Transmittal Summary – FNMA Form 1008/Freddie Mac Form 1077 or 

equivalent).

Loans should not be approved or denied solely on the basis of a risk evaluation 

generated by GUS. Mitigating circumstances according to Agency standard guidelines 

may be considered.

K. Lender’s Reliance on the GUS System

 Lenders represent and agree that they will not rely principally or exclusively on the 

GUS system in determining whether credit will or will not be extended to any applicants. 

The lender remains responsible for the loan qualifying decision in addition to eligibility 

of the household for the SFHGLP. 

L. Lender’s Permanent Loan File - Documentation Requirements 

The lender’s permanent case files must be supported with the following verified 

documentation, regardless of the GUS recommendation:

• Credit history;

• Adjusted Annual Income – determined for program eligibility;

• Stable and Dependable Income – determined for repayment and qualifying 

purposes;

• Assets – for income calculation, conventional credit test, and compensating factor 

analysis;

• Collateral requirements; and

• Any other documentation supporting the mortgage loan request.

Stable and dependable income will be documented in accordance with Chapter 9 of 

this Handbook and remains the responsibility of the lender. GUS does not evaluate or 

predict the stability of an applicant’s continuance of income. This determination is 

performed by the lender prior to final submission of an application.
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M. Resubmission Policy

The lender is responsible for the integrity of the data used to obtain an underwriting 

evaluation in GUS. If data changes during the loan application stage, after Conditional 

Commitment or prior to loan closing, the GUS underwriting recommendation could be 

compromised. Lenders are responsible for resubmitting the loan to GUS when material 

changes are discovered. Lenders must follow the Conditional Commitment guidance 

outlined in Paragraph 15.7 of Chapter 15 of this Handbook prior to closing a loan. Any 

request to release GUS for data updates after issuance of a Conditional 

Commitment will be treated as a new request, processed in date order of 

applications received.

Under the following conditions, lenders must resubmit the loan through GUS for an 

updated evaluation:

• Applicants were either added or deleted from the loan application or critical 

information has changed.

• A decrease in the applicants’ income and/or cash assets/reserves. 

• An increase in loan amount or interest rate on the mortgage loan request.

• Any changes that would negatively affect the applicants’ ability to repay the 

mortgage.

The lender should submit a request via e-mail to the appropriate production team at 

https://www.rd.usda.gov/page/sfh-guaranteed-lender, requesting the loan be released 

from the Agency to the lender. The lender should modify the data and resubmit the loan 

through GUS for an updated final evaluation underwriting recommendation. 

Some data changes do not affect the outcome of an underwriting recommendation. 

Once a mortgage loan has been sent to the Agency as a “Final Submit,” the following 

data changes do not require that the GUS loan application be updated:

• A decrease in loan interest rate 

• A decrease in loan amount 

• A decrease of mortgage or personal liabilities

• An increase of assets
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• The bureau update of a credit report due to the expiration of the credit report 

(expires at 120 days prior to loan closing) after a final submit has occurred by the 

lender and a Conditional Commitment has been issued; yet prior to loan closing 

as long as no adverse impact has occurred that would affect the outcome of the 

underwriting recommendation. The lender must retain the updated credit report in 

their permanent case file.

N. Lender’s Representations to the Agency upon Final Submission

The lender represents as of the date of final submission to the Agency the following:

• All terms, conditions and requirements of the SFHGLP are fully satisfied.

• All representations submitted by the lender are true, correct, and verified.

• The lender is in compliance with the criteria outlined in Chapter 3 and eligible to 

participate in the SFHGLP and utilize the GUS System.

• The lender has not misstated or omitted any material fact about the mortgage loan 

request for guarantee.

• Applicable laws, including state laws, terms of the note, and security instruments 

have been correctly and timely disclosed to all applicants.

• The lender represents that all persons executing documents on behalf of the lender 

are duly authorized to do so.

O. Termination

The Agency reserves the right to terminate the lender’s approved lender status in the 

event of any default under the terms of the lender agreement.

A lender’s suspension, withdrawal, or termination of approval to participate in the 

SFHGLP may be pursued if (not all inclusive):

• A lender fails to provide the Agency with information that is true, complete and 

accurate. 

• Omission of any material fact on any application, other documents, or oral 

representation made to the Agency when seeking a Loan Note Guarantee.
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• A lender has a 30-, 60-, or 90- day delinquency rate or loss claim rate more than 

50% higher than the average 30-, 60-, or 90- day delinquency rate or loss claim 

for all guarantees issued in the Agency’s portfolio. This can be measured within a 

geographic area of the nation.

• Misuse of GUS in accordance with terms and conditions of the agreement to 

utilize the System.

Emphasis of any evaluation conducted will be placed on the risk that the loan(s) poses 

to the Agency.

Agency Actions

• Initially, contact the lender to ensure a firm understanding of the lender’s terms 

and conditions of the lender agreement. Firm evidence of any violations must be 

discussed and addressed.

• Follow up the initial communication with a written notice outlining the agreed 

upon plan to improve.

• Allow a lender a reasonable time frame to institute a remedy and represent 

improvement to the identified findings.

• Monitor the lender for improvement.

• After continued evaluation of findings and results to improve, if the lender fails to 

comply, their approved lender status may be revoked.