The GSEs do not intend to require a lender to repurchase a mortgage loan started before the mandate date solely due to the lender’s use of the legacy AUS data format with the redesigned URLA (and vice versa). However, it is a lender’s responsibility to ensure the data used to underwrite and determine eligibility is accurately reflected in the transaction, and that the lender has otherwise complied with the terms of their contracts with the GSEs. Lenders must apply all policies that may or may not be represented on the new vs. old URLA form and included or not included in either of the GSE’s data file formats: MISMO v2.3.1, v2.4, v3.4 or the RLD 1003, v3.2 (1003 Flat File).
From the FNMA/FHLMC August 2020 Publication “Uniform Residential Loan Application (URLA) / Uniform Loan Application Dataset (ULAD) FAQs”
On April 14, 2020 the GSEs announced an extension to the URLA implementation timeline to support the industry in its response to COVID-19. The redesigned URLA effective date has been extended to January 1, 2021. Industry participants may start submitting updated AUS files to the GSEs on or after this date. The mandate date for delivering MISMO v3.4 AUS files to the GSEs has been changed to March 1, 2021. The GSE’s AUS systems will continue to accept the legacy formats for all loan application submissions until the mandate.
From the FNMA/FHLMC August 2020 Publication “Uniform Residential Loan Application (URLA) / Uniform Loan Application Dataset (ULAD) FAQs”
No, the redesigned URLA cannot be used with the existing AUS formats. After the GSEs begin accepting the new format, lenders using the redesigned URLA must use the updated AUS Specifications for each GSE.
If a legacy AUS file is submitted prior to the mandate date, the submitted file may remain in the legacy format. The lender may complete the loan using the 7/08 (rev. 6/09) URLA, even after the mandate if they submitted the file using the legacy format. However, all new applications submitted after the mandate will not be accepted if submitted using a legacy AUS file format.
From the FNMA/FHLMC August 2020 Publication “Uniform Residential Loan Application (URLA) / Uniform Loan Application Dataset (ULAD) FAQs”