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FHFA Adverse Market Refinance Fee
On 8/25/2020, FHFA directed Fannie Mae and Freddie Mac to delay the implementation date of the adverse market refinance fee until December 1st Purchase Date. Most investors have applied the fee based on lock date which we feel is too inflexible. Instead we will be applying the 50 bps LLPA for any Conventional Refinance which has an Expiration date on and beyond November 4th. Any refinance that expires prior to November 3rd but is subsequently extended will have the LLPA applied.
The fee will not apply to HomeReady, HomePossible and conventional refinances with loan balances below $125k. If a loan is locked with a loan balance less than $125k and subsequently raised above $124,999, the LLPA will apply.
Effective Dates by Lock Period
>=45 day locks beginning 09/21
>=30 day locks beginning 10/06
>=15 day locks (All lock periods) beginning 10/21
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