Connecticut Executive Order 7Q Does Not Meet Updated Fannie Mae and Freddie Mac Guidance On Remote Online Notarization and Could Prevent Purchase of Mortgage Loans
CATIC agents should be aware that the Government-Sponsored Enterprises,
Fannie Mae
and
Freddie Mac
(the GSEs), recently updated their guidance relative to mortgages executed by remote online notarization (RON).
The GSEs have published minimum standards for RON that must be met in order for a mortgage to be qualified for purchase.
These standards include:
- Multifactor identity authentication, including a government-issued credential with a signature, credential analysis, and identity proofing;
- Tamper-sealed notarized documents;
- Use of a notarization system that is secure to:
- Prevent interference with the authenticity, integrity, and security of the notarial ceremony and the recording of such ceremony,
- Protect the communication technology used to conduct the remote notarization along with the electronic record and backup record from unauthorized use;
- A secure electronic journal used by the notary to document the notarial act, including evidence of the signer’s identity and a backup of the electronic record; and
- A recording of the notarial ceremony that must be maintained for at least seven (7) years, unless otherwise required by applicable state law.
Connecticut Executive Order 7Q does not appear to meet these standards, and notarizations conducted under the requirements of this Order may not be acceptable to the GSEs.
Click here
to see how Fannie Mae and Freddie Mac’s guidance compares to the requirements for remote notarizations under Executive Order 7Q.
CATIC advises its agents representing mortgage lenders, that
if you have conducted a notarization under Executive Order 7Q you should contact and advise your lender immediately as to the risk and corrective options.
Further, if agents intend to use RONs, they should ensure that they meet the standards set by the GSEs if possible.
Should you have any further questions about these revised GSE requirements for remote notarization, please contact
Rich Hogan
, CATIC’s Chief Compliance Officer.
