What if I cannot obtain tax transcripts that are required as part of my post-closing QC process?
If verbal or electronic reverifications cannot be completed, lenders can complete the file review without the reverification. However, lenders must:
- internally track all loans that did not have a successful reverification attempt during this time, and
- conduct a special discretionary sample of such mortgages and perform the required reverifications on the sample population upon the expiration of the flexibilities contained in Lender Letter LL-2020-03, Impact of COVID-19 on Originations.
As a reminder, the reporting requirements of D1-3-06, Lender Post-Closing Quality Control Reporting, Record Retention, and Audit continue to apply with respect to this special discretionary sample(s).
Reminder: Lenders should prioritize execution of IRS Form 4506-T in the special discretionary sample(s) based on the expiration date of the IRS Form 4506-T.