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Issuers press Ginnie Mae on bankruptcy, forbearance and code 042 during PDS webinar Q&A
Summary
In a lengthy Q&A, issuers asked whether event codes such as bankruptcy and foreclosure should be reported only when they occur or repeated over multiple months, and whether forbearance and trial plans must be carried forward; Ginnie Mae acknowledged ambiguity in Appendix 6‑22 and said it will update the appendix while accepting current practices for go‑live.
Issuers on the call pressed Ginnie Mae staff for operational guidance about several recurring reporting questions ahead of PDS go‑live. The most persistent themes were whether codes that describe events (for example, a bankruptcy filing or the initiation of foreclosure) should be reported only once when they occur, and how forbearance and trial repayment plans should be carried forward from prior months.
Ravi Chandra asked whether the default reason code should reflect historical contact notes or the current reporting month. Christy Christensen said that "the default reason code needs to be reported for the correct default reason code every month," and that issuers should supply the code that accurately represents the reporting month, carrying forward historic values only when they match the current month.
On bankruptcy, attendees noted that some servicers currently send a bankruptcy code each month while others report it only when it is filed. Matt Tetelbach said the guidance in Appendix 6‑22 treats many items as event based (reported when they occur) but acknowledged that issuers who report bankruptcy monthly will not trigger exceptions; Ginnie Mae said it will update Appendix 6‑22 in the coming months to provide clearer direction.
There was clearer direction on forbearance: presenters said forbearance codes (for example codes cited in the training) are to be reported each month while a forbearance is active, and that the supplemental forbearance file should be continued in parallel with PDS for six months (Modernization Bulletin 54). "If you are reporting a forbearance action code, you will need the term every month," Christy said.
Other clarifications from the Q&A included: trial repayment plans (code 091) should be reported when required payments occur in the reporting month; a one‑time event code (such as the first legal action to file foreclosure) is reported once with the event date (code 068 was discussed as the “first public legal action” one‑time code); and that Ginnie Mae will post an updated slide and corrected presentation file with the clarified guidance.
Ginnie Mae staff encouraged issuers to consult Appendix 6‑22 and the modernization bulletins for definitive code definitions, urged issuer teams to coordinate with vendor or service bureau partners, and offered AskGinnieMae@hud.gov as the contact for follow‑ups. They also said they would email specific clarifications raised during the webinar.
The webinar’s Q&A highlighted a practical tension: servicer systems and vendor solutions vary in whether they capture only events in the month of approval or maintain a live status for ongoing conditions. Ginnie Mae said it recognizes both operational realities and will update its guidance to reduce ambiguity before later reporting cycles.
