Documents held by a third party custodian for financial assets pooled into an asset-backed security or held as whole loans must satisfy program compliance requirements for safekeeping, certification, release, and reporting. These requirements vary by investor program, real estate laws, and custom service contracts negotiated between the custodian and each of their customers. While contracted by the issuer of a security, the document custodian is also accountable to the investor of the asset backed security and the program guarantor (if applicable). The document custodian is responsible for independent verification and reporting of the existence, location, and status of all required documents to be held in order to meet program requirements. The document custodian is responsible for independent verification of critical information about each asset as represented by the issuer of the security and for reporting that information to the program guarantor.
Document custodians are responsible for controlling original documents on a large scale. The control objectives for the document custodian are to accurately account for all documents whether or not received; to manage the risks associated with receiving, storing, releasing, and otherwise handling documents while in possession; to accurately report required facts and status of each document; and to release documents only to authorized requestors and in accordance with authorized procedures for change in possession. Document custodians manage physical and electronic vaults to separately manage but transparently account for a mixture of physical and electronic documents held for a given asset.
Document custodians will have information systems to help them meet their control objectives, and remain in compliance with program requirements, which are subject to frequent independent audits.
We support document custodians through three main tools; the emBTRUST System-Of-Record platform, the MBMS Electronic Vault, and the MBMS Loading Dock consisting of fundamental designs and components:
emBTRUST is the primary source of data, rules, functionality and reports used by the line of business to fulfill its mission. It includes transaction processing, real-time and batch query capabilities for monitoring each customer's portfolio. emBTRUST systematizes business knowledge and business logic, and contains numerous audit logs to monitor and control the line of business activity.
- Account and Pool Tracking
- Document Certification Rules
- Document Set Rules
- Collateral Audit Lists
- Document Package Review Process
- Pool Stratification Tools
- Document Location Tracking
- Release Verification and Audit
- Asset Reconciliation
- Variable Pricing rules
- Configurable edit checks
- Authorized Bank Account Controls
- Authorized Closing Agent Controls
- Authorized Investor Controls
- Interest Accrual / Repurchase Accounting Policy
- Fee Accounting
- Participation and Syndication Accounting
- Transaction Journals
- Rules Execution Audit Logs
Using these business support capabilities, delivered through our .NET solution architecture that we use for all of our systems, we help Custodians successfully implement and maintain effective collateral, document, and exception controls that help them effectively handle a wide number of use case scenarios.
Use Case Scenarios
- Fannie Mae MBS program
- Freddie Mac PC program
- Ginnie Mae MBS program
- Private Label MBS programs
- Warehouse Facilities
- Internal Records Management
- Post Closing Document Tracking
- Initial Certification
- Final Certification
- Pool / Collateral Transfers
- Note Reconciliation
- Payoff Requests
- Invoicing for storage, activity
- Agency Reporting
- Agency Systems integration