Document Custodians

Related-party document custodians, defined as either the Issuer acting as the document custodian (self-custody) or an affiliate of the Issuer acting as the document custodian, are subject to additional requirements. These requirements include:

• Self-custody:

  An Issuer that meets the requirements of Part A, General Eligibility Requirements for document custodians, may perform the custodial functions required in this Manual for its own issuance activities, but only if:

  • the issuer has a trust department with fiduciary powers in accordance the requirements of Section A(10), Possess Fiduciary Powers;
  • Such trust department is vertically independent from the Issuer’s mortgage loan origination, servicing or selling functions. Neither the trust department, nor any of its principals, officers, or employees, may be directly or indirectly supervised by any principal, officer, or employee of the Issuer’s mortgage loan origination, servicing, or selling functions;
  • The trust department maintains personnel that is different and separate from any personnel within the Issuer’s mortgage loan origination, servicing, or selling functions, and;
  • The custodial functions are performed by the trust department described herein.

• Affiliated document custodian:

  Document custodians may not provide the custodial functions required by this Guide for any Affiliate unless the following two conditions are met:

  • First, the document custodian must meet and continue to satisfy the requirements of Part A, General Eligibility Requirements for Document Custodians; and
  • Second, the document custodian must be, and remain, vertically independent from the Affiliate Issuer. For purposes of this requirement, the document custodian is not vertically independent if:
    • its principals, officers, or employees are directly or indirectly supervised by the Affiliate Issuer;
    • it must report to its controlling entity or another Affiliate through the Affiliate Issuer or any of the Affiliate Issuer’s employees, or;
    • the document custodian, its principals, officers, or employees are supervised by an Affiliate that is controlled by the Affiliate Issuer.

The document custodian function must be subject to periodic review and inspection by the primary regulator.

Before executing a Master Custodial Agreement, an institution must obtain a Ginnie Mae document custodian identification number as specified in Chapter 2-E of the Document Custodian Manual(Appendix V-1) of the Ginnie Mae Guide. An on-site evaluation of the site and review of eligibility evidence may be required prior to the issuance of the custodian identification number.

The identification number must be placed on all documents on which the document custodian's name appears.​

Ginnie Mae invites all document custodians to participate in its Document Custodian Outreach Conference Calls.

The outreach conference call schedule will be published as it established:

Each conference call will be held from 1:00 - 2:00 p.m. EST.

Document custodians can participate in these quarterly outreach conference calls by calling (877) 336-1839 and using participant code 6013905.

If you have any questions about these quarterly outreach conference calls, please send an e-mail to GinnieMaeDocCustody@HUD.gov.